Virginia has a problem with data centers.  It created tax exemptions to draw them in.  Northern Virginia is situated near a bloated federal government that needs a place to store all its data.  And "data center alley" was born.  It has since reached outlandish proportions, and more data centers are being approved every day.  Data center sprawl is a serious problem.

Perhaps the biggest problem for the largest concentration of data centers in the world is powering them all.  Data centers use huge amounts of electricity, and as new technology created more ways for data centers to burn electricity, it soon became impossible to power them with the electricity available.  Couple this with state "clean energy" policy that prohibits the building of any new fossil fuel generation, and you've created a recipe for disaster.

This disaster recently manifested as PJM's 2022 Window 3 transmission plan.  Regional grid operator and planner PJM Interconnection was tasked with finding a solution to the closing of 11,000 MW of existing fossil fuel generation in Virginia and Maryland combined with 7,500 MW of new data center load in Northern Virginia.  PJM did the only thing it knows how to do... create new electric extension cords across the region that will import electricity to data center alley from fossil fuel generators in other states.  The only two states in PJM that export electricity are Pennsylvania and West Virginia, where coal is still king.  Pennsylvania produces electricity mainly from natural gas and nuclear, with a significant amount of coal still in its mix.  West Virginia's electricity mix is over 90% coal.

The new extension cords are 3 new 500kV transmission lines pumping electricity to data center alley from Pennsylvania and West Virginia.  It's bad enough that the new extension cords will plow through communities in other states, expanding transmission easements and cutting new ones, but PJM also expects electric customers in other states to pay for a significant share of the cost of these new extension cords.  What do Pennsylvania and West Virginia get from this?  New transmission lines, property destruction and devaluation.  They don't get any electricity... that's all going to Northern Virginia.

When approving this destructive (and unlikely to actually happen) transmission plan, PJM selected the cost allocation scheme that spreads the costs of the projects as widely as possible across its region.  The thinking there is that spreading the $6B cost among as many people as possible won't be noticed by individual electric consumers.  If PJM allocated the costs solely to the causers of the new transmission lines (the state of Virginia) then the rate increases they cause will be very noticeable.  In fact, it may be so noticeable that businesses and residents may begin to leave Virginia for neighboring states where electricity is more affordable.

PJM is complicit with the State of Virginia to cover up its data center disaster by inflicting new transmission on other states instead of the state that caused it.  Sure, Virginia is being allocated a huge chunk, but not all.  Another huge chunk is still being spread among all PJM consumers as far away as Illinois, Indiana, Ohio, New Jersey, Kentucky, Tennessee, North Carolina, Maryland, Pennsylvania and West Virginia.  This is because PJM selected the cost allocation scheme that allocates 50% of the cost of the new projects to everyone in the region based on their peak load percentage from the prior year.  An area that uses a lot of electricity gets a bigger share, for instance electric customers in Northern Illinois are paying a larger share of this 50% than electric customers in Virginia that will actually use the electricity piped in on the new extension cords.  Why is anyone in any state other than Virginia paying for this new data center transmission?

The other 50% of the costs are allocated based on cost causation, with load areas at or near the data centers paying a higher percentage.  However, the load areas near the data center are enormous.  The Dominion zone where the data centers are being built also consists of customers in all parts of Virginia, plus some in North Carolina.  The Allegheny Power zone contains customers at/near the data centers, but it also spreads to cover a huge chunk of West Virginia and Pennsylvania.  Why are consumers hundreds of miles from the data centers paying so much money to build extension cords for Virginia's new data centers?  This isn't fair.

PJM's cost allocation schemes are part of its FERC-approved tariff.  However, PJM must receive FERC approval for each individual collection of transmission projects to ensure they have chosen the correct cost allocation scheme for the projects.  PJM filed to spread the costs across the region back in January, which opened a 30-day comment period.

While lots of entities intervened in the FERC docket for this cost allocation, only 3 comments were received.  That's right... only 3 entities thought this was unfair.  Two of them are residential ratepayers, and the other is the Maryland Office of People's Counsel.

I filed these comments.  I asked FERC to open an investigation into the justness and reasonableness of PJM's cost allocation and took the position that the "clean energy" policies of Virginia and Maryland caused the retirement of 11,000 MW of baseload generation in their states.  Also, only Virginia is responsible for the 7,500 MW of new data center load.  West Virginians should not be paying for these new transmission lines.  Being the "power house" for the electric supply for Virginia's data centers ties West Virginia into many more years of coal-fired electricity production.  Even if West Virginia wanted to close those old, dirty plants, they cannot because Virginia needs the power for their data centers.

Pennsylvania electric consumer Barron Shaw filed these comments.  Barron's comments are similar and underscore the way Pennsylvania and West Virginia are being used to power some of the wealthiest companies in the world.  People in Pennsylvania and West Virginia get little to no benefit from these companies or their new extension cords and will actually end up paying higher power prices in their own states as all the "cheap" electricity is sucked out of their own states to power a wealthier economy in Northern Virginia.  It's basic supply/demand.  Plenty of power makes cheap electricity prices.  When so much power is exported that electricity becomes scarce, prices rise.

Those two comments are probably understandable to the average reader.  However, the Maryland Office of People's Counsel also filed comments and expert testimony purporting that PJM picked the wrong allocation scheme and should have used the one that allocates all the costs to the state responsible.  PJM's other cost allocation scheme is called the "State Agreement Approach" and is used when a state agrees to shoulder the entire cost of transmission made necessary by its public policies.  SAA has been used for New Jersey's offshore wind planning.  PJM planned new transmission to support NJ offshore wind, and NJ agreed to pay for it.  Maryland OPC believes PJM must break down the suite of transmission projects to determine which ones are for other reasons, and which ones are for the data centers.  Once this breakdown is made, Virginia should be charged for the entirety of the data center portion.  Maryland's filing is probably a hard read if you don't speak FERC though, so read at your own risk.  It may seem like you're reading a foreign language.

Now it's up to FERC to decide... should electric consumers in other states be charged for Virginia's data center extension cords?  Maybe if Virginia had to shoulder the entire cost of its data center debacle it would have to realize that approving a whole bunch of new data centers comes at a cost.  Outrageous electricity prices in Virginia are the consequence of out-of-control development.  PJM is helping Virginia avoid the true cost of its policies and shuffling costs off onto other states that had no part in approving the data centers and certainly will not see any benefit from them.  PJM also selected new transmission projects that put most of the burden on other states.  PJM could have selected the proposal that kept new transmission lines in Virginia by connecting to AEP's 765kV transmission system west of Richmond.  But it did not.  PJM is complicit in Virginia's irresponsible energy policies and therefore responsible for the energy crisis that is the logical result of continued data center development.  Why, PJM, why?  

