A plethora of parties have filed motions to intervene, including (of course!) power companies and their transmission affiliates, environmental organizations, land-based wind's front group, renewable companies, Atlantic Wind Connection (not to be confused with their land-based wind opponents) and a handful of states. Some parties have filed brief comments. Among these, there's a couple worth reading.
New Jersey BPU seems to think that PJM has gone off the deep end by including "public policy objectives" as a driver for transmission projects.
"While NJBPU is sympathetic to PJM’s perceived need to include non-codified policy-based factors into its RTEP process, this requirement greatly broadens the pool of assumptions that drive transmission development. This expansive reading of Order 1000 exposes stakeholders to the real risk that costly and undesirable policy-based projects linger in the planning analysis. The longer “specter” projects are modeled, the more likely they become a fixture in the RTEP process. This scenario could drive the development of policy-driven transmission assets based solely upon their recurring presence in PJM’s RTEP models, and further emphasizes the need to prominently include state veto authority in any future filings regarding Order 1000."
And about that "state veto," NJ suggests:
"NJBPU also strongly supports a cost allocation methodology whereby the states that will incur the financial burden of developing a policy-driven transmission asset retain veto power over the project. No party should bear the costs of developing a policy-driven asset that does not comport with that state’s guiding principles, regardless of any collateral reliability or economic benefit identified by PJM.
Moreover, policy is dynamic and changes quickly in response to political, social, and economic factors. By contrast, the decision to develop and build multi-billion-dollar transmission assets cannot change in lockstep with policy; the costs and impacts are simply too significant. Therefore, any cost allocation methodology flowing from a policy-driven framework must contain a safety-valve veto whereby the states may refuse ratepayer financed projects that fail to produce a benefit commensurate with the policy’s long-term value."
They also get their digs in about NJ's frowned-upon LCAPP:
"NJBPU believes that PJM’s resource planning must include an assessment of transmission and non-transmission solutions to identified reliability violations as acknowledged by the Commission in Order 1000. From this perspective, PJM’s resource planning process should include state sanctioned generation solutions. This approach allows PJM to fulfill its federal mandate of ensuring that the bulk transmission system remains reliable, while preserving the states’ constitutionally protected right to site generation resources within their territory."
NJ also had this to say:
"PJM deserves praise for seizing an opportunity to expand its interaction with the entities representing the individuals who ultimately shoulder much of this fiduciary burden – the state ratepayers. However, while these efforts are commendable, to date they are incomplete. Without the ability to measure these changes against a clearly articulated and comprehensive cost allocation methodology, state stakeholders are unable to adequately assess the impact of PJM’s proposal."
This comment was filed prior to last Friday's postage-stamp rate justification. Ut-oh! So, how is FERC thinking that "public policy" projects 500kV or above are going to be allocated? Shall we charge everybody in the region for one state's law? FERC seems to think that's okay, as long as that state gets some of those ethereal "integration" benefits that PJM provides. This just keeps getting more convoluted and unreasonable as we go along.
North Carolina also got offended by the "public policy objectives" thing:
"The North Carolina Agencies have an over-arching conviction that the FERC’s regulation of transmission planning, especially as articulated in Order 1000, over-steps the FERC’s jurisdiction under the Federal Power Act. PJM’s proposed amendments, especially its introduction of the concepts of “public policy requirements” and “public policy objectives,” echo and even go beyond Order 1000 requirements, and therefore raise serious concerns.
Setting aside the thorny jurisdictional issues which the North Carolina Agencies have already articulated in their request for rehearing of Order 1000, the North Carolina Agencies oppose the proposed introduction into PJM’s Operating Agreement of the new concept, “public policy objectives.” While the inclusion of “public policy requirements” in transmission planning raises significant concerns, the inclusion of “public policy objectives” is inappropriate, particularly given the potential for its inclusion to cause transmission planning and cost allocation to become even more controversial than they currently are.
The North Carolina Agencies are concerned that the inclusion of such objectives will result in the enlargement or expansion of the size and scope of otherwise appropriately defined transmission projects. Such enlargement or expansion could be based on a “public policy objective” that is not supported by some or all of the states in PJM’s footprint, and such expansion could cause a transmission project to become subject to PJM’s postage stamp cost allocation methodology, thus burdening customers throughout PJM’s footprint."
They also brought up the postage-stamp cost allocation method that FERC just blessed last Friday:
"To date, PJM’s postage stamp cost allocation method has proven controversial, even for transmission that is being built for reliability or economics.6 The North Carolina Agencies oppose allowing the vague and uncertain concept of “public policy objectives” to create the potential for inclusion of enlarged projects into PJM’s Regional Transmission Expansion Plan (RTEP). Such objectives might not be in the best interests of North Carolina’s citizens, and a fair cost allocation method has not been established for the incremental costs of such projects. Therefore, the North Carolina Agencies oppose the inclusion of “public policy objectives” in PJM’s transmission planning process."
Stay tuned... this is shaping up to be another epic FERC fracas.