Electric consumers are fed up with the gigantic for-profit energy conglomerates, and a day of reckoning is fast approaching.  The status quo will change.

I came across this article recently.  In it, the author claims that, "utility customers are mad as hell."  He's right, but he also thinks that he can fix that for any willing corporate benefactors.  In fact, he can't.  While he does make one interesting observation down near the end of the article, he's about as clueless as his financiers.

Egan says, "Utilities have the tools and opportunities to respond effectively when they are targeted by guerrilla protests, but utilities face significant organizational challenges. Historically, they have been unable to move as quickly as protesters and are uncomfortable with the kind of direct confrontation espoused by activists."

This is a correct statement, and a weakness we discovered and exploited early on in the PATH battle.  I disagree that they "have the tools to respond effectively" though.  PATH was left with drool dripping off its collective chinny, chin, chin on numerous occasions.  My personal favorite was watching them stare in disbelief from behind the lobby doors as we marched onto the sidewalk in front of their Frederick office 10 minutes before their "media event" that we weren't supposed to know about, and the press came running like Pavlov's dogs.  Their ineffective response was to attempt to strong-arm the press away from us.  Wrong!  It set the tone for what was ultimately a complete and utter public relations failure in Frederick County, Maryland.

The PATH project ignited a fire in the hearts and minds of thousands of citizens in three states.  Other unneeded transmission boondoggles have had the same effect in other states. 

Constant electric rate increases that result in increased corporate profit have also awoken a sleeping giant.  In Ohio, PUCO's recent tossing out of AEP's rate increase served only to empower the consumers.  AEP and PUCO will never be able to stuff that genie back in the bottle.  AEP is now a dead man walking in their home state. 

West Virginia consumers are joining forces in record number in response to out-of-control rate increases and a lack of utility performance.

In Boulder last year, the citizens voted to kick energy giant Xcel to the curb and form their own municipal utility.

America is fed up with the corporate elite in general.  We know who you really are, and what you're really doing.  We're never going back to subservient ignorance of your money-making machinations to manipulate the masses.

The consumers are mad as hell.  Changes are coming.  The utilities can adapt or face extinction.  We're not going to take it anymore.

It looks like Primary Power has had another revelation about the shifty state of affairs at PJM.  If you've been following the SVC issue, here's the latest.

Primary Power submitted a letter to PJM on February 29 to make a final plea to retain their prior selection to construct the projects.  FirstEnergy wants to swoop in at the last minute and take over the project and they have been whining like a milksop champ.

In the letter, Primary Power makes a couple of astute observations:

"Continuing to allow a re-opening of the original recommendations made by the OI is tantamount to allowing the incumbent transmission owners to take over PJM’s role as the Transmission Planner in its NERC reliability regions, and PJM’s management of the stakeholder process."

and

"There are real problems with FirstEnergy’s claimed estimate that make it not credible, and not a valid basis for comparison to Primary Power’s well-founded estimate. First, Primary Power’s estimate is based on five years of development work on the Meadowbrook SVC and a design-basis cost estimate provided by the EPC contractor for the Primary Power SVC projects. In comparison, FirstEnergy has done no development work on a Meadowbrook SVC and its estimate is just an unvetted assumption.

Second, FirstEnergy’s track record on cost estimates for this very type of facility demonstrates that FirstEnergy grossly underestimates the cost of the facility in its initial estimate.

In the case of FirstEnergy’s Black Oak SVC facility, which was designated to FirstEnergy in the 2005 PJM RTEP, FirstEnergy’s initial estimate was $35 million. Within a year after FirstEnergy was designated to build the facility, the original cost estimate had ballooned from $35 million to $50 million. FirstEnergy underestimated the cost by almost 50 percent, and PJM selected the project based on that estimate.

If FirstEnergy has similarly underestimated the costs here, which is likely given that FirstEnergy has done no development or design work on the Meadowbrook SVC, then FirstEnergy’s $60 million initial estimate could easily escalate to $90 million, well in excess of the cost for Primary Power’s Meadowbrook SVC project. The lesson learned from FirstEnergy’s prior cost estimating and its off-the-cuff estimate for a project that it has not developed, is that care should be taken when comparing cost estimates."

