"Oh, what a tangled web we weave, when first we practice to deceive." -- Sir Walter Scott
PJM's house of cards is swaying precariously in a new wind that has begun to blow. PJM claims their planning process is "transparent", and I'm starting to agree. It's becoming increasingly transparent that PJM will continue to erroneously favor the greed-driven projects of their most powerful members, even when their own credibility is on the line. Seems like PJM doesn't even have enough intelligence to carry out the basic instinct of self-preservation.
On December 1, PJM announced that the Mt. Storm-Doubs rebuild was approved, and also reaffirmed that the PATH project is needed. Huh? The press release states that the Mt. Storm-Doubs rebuild will increase the capacity of "one of the most heavily used transmission lines in PJM" by more than 60%. This capacity increase is not factored into the supposed "need" for PATH. Why not? A little too much transparency, boys? That's okay, PJM, we can clearly see that you're no longer making any logical sense or even bothering to create some pretext of "need" for the project.
Apparently it's not just us citizens who see PJM bias -- the Consumer Advocates/Peoples' Council from eight different states (WV, MD, VA, IL, DC, OH, NJ and DE) have joined together to question PJM's recent actions.
At issue here is the way PJM has been playing games with proposed alternatives to the PATH project. One such alternative, the Liberty Line, has now been rejected by PJM twice. The most recent rejection was based on a conceptual study prepared by Burns & McDonnell (conflicting interests since 1898!)
Before we even get into some of the interesting conclusions the study reaches, let's talk about CONFLICT OF INTEREST. Burns & McDonnell is also a contractor working on the PATH project. How can they impartially evaluate a competitor to a project they are already working on? They can't. And the Consumer Advocates are pretty steamed up about that (and you should be too!) I'm sure you, dear ratepayer, are paying for this worthless study.
The study prices the Liberty Line between $2 and 2.5 billion, compared to PATH's $2.1 billion. Where's the conceptual study that priced PATH, you ask? It doesn't exist. PATH has simply pulled its cost estimates out of its... hat, and PJM takes them at their word, no study needed. I have a sneaking suspicion that Liberty is overpriced and PATH is severely under priced. Apparently I'm not the only one.
Couple of amusing things in the study:
"...the Project would likely have several challenging issues to address associated with siting, real estate, permitting, and construction that could make it a complex and difficult project to permit and construct and thus could extend the schedule for the completion of the Project."
"Following the collection of available data, Burns & McDonnell identified the major constraints and issues within the study areas. These major constraints and issues consisted predominantly of environmental and regulatory constraints. Environmental, social or regulatory constraints are areas where transmission line siting is impractical or less favorable for institutional or social reasons, or because the potential environmental impacts are considered excessive."
"Risk factors that could delay the project duration are public opposition and organized opposition groups, state siting approval, the NEPA process, permit clearances and approvals, construction issues, and potential mitigation requirements. Several of these risk factors could affect the project duration significantly."
"In addition, the timeframe and costs required to energize the line would likely be significant based on the involvement of three different states and 15 counties and the issues and constraints described above."
"The following factors were identified and taken into account: Expected level of sophistication of landowners"
"National Environmental Policy Act (NEPA) compliance for the crossing of the Appalachian Trail in Pennsylvania. The Appalachian Trail is managed by the NPS. Any federal agency that is being asked to issue a permit to an individual or company must evaluate the environmental effects of the permit decision under NEPA. The NEPA review process could apply to the entire project length."
"Local zoning approvals from affected municipalities for a new substation at Kemptown." Yeah, like how they turned down PATH's application for a special exception.
"Challenges associated with connecting to the new Kemptown Substation. The location of the Kemptown Substation is surrounded by residential development. A new 500-kV transmission line into this substation would likely require the displacement of a number of residences or reconfiguring the existing 500-kV line to minimize impacts to residences in the vicinity of the Kemptown Substation. There are also organized opposition groups, such as Citizens Against Kemptown Electric Substation (CAKES), that are opposed to the proposed location of the Kemptown Substation."
"Public opposition. As a result of several recent transmission line projects in the area (Urbana Loop, PATH, and Mid-Atlantic Power Pathway (MAPP)), the public is highly educated about the Certificate of Public Convenience and Necessity (CPCN) process, and they have created organized opposition groups such as CAKES and the Sugarloaf Conservancy."
And any of this differs from PATH how? Don't you just love how "sophisticated" we've all become? That's just a nice way of saying that the citizens aren't the trusting, uneducated, country bumpkins that PATH expected. Beware, unneeded transmission project owners, we're going to rip your head off and spit down your neck!
This next bit is especially interesting, considering how PATH has been continually playing the FERC card with the various state regulatory boards. Just as I have always suspected, that card is really more of a joker -- one of the states ought to call their bluff...
"The proposed Project falls within the counties included in the Mid-Atlantic Area National Interest Electric Transmission Corridor as designed by the Federal Energy Regulatory Commission (FERC). According to the Energy Policy Act of 2005, FERC may consider an application for a transmission line within this corridor. However, it should be noted that FERC authority can only be requested if the state does not act on an application for more than one year. In addition, FERC has never been asked to exercise their siting authority, which would likely create delays as the agency determines its review strategy. If the transmission line is processed under FERC siting authority, an Environmental Impact Statement (EIS) would be prepared for the entire transmission line."
Looks like big trouble coming up at PJM and at the three state regulatory agencies for PATH as they try to backpedal out of all the lies they have told to the public about their "transparency". Hey, PJM, remember that old adage... "When you lie down with dogs, you get up with fleas"? Now PATH's fleas are making you dance. Let the heads roll where they may...
For more about this issue, be sure to also read PJM Deceives State Officials About PATH Alternatives — And Gets Caught on Calhoun Power Line.