PJM won't be successful in getting all these new transmission lines built in other states, and certainly not by their projected "need" dates in 2027.  What then?  Will the lights go out?  PJM made the wrong choice and we're all going to have to pay.

That was the sentiment expressed by one Missouri farmer about signing an easement for Grain Belt Express under threat of condemnation and taking of an easement across his land by Chicago-based energy conglomerate Invenergy.  The same sentiment also applies to cooperating with biased liberal media journalists from back East.  You can cheerfully cooperate and welcome these people to your home and business and hope that they are guided by professionalism and decency to tell your story accurately, or you can refuse to talk to them and be labeled as a selfish, renewable-hating deplorable in abstentia.

The people of rural Missouri are some of the most welcoming, thoughtful, and brave folks that I have ever met.  Even when their gut told them that a reporter from The New Yorker was probably going to do a hit piece, they warmly welcomed him and cooperated anyway.  They didn't deserve this.

Here's the filter through which the reporter viewed his entire Midwestern experience:

This was the reporter's preconceived notion going into this article.  Nothing anyone said or did, or anything he saw, felt, or experienced, was allowed to interfere with this pre-determined outcome.

​What do you mean, "of course"?  That's the reporter's bias.  The two main characters he visited for this story obviously did not agree.  It's all about perspective... safety risks from GBE are guaranteed and immediate for the people who will have to live and work around it for the rest of their lives.  Climate change is a political  theory espoused by people like the reporter, who don't have to live and work around a dangerous invader every day.  GBE won't be outside his kitchen window every morning, and he won't have to drive huge farm machinery around giant impediments on his land numerous times every year.  GBE will not be personally affecting him so he is content to belittle its impacts on others in favor of his own armchair scientist theories.  The risk to Missouri farmers is REAL.  The risk to the reporter is a watered down possibility.  Get off your high horse, buddy, assuming you've ever even been on a horse, of course.

The article drones on about how wind and solar energy has not been successfully deployed, and that it will require enormous sacrifice to ever work as a dependable source of electricity.  Instead of contemplating, perhaps,  whether wind and solar is not a realistic future energy source because it isn't progressing, the reporter  doubles down on a bad idea by believing transmission lines like Grain Belt Express can be the turning point to success.  It can't.  Wind and solar are not the answer for our energy future.  It's too expensive, too invasive, and unreliable.  It's actually making our entire electric system incredibly fragile.  We need to abandon this bad idea in favor of new technology that can produce the energy we need where we need it when we need it.  I haven't heard any talk that we need enormous amounts of new transmission for new-age nuclear generators.  Wind and solar is an experiment that didn't work, but it made a lot of investors very rich and they don't want to let go of their golden goose, even if it is for the betterment of society.

The reporter's portrayal of Loren Sprouse and Marilyn O'Bannon as "holdouts" against a "better grid" is unfair.  Both Loren and Marilyn have selflessly devoted themselves to careful and deliberate examination of the issue and spent their personal time and money standing up for the rights of farmers.  They did the right thing. 

The reporter fails to mention that Loren is a knowledgeable electrical engineer and preferred to portray him as an uneducated rural farmer.  When Loren worries about GBE's interference with GPS, he's basing it on REAL studies and, more importantly, real experience using GPS systems to farm.  As if Loren's educated concerns can be alleviated altogether because the reporter managed to find a Canadian study that said there was no problem.  Neither the reporter or the Canadian study author will be in the cab with Loren when his GPS system is scrambled or temporarily disabled.

When Loren says that GBE could have been designed better, he's expressing an educated opinion.  Numerous other HVDC transmission lines have been proposed and built underground on existing road/rail rights-of-way.  Choosing to reject that and instead swallow a great, big mouthful of Invenergy's excuses for not burying its line demonstrates the reporter's bias and ignorance.  Grain Belt Express was planned more than a decade ago based on a bad idea for cheap, overhead lines across private property.  GBE has poured millions of dollars down the drain trying to force its cheap, overhead project on private landowners over the last 15 years.  At any time it could have stopped and investigated whether there was a better way to do things.  But it did not.  Perhaps if GBE had stopped throwing good money after bad 10 years ago, it could have used all the money it wasted on lawyers, lawsuits, environmental studies, experts, land acquisition, and buying advocacy to bury its line on existing rights-of-way instead.  Perhaps if it had, GBE would be built and in operation right now.

Instead, it's barely limping along a road so lengthy it cannot see the end.  GBE doesn't have county assents in Missouri, its Illinois permit is being appealed, it has not announced enough customers to pay for the line (and in fact doesn't even have permission to negotiate with customers), it has not secured its financing, it doesn't have all the land it needs, its interconnection has been delayed 3 years, and it's now facing competition from new transmission planned to be built by regional grid operator MISO.

Marilyn O'Bannon is one of the nicest, most thoughtful ladies I've ever met.  But she's not a pushover.  This brave lady didn't just complain when GBE showed up in Missouri, she stood up and fought for everyone.  She was instrumental in forming a landowner group, fully participating at every opportunity, and she pushed herself to leave no stone unturned in her quest for justice.  She went on to become a popular county commissioner, taking on a leadership role when people needed her most.

It doesn't matter what she was wearing, or what she was driving, or what various characters in the story ate for that matter.  The part about the Escalade was touching... but he forgot to mention that Marilyn intended to take him around the farm in a pick up, the vehicle of choice for just such an adventure.  However, when they got outside, they found all the pick ups were in use around the farm doing actual farm work.  She could have sent him packing, or cancelled the tour.  But instead, she took her 6-year old Escalade, used to go to town, not putter around the farm.  And for that, she gets slyly attacked, like she has no right to own or drive such a car while opposing GBE's invasion of her farm.  What  is she allowed to drive to become a sympathetic character in this story?  A totally inappropriate (and much more expensive) electric coupe?  The reporter, who may or many not even own a car of his own, had no idea why a farmer may have more than one vehicle, each for a different purpose. 