So, FirstEnergy severely undervalues their "off the cuff," unvetted cost estimates in order to have them selected by PJM.  And PJM continues to defer to the profit-driven bullying of its largest members.  Anything new and striking in that for you PATH opponents?  Nah, didn't think so.  PJM is a dangerous cartel and its continued biased favoritism of projects awarded to certain incumbent TOs keeps cropping up again and again.  Like water dripping on a stone...

...it causes news stories like this:

PATH power line could be back on track this summer

Don't blame the reporter, it looks like the title of the article that was not used by her editor was the more realistic, "Future of PATH power line could be decided this summer."

Does Herling actually say that PATH will be needed?  No.  In fact, most of what he says points to PATH not being needed.  New generation is planned for the east coast, coal prices are up, gas prices are down, prices have levelized, the bottom has fallen out of the Ohio Valley power generation market, east coast states are pursuing renewables and PATH's parent companies clearly aren't interested in the project any longer.  He drones on and on about PJM's new planning process, but none of what he says is news.  In the practice of what Bill has termed "PATH Kremlinology," we've been keeping you informed of the little puzzle pieces we dig up and fit together.  Stay tuned while we see this one through.

We first got wind of the supposed "summer" decision about PATH from the letter PATH sent to the NPS asking to have the EIS held in continued abeyance until 60 days after PJM's RPM auction in May.  None of that has changed.

Herling isn't exactly known as a "transparent" source of information, however.  When Dominion presented the rebuild of the Mt. Storm - Doubs 500kV line to PJM, our pal Herling tried like mad to sweep it under the rug or delay it unnecessarily.  He lost that battle.  MSD is proceeding with an in service date of 2015.

So, why would an impartial planner be in the pocket of the PATH companies?  Here's a little "transparency" for you, taken from one of Herling's many expert testimonies for the PATH Project:

"Prior to that, I worked for the American Electric Power Service Corporation for eight years in bulk transmission planning."

Okay, so that explains Herling.

It probably also explains this glaring departure from reality that I noticed in the 2011 RTEP last night.

In Book 3 of the 2011 RTEP, PJM makes the following statement about PATH's "abeyance" as it was announced in early 2011:

"Additional sensitivity analysis performed on a 2017 study year case examined the impacts on the need for PATH abeyance from Warren County Generation, a Global Insights load forecast, RPS initiatives, at risk generation and State DR/EE goals."

What's missing?  Dominion's MSD rebuild - the ultimate grim reaper for the PATH project.

Here's what PJM says about MSD:

"Baseline RTEP studies conducted in 2010 indicated that the Mt. Storm - Doubs line would continue to be a limiting system element even after major backbone additions like TrAIL and PATH were completed. Consequently, the PJM Board approved PJM’s recommendation to add the rebuild to the PJM RTEP as an operational performance upgrade."

But here's the testimony PATH presented to the VA-SCC on March 17, 2011 regarding PJM's additional analysis requested by the hearing examiner:

"When the upgrade is completed, the Mt. Storm-Doubs line, the first two lines on this slide, the carrying capacity of that line will be increased about 66 percent. And so, that will move out the thermal violations shown in the base case well into the decade of the 2020's."

Herling has always been in denial about MSD.  He also rules his little fiefdom like the lunatic patriarch of a dysfunctional family.

"As we work through 2012 … I think will fill in the blanks for what other factors we will consider and how we will weigh them when we are making decisions," he said.

Transparent?  Hardly.  But, will the PATH project become "needed" again this summer?  I suppose anything is possible when you're dealing with a cockamamie, clandestine cartel, but it's probably unlikely.  This doesn't mean you should forget about PATH and staying involved in continued opposition, though.  It's always possible that the zombie could rise from the grave until it is officially abandoned.

Nudge, nudge, FERC.  Some people are getting impatient that you seem to have clammed up about transmission incentives after being deluged with comments from states, environmental and consumer groups, and angry citizens.

Spiegel & McDiarmid submitted a letter today on behalf of numerous organizations and states summarizing the general gist of the comments, in case FERC is having trouble sorting them out.

It makes perfect sense.  But it doesn't make a bunch of unearned profit for transmission owners.  Cue the whining... the IOUs should be responding in... 3, 2, 1...

