When policy change which results from FERC conspiracy with industry lobbyists is hidden from other "stakeholders" and only revealed publicly two days before the deadline to submit comments, one wonders what they're trying to hide.
According to comments filed by NARUC (National Association of Regulatory Utility Commissioners), they weren't notified of the proposal until just before a meeting in mid-August.
"Given that our members remain the primary transmission siting authorities, we are disappointed that we were not privy to the details or even informal conversations about this proposal prior to the above-referenced meeting, especially since the proposal has been under discussion since June and was vetted with industry stakeholders long before it was even revealed to us."
Apparently FERC and the industry have been discussing the best way to ram this through since June, but it was only recently that FERC began a series of conference calls with other "stakeholders" such as states and environmental groups. And, of course, they NEVER consulted the most important "stakeholder" of all -- you! As an electric consumer, property owner and citizen, YOU will be the ones who pay for new transmission, sacrifice your property and well-being to new transmission line rights-of-way, and must live with the consequences of FERC and industry's heavy-handed determination of where renewable energy will develop. This will ensure that development of renewables will only occur at utility scale and be concentrated in a handful of Midwestern States. Instead of each individual state getting a piece of the economic/jobs boom expected to result from renewable resources and developing their own local renewables to meet their own in-state goals, they will be forced to buy high-priced renewables from other states. Still other states will be forced to live with new transmission lines crossing their state which are intended to deliver renewables to their neighboring states, without receiving ANY benefit from the transmission line project. This should concern another group of "stakeholders" who were not consulted: your local and state elected officials. Give them a call and make sure they know!
The root of this problem is a couple of greedy energy corporations and a few Midwestern states who are trying to corner the renewable energy markets of the entire U.S. before other, perhaps more viable, resources have a chance to fully develop. Earlier this year, FERC granted incentives to a company to develop an offshore backbone intended to support development of wind farms along the Atlantic coast. These offshore wind farms are ideally sited to provide renewables to the huge load centers along the coast, with a minimum of new transmission capacity required. Earlier reports said that no new land based transmission will be required. This would make offshore wind a cheaper resource for the East Coast.
Take a look at these maps from a recent PJM planning document. They show two different scenarios regarding integration of different amounts of offshore wind into the transmission system. The first slide shows improvements they think will be needed if they base planning on 20GW of offshore wind. Those fat, orange lines on the coast are new 500kV transmission lines. For some inexplicable reason, it looks like they intend to bring back the MAPP project to transport wind power from the coast to the Washington, DC area. MAPP's original purpose was to transport power produced in Virginia and Maryland to New Jersey. PJM is desperately trying to find a "need" for MAPP. Since MAPP was not designed to distribute offshore wind power, it's probably not the most efficient or cost-effective way to do so. PJM is just throwing Pepco a bone here. If we're going to invest $5B in an offshore backbone, PJM needs to scrap all old projects and go back to the drawing board and create the most efficient and cost effective method of injecting this new generation into the existing grid. Look at the map. Does that even make sense? Maryland and Delaware don't need any of that transmission. The second slide shows what happens when the amount of integrated offshore wind drops to 4GW. All the new transmission lines are in the western PJM region, with no new transmission lines needed on the coast. This is because all the wind will be coming from the west, instead of the east. This is what FERC and their industry pets want to see happen. Most of those 765kV lines aren't even in PJM territory (indicated by the gray shaded areas). So, who do you suppose will be able to lobby and influence PJM to embrace their particular version of where PJM renewables will come from? Remember, it's not about planning or regulation or what's good for the grid, it's about who has the most influential lobbyists.
Now that FERC's scheme with the industry has been publicly exposed, the battle lines are being drawn. On the DOE's website dedicated to this proposal, which was just recently constructed, you can read comments from industry (for the proposal) and from state regulators (against the proposal). In addition, there are some comments from a couple of environmental groups who are inexplicably in favor of the proposal. In their quest for renewable power at any cost, they are being duped into going along with a plan that hurts consumers and citizens and subverts states' rights.
Since you weren't given a chance to express your views, the states and organizations like NARUC are fighting for your interests.
"Siting is inherently a local issue that impacts local environments, local landowners, local businesses and local communities. The best decisions come after complete due process where every interested neighbor, farmer and businessperson has an opportunity to be heard. People who know the landscape must be able to participate in the transmission siting processes to minimize negative environmental and economic impacts. Federal siting authority makes local participation less accessible, more expensive, and therefore less likely. State siting processes that enable local engagement may take time (although often less time than the combined pre-filing and filing processes at FERC), but they do not conflict with regional or national interests. On the contrary, local processes are essential to accomplish those interests, and the federal government should not create a short cut around local engagement."
NARUC wants to know what the "problem" is:
"...we would appreciate a specific articulation of the problem the delegation intends to solve and how the delegation will solve the problem identified."
This "if it ain't broke, don't fix it" theme is prevalent in all the comments from state regulators as well. The same question was repeatedly asked of Chairman Wellinghoff during one of those "stakeholder" calls this week. He never answered it. I guess nothing's broke afterall.
This is setting up to be an epic battle involving states, Congress and the courts, and it's root cause is industry lobbying influence on an agency that is supposed to regulate them. FERC is on the road to disaster and is going to end up strangling "the precious" that it's sticking its neck out to protect -- new transmission. NARUC sums it up well:
"To the extent that this proposal is motivated by a desire to reduce barriers to transmission, it fails. It relies on a tortured reading of the statute that would cause uncertainty, litigation, damage to State and federal relations, and delays in transmission development."