I found the focus on Marilyn's outfit downright creepy.  Five-pointed stars on her shirt?  What does that even mean?  Who cares?  The trucker's hat on the counter... was he sad it wasn't on her head to complete his irrational attack on her character?  I'd bet that reporter would covet just such a cap if a filthy rich corporation came to take his land, or his family's land, for its own profit.  Nobody knows what eminent domain feels like until it happens to them.  It's a devastating punch to the gut, not a slogan used to make ad hominem attacks on people unlucky enough to experience it.

The quotes attributed to Marilyn regarding climate change are manufactured, she claims.  Marilyn shared that she was recently contacted by a New Yorker "fact checker" to make sure the quotes in the story were correct.  Although she said they were not, it didn't matter.  They stayed in the story.  That's all we need to know to dismiss this article as a pre-planned hit piece.

At the end of the day though, nobody in rural Missouri reads The New Yorker.  It doesn't matter to them or their battle how they are perceived by eastern city dwellers.  What does matter is that Marilyn, Loren, and others graciously hosted a stranger and told their story honestly.  That the reporter couldn't accept it because it didn't fit with his pre-determined agenda is all on him.  Do unto others as you would have them do unto you.  It's a good way to live.

What does "collaboration" mean?

NextEra, one of the utilities assigned to build PJM's coal-fired transmission extension cord from West Virginia to the data centers has been bandying that word about, but I don't think they know what it actually means.  If they actually do know what the word means, then they must be intentionally rebuffing concerned citizens while pretending they are "collaborating."  Either way, it's disingenuous.  And it will be the root cause of future project delay... and ultimate failure.

MidAtlantic Resiliency Link partner NextEra has begun its "collaboration" with a shell of a website.  The website says:

The website includes a form at the bottom if you "have questions."  This seems to be the only avenue for a concerned citizen to begin "collaborating" with NextEra.

​So, I did.

This is what I'm talking about. 

It's a conceptual point-to-point connection from coal-fired generators to data centers that has not been subject to the "routing" lens.  You can see a bigger version here on slide 41.  When routed directly from generator to load, this line does not cross Jefferson County, WV and does not require a new 500kV transmission line across Loudoun County.  So, is it even being considered?  Yes or No?

NextEra's reply sounded like it was written by a Magic 8 Ball.

MARL Team members?  How many were crowded around the keyboard typing that reply?

Yes or no?  Can I get an answer here?  I tried again:

And here's the reply from "the Team."

Is that a yes?  I don't think so.  If the answer was simply "yes" then none of that other stuff was necessary.  So, this must mean the answer is actually "no"?  But our slippery "Team" can't actually "collaborate" with anyone to answer a very simple and basic question.  How is any "collaboration" happening when inquiries are met with total nonsense and local communities are being rebuffed from participating in the routing process?  

So, I tried one last time to appeal to "the Team's" strategic thinking (such as it may be):

Well, I guess I must have hurt "Team's" fee-fees because I haven't heard from them at all this week.

I guess I'm going to have to "collaborate" with myself to answer my own questions.  No big deal, I've been doing this for more than 15 years now.

Who are the “stakeholders” if they are not local communities, regulators and landowners?

Perhaps they are greedy elected officials, lobbyists, the data centers, other corporations with tons of money, astroturf front groups, hired advocates, environmental and other special interest groups whose agenda can be directed with generous donations, and other entities nowhere near the proposed route.  Why would any of these "stakeholders" have an interest in the route of the project?  It's not going to be in their backyard.  In fact, they may only be "stakeholders" in order to make sure it doesn't end up impacting any of their own interests and, instead, impacts yours.

What are the technical specifications of the project?

I think the technical specifications of the project are to connect over 10,000MW of coal-fired electric generators in the Ohio Valley to data center alley via a new 500kV electric transmission project.  Of course, this has no correlation to routing... the project could go anywhere and still make the connection.  But it's supposed to sound official and you're not supposed to question a statement like this because you're supposed to be dumb.

​What are the economic needs of the project?

This one is easy!  Let's refer to PJM's Constructability and Financial Analysis Report for this project.  NextEra bid that it could complete MARL for $683.5M.  PJM's analysis of project cost put the project more in the neighborhood of $1.2B, a 30% increase.  But, hang onto your wallet... NextEra included a contingency budget of 14%.  NextEra also offered some cost control promises.  NextEra's Return on Equity is capped at 9.8%.  Its equity share is capped at 45%.  These numbers are important because the ROE is the amount of interest NextEra earns on the capital costs of MARL for the next 40 years while we slowly pay them back for the project (think mortgage, or car loan, where you finance a big purchase over time).  NextEra can only contribute 45% of project costs that will earn that 9.8% ROE, the other 55% of project costs will have to be debt, which we repay at its own interest rate.  NextEra offered a "soft cap" on its expenditures that promises any expenses that exceed the estimate earn no return at all -- 0%.  However, regardless of any of these provisions, NextEra's earnings cannot be lower than 7 or 7.5%.  Then NextEra promised a schedule guarantee that the project would be completed by its June 2027 deadline.  For each month the project is delayed past then, NextEra's ROE falls 2.5 basis points, with a maximum drop of 30 points.  What is a basis point?  100 of them make up 1 percent of the ROE.  Therefore, a 9.8% ROE contains 980 basis points.  

Wow, we're just going to be saving buckets of money here!  Or maybe not.  Anyhow, all this is relevant to know that NextEra must control its costs.  It cannot make any routing changes that increase its costs such as different routes, different structures, different land acquisition.  NextEra is also sensitive to staying on schedule.  If "collaborating" with you delays things, then your opinion doesn't matter.

What are the “regional reliability needs” criteria of the route?

This is pretty nonsensical.  Regional reliability needs are rooted in technical specifications and inservice date.  The "Team" is just repeating itself and trying to make it sound like something different.

Yesterday, I was reading a news article about MARL and I ran across the same ridiculous phrases that populated. my own email exchange with "the Team."  Maybe "the Team" is nothing more than an automated robot choosing from a list of approved phrases to respond to inquiries that are used by many big companies.  If so, is it programmed to "collaborate" or simply to pretend?

Do you trust NextEra?  I don't.  NextEra can't answer a simple question.  Much of what they said is meaningless gibberish.  Trust is first and foremost and NextEra has already blown it.  Of course, gaining the trust of a public that suspects NextEra wants to take their property and construct a huge transmission line on it is an uphill battle to begin with, but hiding behind "the Team" and refusing to answer a simple question with a straight up answer destroys whatever trust ever might have existed.  Get your information elsewhere.