It could have been better if they hadn't started out spelling two out of four Commissioners' names wrong.  And, that word "incentive" is such a toughie!  It isn't a verb.  Even grammar experts can't agree on how to turn it into an action word.  However, once you've picked one of the bastardized verb versions, please stick with it throughout the document.  I'm glad this isn't an English 101 test.

But, hey, something amazing happened with this letter... WV's Consumer Advocate finally weighed in on the matter of FERC's transmission incentives!  If he'd gotten involved sooner maybe they would have found out that there's already plenty of transparency between costs and reward in a formula rate.  It's that line item called "Return."  It's not that hard, Byron.

PJM finally made the 2011 Regional Transmission Expansion Plan available online today.  It's 5 "books" of silly stuff that's going to take a long while (and a lot of coffee) to get through.  PATH will continue to be "held in abeyance" in 2012.  No surprise there.  Just another $13M of profit for the PATH companies this year that will be paid for by you while the project continues to sit on a shelf.  Here's the PATH money quote:

PATH Abeyance
Analysis performed during the 2010 RTEP cycle required an in service date of June 1, 2015 for the PATH Line as shown on Map 1.3. The PJM Board issued a statement on February 28, 2011, suspending the PATH line.
PJM staff performed an updated analysis based on the 2011 RTEP assumptions that included Generation Deliverabilty; and Load Deliverability for the following LDA’s: MAAC, Southwest MAAC, Eastern MAAC, PEPCO and Dominion. Additional analysis performed on a 2017 study year case with 2011 RTEP assumptions examined the impacts on the PATH abeyance from Warren Generation, Global Insights load forecast, RPS, at risk generation and State DSR/EE goals. 2011 RTEP analysis suggests that the need for the PATH line has moved several years beyond 2015. Based on these analyses the PJM Board has decided to continue to hold the project in abeyance and requested that the transmission owners suspend development activities. Furthermore the PJM Board has directed staff to perform additional analysis using the 2012 RTEP assumptions and incorporating May RPM base residual auction results.

In honor of this momentous occasion, the li'l Coalfella has dug up some of his trademark stupid comments, just for you:

WV Metro News reports,
"Our energy delivery to customers still remains below 2008 levels,” Colafella told MetroNews. “You're really looking at a situation that's different today than when PATH was originally proposed."

PJM has continued to research the PATH project for the last year, getting updates to determine if things are changing. At this point, Colafella says the answer is "no."

"The landscape today is really no different than where we were a year ago,” he said. “Supply really continues to exceed demand on the electric grid."

Colafella says First Energy and Appalachian Power are following the lead of PJM.

"The companies are not moving forward with the project,” he said. “At this point there aren't any activities that are underway."

Except for that collection of $13M out of your wallet this year.  Li'l Coalfella forgot that "activity."

Looks like our li'l Coalfella isn't so hopeful about his little PATH Project anymore.  Compare the above with the stupid comments he made last year:

"'The investment we’ve already made won’t be lost though, because the project is not lost — just suspended,' Colafella said."

The project is lost.  Get on with the abandonment before your $140M investment is "lost" too.  We're not going away until you do.

TrAILCo recently made a filing with the WV Public Service Commission requesting blanket permission to divest itself of real property it currently owns that is "not useful or necessary to TrAILCo’s performance of its public service obligations."  Why would TrAILCo have imprudently spent ratepayers' money purchasing property that wasn't useful or necessary?  Some (but not all) of these properties are ones that TrAILCo was obligated to purchase, at owner's option, under one of the stipulations in its settlement.  In order to buy itself the necessary Certificate of Public Convenience & Necessity it needed from the WV PSC, former Gov. Joe Manchin engineered what were called "concessions" from the company.  The rest of us may view them as bribes.  The cost of these "concessions" to West Virginia were then recovered from ratepayers throughout the 13-state PJM region, except for TrAILCo parent company subsidiaries Mon Power and Potomac Edison's customers in West Virginia.  In another stipulaton, the parent company agreed to absorb those customers' cost of the TrAIL Project for a period of 7 years.  That date with a big rate hike is looming just over the horizon for those electric consumers, who will not be easing into the cost of TrAIL gradually over a period of years during construction as the other ratepayers did, but all at once.  The rate shock is coming, my friends.