PJM's house of cards is swaying precariously in a new wind that has begun to blow. PJM claims their planning process is "transparent", and I'm starting to agree. It's becoming increasingly transparent that PJM will continue to erroneously favor the greed-driven projects of their most powerful members, even when their own credibility is on the line. Seems like PJM doesn't even have enough intelligence to carry out the basic instinct of self-preservation.
On December 1, PJM announced that the Mt. Storm-Doubs rebuild was approved, and also reaffirmed that the PATH project is needed. Huh? The press release states that the Mt. Storm-Doubs rebuild will increase the capacity of "one of the most heavily used transmission lines in PJM" by more than 60%. This capacity increase is not factored into the supposed "need" for PATH. Why not? A little too much transparency, boys? That's okay, PJM, we can clearly see that you're no longer making any logical sense or even bothering to create some pretext of "need" for the project.
Apparently it's not just us citizens who see PJM bias -- the Consumer Advocates/Peoples' Council from eight different states (WV, MD, VA, IL, DC, OH, NJ and DE) have joined together to question PJM's recent actions.
At issue here is the way PJM has been playing games with proposed alternatives to the PATH project. One such alternative, the Liberty Line, has now been rejected by PJM twice. The most recent rejection was based on a conceptual study prepared by Burns & McDonnell (conflicting interests since 1898!)
Before we even get into some of the interesting conclusions the study reaches, let's talk about CONFLICT OF INTEREST. Burns & McDonnell is also a contractor working on the PATH project. How can they impartially evaluate a competitor to a project they are already working on? They can't. And the Consumer Advocates are pretty steamed up about that (and you should be too!) I'm sure you, dear ratepayer, are paying for this worthless study.
The study prices the Liberty Line between $2 and 2.5 billion, compared to PATH's $2.1 billion. Where's the conceptual study that priced PATH, you ask? It doesn't exist. PATH has simply pulled its cost estimates out of its... hat, and PJM takes them at their word, no study needed. I have a sneaking suspicion that Liberty is overpriced and PATH is severely under priced. Apparently I'm not the only one.
Couple of amusing things in the study:
"...the Project would likely have several challenging issues to address associated with siting, real estate, permitting, and construction that could make it a complex and difficult project to permit and construct and thus could extend the schedule for the completion of the Project."
"Following the collection of available data, Burns & McDonnell identified the major constraints and issues within the study areas. These major constraints and issues consisted predominantly of environmental and regulatory constraints. Environmental, social or regulatory constraints are areas where transmission line siting is impractical or less favorable for institutional or social reasons, or because the potential environmental impacts are considered excessive."
"Risk factors that could delay the project duration are public opposition and organized opposition groups, state siting approval, the NEPA process, permit clearances and approvals, construction issues, and potential mitigation requirements. Several of these risk factors could affect the project duration significantly."
"In addition, the timeframe and costs required to energize the line would likely be significant based on the involvement of three different states and 15 counties and the issues and constraints described above."
"The following factors were identified and taken into account: Expected level of sophistication of landowners"
"National Environmental Policy Act (NEPA) compliance for the crossing of the Appalachian Trail in Pennsylvania. The Appalachian Trail is managed by the NPS. Any federal agency that is being asked to issue a permit to an individual or company must evaluate the environmental effects of the permit decision under NEPA. The NEPA review process could apply to the entire project length."
"Local zoning approvals from affected municipalities for a new substation at Kemptown." Yeah, like how they turned down PATH's application for a special exception.
"Challenges associated with connecting to the new Kemptown Substation. The location of the Kemptown Substation is surrounded by residential development. A new 500-kV transmission line into this substation would likely require the displacement of a number of residences or reconfiguring the existing 500-kV line to minimize impacts to residences in the vicinity of the Kemptown Substation. There are also organized opposition groups, such as Citizens Against Kemptown Electric Substation (CAKES), that are opposed to the proposed location of the Kemptown Substation."
"Public opposition. As a result of several recent transmission line projects in the area (Urbana Loop, PATH, and Mid-Atlantic Power Pathway (MAPP)), the public is highly educated about the Certificate of Public Convenience and Necessity (CPCN) process, and they have created organized opposition groups such as CAKES and the Sugarloaf Conservancy."
And any of this differs from PATH how? Don't you just love how "sophisticated" we've all become? That's just a nice way of saying that the citizens aren't the trusting, uneducated, country bumpkins that PATH expected. Beware, unneeded transmission project owners, we're going to rip your head off and spit down your neck!
This next bit is especially interesting, considering how PATH has been continually playing the FERC card with the various state regulatory boards. Just as I have always suspected, that card is really more of a joker -- one of the states ought to call their bluff...
"The proposed Project falls within the counties included in the Mid-Atlantic Area National Interest Electric Transmission Corridor as designed by the Federal Energy Regulatory Commission (FERC). According to the Energy Policy Act of 2005, FERC may consider an application for a transmission line within this corridor. However, it should be noted that FERC authority can only be requested if the state does not act on an application for more than one year. In addition, FERC has never been asked to exercise their siting authority, which would likely create delays as the agency determines its review strategy. If the transmission line is processed under FERC siting authority, an Environmental Impact Statement (EIS) would be prepared for the entire transmission line."
Looks like big trouble coming up at PJM and at the three state regulatory agencies for PATH as they try to backpedal out of all the lies they have told to the public about their "transparency". Hey, PJM, remember that old adage... "When you lie down with dogs, you get up with fleas"? Now PATH's fleas are making you dance. Let the heads roll where they may...
For more about this issue, be sure to also read PJM Deceives State Officials About PATH Alternatives — And Gets Caught on Calhoun Power Line.
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