True "collaboration" on developing a project route means that impacted communities should be participating in the route development and evaluation process.  However, they are not.  Instead, NextEra is developing the route all on its own, using its own criteria, and will only "collaborate" with the community to show them the finished route selections and accept their feedback.  None of the routes are proposed by impacted communities.  Impacted communities are estranged from NextEra's actual routing process.  This isn't "collaboration."  It's route consultation by fait accompli.

And that never works.  Impacted communities want to know what problem is being solved and to be active collaborators in developing the solution.  Keeping them in the dark until the route is selected is not "collaboration."  It's a route developed in a silo.  And it's a recipe for project delay and failure.

You just can't trust the media these days.  Instead of impartially reporting the news anymore, many major media outlets are engaged in pushing the propaganda of energy companies and political goals.  Case in point:  This article about a solar farm in Michigan.

The "victim" in this article is a landowner who needed money and decided to lease her ground to a solar company.  Neighbors objected to the solar farm so local zoning got changed and the project was blocked.  Isn't that democracy at work?  The needs of the many trump the needs of the few.  Local governments have become ground zero for land use issues, and the voters drive acceptance or rejection.  But for some reason, the media presented the story to make the voters the bad guys and the few the "good guy."  Of course this isn't how democracy works, but somehow this anti-democratic rhetoric was championed in the name of "clean energy."  That is, the government should be allowed to dismiss the concerns of the voters if it's about a clean energy project.  There, the few rule supreme.  This is about huge multi-national corporations making money building things we may or may not need in our own communities.  We no longer have a voice in our local affairs.  The article touts policies in several states where state level government can overrule local government and direct land use in the locality.  Is this a good idea?  The article tries to make you think so, but if you extrapolate this out to things like data centers, Walmarts, and polluting factories, the supporters of state rule suddenly think it's not a good idea.  It's hypocrisy, plain and simple.

We are constantly told that rural areas must make a sacrifice to create and transmit "clean energy" for urban areas that don't want to put that stuff in their own community because... you guessed it... their voters object to that use of remaining open space.  How about a little empathy?  If you don't want it in your backyard, we don't want it in ours, either.  Urban areas are not "more special" where they can push energy impacts off onto less fortunate and politically-connected communities in order to save themselves.  This is the rich and politically powerful enslaving the rest of the country... so they can live well in their own communities and not give "those people" another thought.  Some of them tell themselves that "those people" like being their slaves and that they should be congratulated for giving "those people" an opportunity to "be heard."  What good is "being heard" when nobody listens?  Giving "those people" an opportunity to shout into an empty well before you run them over is not democracy.

When did our energy system stop becoming democratic?  It never actually was.  It was designed for benefit of corporations, and those corporations are still the ones who benefit.  Pretending that "everyone else" loves clean energy and transmission when it is sited on someone else's property, is not democracy, it's corporate-fueled mob rule.  And somehow rural property owners protecting the land that produces their income are the demons, the NIMBYs.

NIMBY stands for "Not In My Back Yard."  NIMBY is name-calling at its most basic level.  Calling opponents "NIMBYs" does not deal with their arguments in a logical way, it simply directs the reader to dismiss the NIMBY altogether and not listen to his arguments because they must be "selfish."  Who's the real selfish person here?  The person trying to protect himself from invasion, or the person doing the invading in order to protect himself from a similar invasion?  Corporations who stand to make big bucks exploiting rural landowners are quick with the NIMBY label.  They also try to shut down any NIMBY arguments by claiming they are "misinformation."  And they further demonize the NIMBYs by falsely claiming that they are organized and funded by corporations and mysterious "national organizations."  All this adds up to censorship of "those people" by turning them into unacceptable groups who are so extreme that they should not be allowed to speak out or object in any way to the invasion.

Case in point:  This article demonizing NIMBYs.  The author is a real jerk, pretending he's Mr. Science and is somehow figuring out NIMBY motivation.  Poor fella, he has no idea what motivates "NIMBYs" and never will until he actually becomes one himself.  You cannot truly know how another man feels until you walk a mile in his shoes.

He also doesn't get the reason why thousands of unaffected "YIMBYs" don't show up to shout down the NIMBYs, acting as his own personal army.  First of all, use of the term "YIMBY" -- YIMBY stands for "Yes In My Back Yard."  None of the proposed YIMBYs even have a back yard of their own if they're the proposed young and clueless climate protestors.  They are not accepting any sacrifice for themselves, just demanding that others make a sacrifice for them. YIMBY is not the proper word here.  Paid protestor is more apt.  It doesn't take a lifelong study of human nature to realize it is harder to whip up support for something than it is to whip up opposition.  The supporter simply doesn't care enough to go out of their way to support someone else's project.  However, the objector whose property and way of life is threatened will go to great lengths to protect himself.  The only way corporations have been successful in creating supporters is with good, old fashioned cash.  Paid advocates, whether they are handed cash, free dinners, or business favors, will go out of their way to provide support if the price is right.  They will also spread any misinformation they are handed.  They are part of national organizations.

Despite all the biased media, we've yet to see rural landowners bow down to their wannabe urban masters.  Who do they think they're convincing with this hogwash?

As part of the "energy transition" big green, big government, and the electric industry have been promoting an overwhelming need for new high-voltage electric transmission.  The message goes like this:  we need more transmission to move electricity from new renewable energy generators (solar and wind) to big cities that "demand" more renewable energy. 

That message is pure propaganda.

The "energy transition" is squeezing existing fossil fuel generators financially and many are shutting down.  This phenomenon is caused by federal taxpayer-funded subsidies for renewable generators and state/local energy policy that requires your electric company to cut its carbon to zero by a certain date.  Government policy has finally been successful in forcing the closure of fossil fuel electric generators.  Perhaps this is a good idea, environmentally, but it absolutely doesn't work to keep the lights on.

One of the biggest problems is that new renewable generators are not coming online in time to replace closing fossil fuel generators.  Instead, we just have less generation.  The liars point to regional interconnection queues to demonstrate that thousands of megawatts of wind and solar are waiting patiently to connect to the grid, and blame grid operators and utilities for holding up their connection.  Except this is just another lie.  Generators in the queue have not yet been built and may never be.  Vast numbers of generators drop out of the queue before constructing anything, even more now that the government has completely hosed up the supply chain.  