The stipulation causing TrAILCo's current filing reads:

Staff General Condition #2 - “The Company shall purchase any property containing residences that are within 400 feet of the centerline if the owner desires to sell their property.”
TrAILCo accepts this condition, provided that in each case the property owner will have until the first anniversary of the inservice date of the West Virginia Segments of TrAIL to notify TrAILCo in writing that the property owner has elected to exercise the option to require TrAILCo to purchase the property at a fair market value based on the median of three appraisals. One appraisal shall be prepared by a qualified appraiser selected by the property owner, another appraisal shall be prepared by a qualified appraiser selected by TrAILCo and a third appraisal shall be prepared by a qualified appraiser selected by agreement of the two other appraisers. TrAILCo shall pay the reasonable costs of all three appraisals.

So far, TrAILCo says it has purchased 24 properties, although they admit that they purchased some of these properties "through [their] own initiative." The properties purchased at TrAILCo's own initiative were not a requirement of the stipulation.  Why are ratepayers subject to the cost of "unneeded and useless" property that TrAILCo voluntarily elected to purchase?  Exactly how much unneeded property did they purchase on their real estate buying spree?  The offer to buy properties under the stipulation is valid until May 18, 2012.  How many more unneeded properties will TrAILCo buy and add to its "unneeded and useless property" list before the deadline?

TrAILCo does not put a purchase value on these properties in their filing, although the amount is certainly known.  The stipulation required TrAILCo to purchase these properties at "fair market value."  However, in its filing, TrAILCo says the properties will be revalued at "fair market value" before selling.  So, which "fair market value" is actually "fair market value?"  Apparently it's not the "fair market value" at which they purchased the properties.  Were these landowners cheated out of true "fair market value?"

TrAILCo's filing is made necessary by WV Code that requires approval of any sale of utility property by the WV PSC.  In order to consider the sale, the PSC requires all the information listed in TITLE 150 PROCEDURAL RULES PUBLIC SERVICE COMMISSION, Sec. 10.6. Sale of franchises, permits and plant.  However, TrAILCo does not provide all of the information and claims in their filing that the information "has little bearing, if any, on the Commission’s decision."

Some important, required information that TrAILCo conveniently omits from their filing is:

10.6.e. accounting history of the franchises, licenses, equipment etc., to be sold, assigned, etc., including the account numbers used, the original cost, and the date of purchase by the petitioner,
10.6.f. the proposed journal entries associated with the sale of the franchises, licenses, equipment etc., to be sold, assigned, etc., including account numbers and amounts,

This information is crucial to the Commission's decision since "Any gains or losses incurred will be recorded below the line, protecting ratepayers from any adverse impact from the sales.    Further, as TrAILCo will not include any costs, gains or losses associated with selling the Properties in its revenue requirement, TrAILCo’s customers will not be adversely impacted by the Properties’ sale."  TrAILCo says sale of the properties "will have no adverse impact upon TrAILCo, West Virginia ratepayers, or other public utilities within the Commission’s jurisdiction."

But what about the ratepayers in the other 13 states?  TrAILCo's claims of "no impact" are not necessarily true.  The "gains or losses" are to be recorded "below the line."  Below the line expenses are those that are absorbed by the company and not recovered from ratepayers.  Conversely, above the line expenses are those that are the responsibility of ratepayers and are recovered through rates.  TrAILCo does not provide a clear picture of where the expense of purchasing the properties, maintaining the properties, paying taxes on the properties, and other costs such as the demolition of several buildings on the properties, was originally booked.  TrAILCo merely states, "TrAILCo will record each sale of Property in accordance with the Uniform System of Accounts."  That's hollow assurance, since TrAILCo's parent's accounting practices have been proved incorrect in numerous corrections to its FERC Formula Rate filings, and TrAILCo is currently the subject of an audit being performed by FERC's Office of Enforcement.  TrAILCo is seeking the West Virginia PSC's permission for rate accounting over which they have no jurisdiction.  TrAILCo wants to book any gains on the sale of these properties below the line.  The proceeds will go directly to TrAILCo's shareholders, which happens to be the parent company, FirstEnergy.  If the property purchase and expenses were the responsibility of ratepayers, any gains should flow back to ratepayers, not to FirstEnergy's pocket.