When big, baseload fossil fuel generators close, there is often nothing in the state or locality to replace them.  Regional grid operator PJM Interconnection is struggling to replace over 11,000 MW of closing generation.  The continuing closures keep pushing our electric grid further and further to the edge.  Closure of the last of Maryland's coal-fired electric generators causes widespread grid impacts that can destabilize the grid and cause power outages.  But does Maryland care?  Not really.  Maryland leaves replacing the retiring generation to PJM and other states.  Maryland is an energy parasite.  Maryland's energy policies are causing unreliable electricity for everyone in the region.

PJM is also struggling with a 40% increase in electric demand caused by Virginia's out-of-control approval of new data centers.  Data centers use incredible amounts of electricity that cannot be satisfied with variable forms of renewable energy like wind and solar.  Data centers need 24/7 on-demand electricity, even after dark and on calm days.  The capacity factors for renewables are much lower than fossil fuels.  While fossil fuel generators can stockpile fuel and be prepared to run when needed, renewable generators only run when nature makes their fuel available.  Therefore, you'd need many more renewables than fossil fuel generators to maintain reliable power.  The big lie pretends that if we only build transmission to connect everything then some renewable generator, somewhere, will be producing electricity.  But it won't be producing enough to replace everything else that isn't producing.  Pretending that is so is an unproven fantasy, and one we engage in at our own peril.  The cost of new generation and new transmission to connect it all is also going to make electric bills skyrocket.  The liars say that renewable generation is cheaper than fossil fuel generation, but they don't tell you that's because of government subsidies, and they also don't add in the cost of all that new transmission needed to connect all the renewables.  Unsubsidized remote renewables plus transmission is more expensive than existing fossil fuel generation that relies on existing transmission.  Fact.

This whole lie has been spoon fed to a trusting public for years.  But what happens when the largest grid planner in the country approves a new transmission expansion plan?  Is it connecting renewables to load using new transmission?

NO.

PJM's recently approved transmission plan replaces closing fossil fuel generators, and increases electric supply for new data centers, by connecting these areas with existing fossil fuel generators in other states.  This isn't about the "energy transition"; it's going backwards to increase the use of coal and other fossil fuels from states without impossible clean energy goals.

PJM's MidAtlantic Resiliency Link, or MARL, directly connects the data centers in Northern Virginia to over 10,000 MW of coal-fired generation.  The MARL will enable the export of electricity produced at Ft. Martin (1,100MW), Harrison (2,000MW), Long View (860 MW), Mitchell (1,600 MW), Cardinal (1,800 MW), Sammis (1,700 MW) and Mt. Storm (1,700 MW).  Wind, solar, biomass and hydro in this area add up to less than 10 MW.  It is indisputable that the electricity carried by MARL will be overwhelmingly created by burning coal.

When will the environmental groups and people who will use this new supply of dirty power wake up and object?  Transmission divorced from its source of power is a giant lie.

While Maryland sits around playing "victim" of its dwindling power supply, Virginia is planning a slew of new legislation supposed to make its data center problem "better."  However, none of Virginia's legislation addresses the REAL problem -- the generation of electricity.  Virginia's legislators try to pretend that electricity comes from new transmission lines.  

Maryland has ambitious climate goals for 60% reduction of greenhouse gas emissions by 2031 relative to 2006 levels, and to attain a net-zero economy by 2045. Maryland’s plan, just like Virginia’s, can only apply to power generation within the state. Maryland is poised to eliminate coal generation within its borders with the upcoming shutdown of the last three remaining plants, Brandon Shores, Wagner and Warrior Run, already announced to happen in 2025.

​But does that eliminate Maryland’s reliance on coal to keep the lights on? No, it doesn’t. Maryland already imports more than 40% of the energy is uses from surrounding states. Maryland’s plan calls for significant new imports after all coal-fired generation in the state retires.

That’s right... in order to keep the lights on in Maryland, it must import staggering amounts of electricity from other states in the region, including West Virginia (91% coal) and Pennsylvania (predominately natural gas and nuclear). There’s no invisible barrier that prevents downwind emissions from Pennsylvania and West Virginia from fouling Maryland’s air. Maryland is a filthy parasite.
Maryland has historically dealt with its failure to build enough of the clean energy it loves by filing lawsuits to force the shut down of dirty generation in other states.

Maryland admits that it has no hope of building enough clean energy generators to power its own state. Why, then, does it continue to shut down power generators without a viable plan to replace them?

The generators are shutting down because of a settlement between Sierra Club and Talen Energy that was the result of a lawsuit. Neither Maryland, nor regional grid operator PJM Interconnection was party to the lawsuit. They just got left picking up the pieces to make sure the lights stay on. Maryland seems to be doing nothing except hoping for more solar, storage and offshore wind to offset a portion of Maryland’s energy deficiency. This is not realistic. Offshore wind has taken a beating recently. Maryland’s big project has recently been paused and is in danger of being cancelled. 

But Maryland chooses to bury its head in the sand and push its responsibility to keep the lights on to regional grid planner PJM Interconnection. It’s up to PJM to keep the lights on despite Maryland’s electric suicide plans. PJM employs the only tool it has... new transmission to Maryland from surrounding states with excess fossil fuel generation. PJM seems quite pissed about it too, judging from its recent letter defending against Maryland’s attacks on who will pay for the new transmission. 

And then you’ve got Sierra Club, jumping in to shift the blame and telling Maryland what PJM ought to do about the situation Sierra Club has created with its lawsuit against coal-fired generators. Sierra Club thinks PJM should just sit back and indulge in the fantasy that the lights will stay on because Sierra Club thinks they should. Sierra Club doesn’t have a realistic plan, but it doesn’t want to take any blame for what it has done. 

Who is running the state of Maryland? Elected representatives or Sierra Club? Meanwhile, electric rates will skyrocket and Maryland will be using more coal-fired electricity than ever. This isn’t an energy transition and it’s not helping the environment. In fact, Maryland seems to be going backwards, put pretending that is is “clean”.
Maryland, just like Virginia, is nothing more than a filthy parasite. But the parasitic “clean energy” policies of Maryland and Virginia aren’t just hurting Maryland and Virginia. The misery caused by their incoherent energy strategies is spreading to other states. West Virginia will mine more coal, burn more coal, and transmit more coal-fired electricity to Maryland and Virginia via new high-voltage electric transmission lines. New transmission lines take property from residents of other states using eminent domain in order to make way for the new lines. And that’s just the physical impacts, residents of other states will also have to pay for the new transmission because Maryland and Virginia’s parasitic energy policies threaten reliability of the entire PJM grid, stretching as far west as Chicago, and as far south as Tennessee.