TrAILCo insists, "TrAILCo needs to sell the Properties in order to prevent deterioration and to maximize their resale value."  Isn't it ironic that TrAILCo's related subsidiary's PATH Project has purchased numerous properties at ratepayer expense that they continue to hold, year after year, while those properties "deteriorate" while that project sits "in abeyance."  PATH is in no hurry to sell properties it purchased in order to protect ratepayers' investment.

In addition, TrAILCo claims that the information required in Sec. 10.6.h (description of how purchaser became aware of TrAILCo’s intent to sell the Property) "would have little, if any, impact..."  That requirement is in there to ensure that all sales are "arm's length" transactions.

TrAILCo states, "The sales of the Properties will benefit TrAILCo..."  Well, that much is clear.  The rest remains ambiguous.

Dominion has made a filing with the Bureau of Ocean Energy Management asking them to suspend Atlantic Wind Connection's $5B offshore wind backbone.  Dominion says AWC's right-of-way request should only be approved after PJM Interconnection first approves the project.  PJM says:

"A spokesman for the group, which has more than 750 members, many with ties to the commercial power industry, said the project doesn't meet PJM's goal of providing reliable and low-cost energy to its customers.

"'It's something that doesn't fit into our existing framework,' Ray Dotter said."

It doesn't fit into their existing framework.  Perhaps that's because PJM never completed studying it last year due to "resource limitations."  However, PJM did manage to find the "resources" to study importing 40% renewables into PJM from "wind profiles for resources further west of PJM."

It doesn't "fit into their existing framework" because they don't want it to "fit into their existing framework."  PJM is first and foremost a cliquish cartel ruled by Ohio Valley coal-dependent generators.  These PJM bullies don't want offshore wind to upset their status quo.  Onshore wind from the midwest will provide opportunities for these companies to own profitable portions of an "energy superhighway" envisioned to move these renewables to population centers on both coasts.  Once this "superhighway" is in place, it will also provide them with an opportunity to undercut intended renewables with new and expanded coal-fired generation in electricity markets.  Offshore wind will cut into their current market share of load on the east coast, and require only a minimal amount of new transmission at four proposed injection points along the coast.  It will not provide expanded opportunities to get coal-fired generation to market.

The fact that offshore wind does not require a new, nationwide grid of transmission lines is one of its best selling points.  Transmission lines are expensive to build (estimates are currently more than $300B for the "superhighway"), take land through eminent domain, and face fierce opposition which causes project delays, or even cancellation of the entire project.  A recent article in Public Utilities Fortnightly estimates that onshore renewable generation, backup generation to support it, and required new transmission could top $500B.  The article, entitled "The Not-So-Green-Superhighway" (sorry, no link, you need a subscription to view online content by this snooze-fest) was written by the same author of this presentation.  Although the presentation is not as recent or extensive as the article, the article sets forth the same basic idea that was presented at the National Coal Council's 2010 Spring Meeting.  After stating that "RES transmission could enable expansion of coal-fired generation by equivalent of 30 new plants by 2020," the presentation concludes that "When public understands this, there will be reaction."  Well, consider this your notice.  React!

Offshore wind is being presented as more expensive than onshore wind.  Those estimates do not take into account the cost of getting onshore wind to market via $300B of new transmission.  When the true cost of onshore wind is recognized, it's not such a bargain after all.  The PJM cartel needs to quit dragging its subservient feet and stonewalling offshore wind.

It seems nobody can resist piling on the AEP beat down lately.  Okay, I'll admit it, it makes me laugh to watch AEP get some of what they so rightly deserve.

In addition to having their rate increase settlement revoked by PUCO, having their stock tank, and their leader's baby tantrum causing a public relations disaster, a few other unsavory deeds of AEP greed have also surfaced in the news over the past couple of days.  AEP's spin-meisters are probably spending the weekend digging a hole that they plan to jump into and pull in after themselves on Monday morning.