We cannot continue on this way and package this disaster as a beneficial transition. When the rubber meets the road, state clean energy policies are destroying electric reliability and affordable electricity for everyone. 

I don’t hate clean energy. I’m all for it, if it works in an economic and equitable manner. But that’s not what’s happening. Clean energy has become a virtue signal, all talk and little action.  It's just words Virginia hides behind so its citizens think it's a "clean energy" state.  When the rubber meets the road however, Virginia is actually using more dirty energy than ever!

Virginia passed its Clean Economy Act in 2020. On its face, it sounds promising. It establishes a renewable portfolio standard that mandates that the two utilities in the state, Dominion Energy and Appalachian Electric Power, produce 100 percent renewable electricity by 2045 and 2050, respectively. It also established energy efficiency standards. It sounds like a great plan, but can they pull it off? 

In 2023, Dominion filed its Integrated Resource Plan, or IRP. An IRP is a utility plan for how it will meet anticipated electric load, and what resources the utility will use to keep the lights on. Dominion’s plan for future resources that comply with the VCEA and meet an unprecedented annual 5-7% increase in load created by the proliferation of new data centers in Northern Virginia consists of new solar and offshore wind additions, energy storage, and thousands of megawatts of incremental small modular nuclear reactors, or SMRs in order to retire all company-owned, carbon-emitting generation by the end of 2045. Dominion also plans to construct several new gas combustion turbines to address future energy system reliability needs. But that’s not all. Dominion also needs to increase its imports of electricity from other states to more than 10,000 MW. Dominion stated that this amount of imports “raises significant concerns about system reliability and energy independence, including over-reliance on out-of-state capacity to meet customer needs.”

Considering that one good-sized fossil fuel or nuclear power generator produces around 1,000 MW, that’s at least 10 electric plants in surrounding states that would exclusively serve Virginia’s needs. Virginia’s clean economy act is coming at the expense of the clean economies of surrounding states. Virginia’s law only concerns itself with power generation in Virginia, but in doing so, it places greater burdens on the surrounding states to power Virginia's economy. Virginia has turned itself into a power parasite – crowing about its clean energy economy while ignoring the fact that it is importing more and more dirty generation from other states in order to power that economy. There is no invisible barrier that keeps emissions from surrounding states from fouling Virginia’s air. Virginia’s “clean economy” is nothing but a virtue signal, and a very expensive one at that.

Would it be cleaner for Virginia to support its own load by building enough of its own new generation to meet VCEA, instead of importing dirty energy from surrounding states? Of course it would. But it would be much more expensive. Virginia’s clean virtue only extends as far as it can raise electric rates without killing its own economy. If Virginia really got 100% of its electric supply from non-emitting sources located within the state of Virginia, electricity would be so expensive that nobody would want to live or do business there. Instead, Virginia is virtue signaling and building its own economy at the expense of surrounding states.

Recently, the Virginia State Corporation Commission rejected Dominion’s IRP because the proposed new gas turbine generators failed to meet the standards of the VCEA. Dominion must come up with a new plan that does not build any new emitting generators. At what point does Virginia’s virtue signaling end and the real work of creating an actual clean economy begin?

Something has to change. Either Virginia has to build its own clean generation to serve its ever-increasing load and actually have a clean economy, or Virginia has to stop building the data centers that are creating that load. More transmission to import fossil fuel electricity from West Virginia to meet load is not the answer. 

It’s simply hypocrisy at the highest level. Virginia is not clean, despite its clean energy laws. It’s a filthy parasite feeding off the misery and ruined environments of neighboring states. At some point, those dirty plants in West Virginia will shut down. They’re getting older and more expensive to operate, and they’re getting squeezed by federal energy policy. If Virginia thinks that there will be more than 10,000 MW of generation available to import in 2045, it needs to think again. Shoving Virginia’s energy burden off onto neighboring states and thinking we won’t notice is not sustainable.

It’s up to you, Virginia. Clean or dirty? Energy freedom or filthy parasite? The choice is yours.  

There's a new filing in the on-going saga of GBE's FERC Negotiated Rate Authority.  As I wrote earlier, here and here, Grain Belt Express recently asked FERC to approve an "amendment" to its existing negotiated rate authority.  Missouri Landowners Alliance filed a protest and asked FERC to consider all the changes to the project, including its change of ownership since the original Negotiated Rate Authority was issued.  Missouri Landowners Alliance questioned whether GBE needed approval for the sale of its project to Invenergy under Sec. 203 of the Federal Power Act.  Invenergy responded saying that it didn't need permission.  But is that really true?

Yesterday, a coalition of Illinois groups filed a Motion for Summary Disposition, asking that FERC deny GBE's request for amendment to the existing negotiated rate authority.  The Illinois groups contend that when the project was sold, the negotiated rate authority issued to Clean Line expired because GBE did not get FERC approval for the sale.

And that pretty much describes ALL of the regulatory activity on GBE since Invenergy bought the project.  GBE has treated all its approvals as collectible baseball cards.  Invenergy did not buy a transmission project, it bought a set of state and federal approvals, and then methodically set about changing the actual project that was permitted without the regulator actually examining the new project.  It simply transferred the permits to a new project without proper examination.

The Illinois groups make the case why GBE should have to get the sale of its project approved, not simply "amend" its existing authority without proper examination of changed circumstances.

When GBE filed for its NRA "amendment" in early October, it expected to sail through a mere rubber stamping of its request so it could have new authority granted by December 5.  December 5 came, and December 5 went.  FERC doesn't seem to be in any particular hurry to ink up its stamp, and now that there is considerable controversy in this case, FERC must spend more time figuring things out.  GBE cannot advertise its capacity for sale, nor sign contracts to sell it, until it has FERC approval.

This must be extremely frustrating to Invenergy CEO Michael Polsky.  In a recent interview on Bloomberg, Polsky lamented that "we don't hear much" from FERC on a number of open dockets.  Isn't that a shame?  FERC isn't dancing to Polsky's serenade.  Also in this interview Polsky says that he thinks "the government" should pay for new transmission.  Well, that would make things rather simple for GBE, wouldn't it?  Then the merchant transmission project wouldn't need customers to fund it before it is built.  In Polsky's world, anyone who wants to build a transmission project would simply shake the taxpayer piggy bank until enough money falls out. Perhaps that's the way things work in Ukraine, but that's not where Polsky is operating.  He chose to come to this country and he must abide by our laws.

And while we're thinking about the elite Mr. Polsky, perhaps this article can also shed some light on how he makes money controlling energy policy?

Meanwhile, FERC continues to do "not much" on Invenergy's numerous open dockets, and Invenergy keeps filing stuff, like this recent complaint.  It must be really frustrating not to have a federal regulatory agency under your super rich thumb.

P.S.  Nice jacket!  Where does he find them?  Nightclub yard sale?

What's a NIETC (pronounced nit-zee)?  Just when you thought the energy alphabet soup couldn't get any thicker, here's another federal program meant to enable a massive buildout of high voltage electric transmission, whether we need it or not.  NIETC stands for National Interest Electric Transmission Corridors.  NIETCs were dreamed up by Congress in the Energy Policy Act of 2005 as a way to give the Federal Energy Regulatory Commission (FERC) "backstop" permitting authority for certain transmission lines.  Transmission line siting and permitting is state jurisdictional.  It is up to the states to decide whether a new transmission line is needed and, if so, where to put it.  However, Congress wanted to give the federal government authority to permit transmission where states did not use their own authority.  In its original form, designation of a NIETC by the U.S. Department of Energy (DOE) would bump permitting to FERC if a state did not possess the authority to site and permit, or if it took too long, or if it burdened its permit with unworkable conditions.  Importantly, Congress did not give FERC jurisdiction to permit a transmission project if a state issued a denial within one year.  But our federal government overstepped its boundaries by interpreting the statute to mean that a state denial could be overruled by FERC.  The NIETC process was killed by two court decisions that said the government failed to consult with states in making its designations, and that it had no authority to permit if a state issued a denial.  NIETCs were shelved and we moved on.  In 2021, NIETCs were dusted off and a new Congress decided that FERC could overrule a state denial for a transmission project in a NIETC.  This overreach into areas of state jurisdiction has not yet been challenged in court, but I guarantee you it will be.

Meanwhile, the U.S. DOE has been busy re-imagining the NIETC process so that it can designate new corridors.  The purpose of a corridor is to turn FERC into an appeals court for new transmission lines in the event that a state denies a permit to build.  For its part, FERC has initiated a rulemaking to set up its new permitting authority.  After proposing the rule, FERC accepted comment on its proposal, and then let the matter die.  FERC has not yet set the rules for applying for a permit for a project in a NIETC.  Nothing can be done until this process is finished.  However, DOE is moving ahead to designate corridors.

DOE'S first proposal was to allow transmission developers to apply for NIETCs for transmission projects they wanted to build.  In order to inform its process, DOE also conducted a National Transmission Needs Study.  It came a no surprise that DOE determined that the entire U.S. is in need of lots of new transmission, although the regional transmission planners (like PJM Interconnection) have been planning the transmission we need for decades.  Although DOE does not have any authority to plan the transmission system, or decide who pays for it, DOE issued its biased report in order to enable the designation of NIETCs.  Now that the entire country needs new transmission according to DOE's report, DOE has issued what it calls a "guidance document" to create the rules for designation of NIETCs.  It's not a rulemaking (sez DOE), it's a "guidance" and there are no formal rules.  Of course, this does not comport with administrative policy rules that require public notice and comment on agency rules, but DOE isn't bothered by that.... it's simply plunging ahead.  As if that won't be litigated...

Anyhow, on December 19, DOE published its "guidance".  The guidance says that any person can suggest a NIETC anywhere, and DOE will evaluate the suggestions it receives and publish a short list of possible NIETCs by the spring of 2024.  After the list is published, DOE will accept comments on the possible NIETCs.  It doesn't look like DOE will bother to undertake any local community notice so that impacted landowners and communities will be made aware of the comment opportunity.  You're supposed to be in the dark about this (so spread this around and educate yourself).  Once DOE receives comments on its list of possibilities, it will further winnow it down to select a number of "draft" corridors.  The draft corridors will be subject to an environmental statement under the National Environmental Policy Act.  This is where DOE will finally begin "robust" public notification and invitation to comment.  However, the NEPA report only concerns itself with environmental issues, not issues of need for the project in the first place.  While you should comment on the Environmental Impact Statement, you should also comment before the draft corridor is designated.

I know the guidance document is long and perhaps confusing, but you shouldn't ignore it.  I expect that every transmission proposal that has not yet been approved by state utility commissions will be proposing a new corridor as insurance in case it cannot get the state approvals it wants.  Your goal should be to prevent designation of a NIETC in your own community.  DOE will be holding one of its silly webinars to explain its process on January 3.  You can register to attend here.  The webinar will consist of some DOE employees reading the slides of a power point presentation.  DOE rarely allows attendees to ask questions during the webinar.  When it allowed questions in the past, it never seemed to like the questions asked by real people.  Therefore, in order to avoid embarrassment for DOE, there is unlikely to be any actual interaction during the webinar.  However, if you are new to NIETCs, you may get some information from reading the slides yourself.  What the hay, it's only an hour.

DOE pretends that its "guidance" was informed by the comments it received on its initial plan.  But reality is that DOE cherry picked the comments that supported what it wanted to do, and ignored the rest.  I submitted extensive comments on this (and also all the other related rulemakings and studies at FERC and DOE), however DOE ignored everything that didn't fit in with its plan.  Here's what I found wrong with DOE's process:

The U.S. DOE is like a kid with a new Christmas toy.  In the name of "clean energy" DOE has been given limited new authorities by Congress that clash with other authorities already possessed by grid planners, state regulators, NERC and FERC.  DOE doesn't know squat about transmission for reliability or economic purposes.  It is only concerned about building a bunch of transmission willy-nilly because Big Green says we need a bunch of new transmission to connect more unreliable wind and solar generators.  Wind and solar alone are not a viable means of powering our society.  But certain companies are getting very rich on all the government handouts for "clean energy" so they make up all sorts of new ways to pick our pockets, claiming that there's just one more thing we need to pay for in order to make wind and solar work.  Several years ago, they complained that wind and solar weren't working because it was too hard to connect new projects to the existing grid.  So, all the grid interconnection rules were reformed and a huge amount of new connections were approved.  But guess what?  Most of the approved projects dropped out because they were not economic or profitable.  Now Big Green says we need to build new transmission in order to connect new wind and solar.  As Rosanne Rosannadanna once said:

The U.S. DOE is not a grid planner.  It is not a grid regulator.  It's not a cost allocator.  It's just a gigantic waste of everyone's time and money... but it's a waste that we would ignore at our own peril.

The Potomac-Appalachian Transmission Highline, or PATH project died yesterday.  It was nobody's friend at the end.  I don't think anyone is going to miss it, even PATH itself.  It's been an albatross around everyone's neck, including mine, ever since FERC decided to second-guess itself on the matter in 2020.

An uncontested settlement was filed at FERC on November 17 that created a lump sum refund for PJM ratepayers of $9.5M.  The refund came as a result of the DC Circuit Opinion back in 2021 that determined PATH's advocacy and advertising costs should not have been collected from ratepayers.  Also included in the lump sum was a final accounting for money due under PATH's formula rate.  The settlement also provides for the cancellation of PATH's formula rate and cancellation of the companies themselves.  In several months, PATH will be nothing but a bad dream and a lightness in your wallet.

Because FERC had failed to act (again) on the DC Circuit remand and a paper hearing FERC opened on PATH's return on equity in 2020, the parties to the long-running formula rate and abandonment cases took it upon themselves to ink out a deal and present it to FERC for approval.  FERC allowed PATH to begin collecting money for its project beginning in 2008, and it won't stop collecting until 2024.  That's 16 years.  Much of that time came courtesy of an overworked and tone-deaf FERC simply ignoring the issues PATH created for years on end.  Two years to grant our formal challenges, 3 more years to get them to hearing, 2 more years to issue an order, 3 more years to grant rehearing and do a 180 on FERC's first decision, only a year at the D.C. Circuit Court of Appeals straightening that out, and then 2 more years before the settling parties, including yours truly, finally pulled the plug to short circuit another long period of waiting for FERC to act.  To its credit, FERC jumped right on the settlement when it was presented and approved it yesterday, just a mere month after it was filed.  But why did it take us doing FERC's job for them to get this resolved?

Yesterday, a public shaming of PATH, utilities, PJM, and FERC itself came courtesy of FERC Commissioner Mark Christie during the monthly Commission meeting.  You can watch it here beginning at minute 13:48 and ending at 18:24.  Just five minutes of your time to get the satisfaction you've been seeking for 16 years.  I love a happy ending like this!  PATH was a terrible idea that has caused harm to consumers.

Commissioner Christie also issued a written statement to append to the Commission's Letter Order approving the PATH settlement.  You can read it here.

Christie used PATH as a reason to take issue with FERC's overly generous incentives, formula rates, and long-term planning for transmission that is purposed to serve needs that never materialize.

Commissioner Christie has been on the warpath against certain overly-generous FERC incentives, issuing strongly worded statements in 13 cases over the past 2 years (all footnoted in yesterday's statement).  He pointed out that FERC has opened several proceedings to investigate and change the Commission's incentive rules since 2019, but still has not managed to conclude those proceedings (PL19-3, RM20-10).  Christie also noted that the Commission proposed discontinuing the CWIP incentive in its also pending Rulemaking on Transmission Planning (Docket RM21-17).

A highly politicized FERC means the agency can't get anything done and has found itself at a standoff over many issues over the past 8 years.  Commissioner Christie stands alone as the most consumer-focused Commissioner FERC has ever had.  He has tirelessly fought for consumers and will continue to do so.  Commissioner Christie came to FERC from the Virginia State Corporation Commission in 2021, and will serve until 2025.  We need more commissioners like Christie, who have a history of serving at state utility commissions, and less Commissioners from the political and special interest realms that have dominated appointments over the past 8 years.  FERC needs to go back to its  function as an impartial regulator, not a political vehicle for the policies of the administration in charge.  Sadly, I don't see things changing much in 2024.  

Commissioner Christie used yesterday's PATH settlement as a lesson and a warning, referring to it as an "omen" of more bad things to come if FERC's policies are not reformed.  He used PATH as an example of how these different policies come together to create zombie projects that can pick ratepayer pockets for decades.  According to Christie, PATH was originally part of Project Mountaineer, a PJM scheme to import electricity to eastern load centers from the Ohio River Valley's massive fleet of coal-fired generators.  Once PJM approved PATH and added the project to its regional plan, that turned on the money spigots.  Thanks to FERC's overly-generous award of every incentive possible and its use of formula rates, PATH began collecting its costs from ratepayers in 2008, during its development and permitting stage.  The Commission's policies allowed PATH to continue to collect its costs during the long period between PJM's approval and state regulatory approval.  Although PATH never received any state approval, and nothing was ever built, its formula rate continued to recover costs from consumers, even after PJM abandoned the project in 2012.  PATH is still collecting a cool million (or more) from consumers every year to this day.  The Commission's approval of the settlement yesterday shuts off the money spigot... finally.

Commissioner Christie cautioned against making long-term transmission plans based on today's generation choices. PATH demonstrates that those choices can change quickly, although the transmission projects set in motion to achieve them cannot.  It was wise advice to a Commission that is poised to pass new long-term transmission planning rules in 2024 based on today's generation choices of wind and solar.  The Commission needs to think carefully about saddling consumers with the cost of new transmission that could become obsolete before it is even built, such as PJM's recent slate of projects for the purpose of importing fossil fuel electricity to Virginia's data centers from the Ohio Valley.  PJM has acknowledged that new wind and solar additions are not keeping up with fossil fuel generator retirements in its eastern regions, but yet the generators keep closing and the data centers keep being built.  Something has to change, or the lights are going to go out.  PJM chose to approve a bunch of new PATH projects from the west, including the NextEra/FirstEnergy project from southwest Pennsylvania to Loudoun County.

We should all heed Commissioner Christie's warning, and support needed changes to FERC's incentives and transmission policy choices.  A group of consumers filed comments on FERC's transmission planning rulemaking back in 2021.  Check out the discussion of the PATH project beginning on page 21.

This is the same history lesson Commissioner Christie taught yesterday.  Christie said the PATH debacle has cost consumers nearly a quarter of a billion dollars over the past 15 years... all for nothing.  Christie quoted what Willy Loman’s wife Linda said in Death of a Salesman, "attention must be paid."  Let's hope proper attention is paid to the demise of PATH.  I, for one, won't miss it.  It frees up my time to pay attention to things ahead, such as the new PATH-like projects recently approved by PJM.

Let the funeral dirge play... we beat you, PATH.  We beat you BAD.