First, it was revealed that AEP had signed a contract to lease mineral rights it owns under reclaimed strip mining land in Ohio to Anadarko Petroleum, who plans to frack it up.  The deal will net AEP about $15 million over the next seven years, plus royalty payments.  The only hitch is that part of the mineral rights leased are underneath land AEP previously donated to the Columbus Zoo for use as a wildlife park, breeding ground and research center.

"Dale Schmidt, CEO of the Columbus Zoo and Aquarium, which operates the Wilds, said he wasn’t aware a lease had been signed."

Remember now, AEP is crying poor and threatening to lay off workers if it doesn't get its rate increase reinstated.

Meanwhile, it was revealed that an AEP adjuster in Charleston, WV, has bilked the company out of over half a million bucks by filing false "power surge damage" claims.  Of course, it's not the company who ultimately would have paid these costs, remember all their costs get recovered from electric consumers. From what I've seen of power company accounting practices over the past couple of years, I'm surprised they even managed to figure it out.  After all, what's a half million bucks between friends, right?

And just in case competitor FirstEnergy is getting a little too giddy about AEP's misfortune, PUCO reached out and slapped FirstEnergy down for their scheme to make a bundle of money off their plant closures in the state.  In an order issued last week, PUCO required FE to re-think implementation of mandated energy efficiency and demand response programs in order to reduce expected rate increases caused by the plant closures.  Caught, FE!

My, my, my, how far we've come from our "good buddy" days when these two greedy corporations thought they'd get together and run a 300 mile transmission line through the backyards of a bunch of ignorant hillbillies and get rich.  It really sucks to be them.  Heh.

In this press release the Coalition for Fair Transmission Policy (CFTP) points out that investment in new transmission is expected to increase 43% between 2011 and 2014.

"According to the Edison Electric Institute, shareholder-owned electric utilities and stand-alone transmission companies for the first time in 2010 surpassed the $10 billion mark for a yearly investment in transmission infrastructure. Spending on transmission increased nine percent from 2009 to 2010, EEI reported. Utilities and others are expected to invest $54 billion on transmission between 2011 and 2014, a 43 percent increase over transmission investment during the previous four-year period, 2007-2010, EEI reported."

That's because transmission is a tidy profit center for investor-owned utilities.  In return for their investment, these companies earn an immediate, guaranteed double-digit return on equity courtesy of federal transmission incentives and formula rates, even if the projects they invest in never get built!

While the CFTP makes some good points about broad socialization of transmission costs, the wisdom and ultimate cost of a "national grid" build out to support on-shore wind, and federal control of transmission siting and permitting, it's pretty hard to take them seriously or to want to support their "coalition."

That's because their membership (bankrollers) is composed of some of the worst perpetrators of the same bad policies they denounce.  For instance, member PSE&G is currently gouging over 60 million ratepayers throughout the 13-state PJM region for their unneeded Susquehanna-Roseland Project, as well as multiple other transmission projects they are undertaking.  If Susquehanna-Roseland had to be paid for solely by the ratepayers that benefit from it, it would not be cost effective.  S-R will purportedly reduce electric costs in New Jersey and load centers located at its eastern terminus.  According to CFTP, that's who should pay for the entire line.  Instead, PJM's cost recovery policy socialized PSE&G's cost across their entire region.  If we believe that S-R will reduce prices in New Jersey, we also accept the fact that S-R will increases prices to the west of it's starting point.  This "levelizing" of prices within the region is what PJM's screwed up markets promote.  Why is it that ratepayers who bear the direct brunt of proximity to "cheaper" generation must not only pay the cost of new transmission to make electricity cheaper for other load centers without enough generation to support their needs, but also have the prices they pay for electricity raised by the ultimate "benefit" of these same transmission projects?  This is the bad logic that PJM has been getting away with for years with their destructive "markets."

CFTP is just another corporate-funded "coalition."  These "coalitions" always have ulterior motives because, let's face it, corporations aren't in the "warm & fuzzy" business of helping consumers.  They exist to turn a profit every quarter.  Every expenditure is geared toward increasing those profits.  So, while their "coalition" has some good arguments, they're also a bunch of hypocrites.

As I'm sure you all remember quite fondly, last year around this time, the PATH Project was "held in abeyance" by PJM, who also said they would continue to evaluate the project for inclusion in a future RTEP.  What they also said at that time was that they were embarking on a process to retool the way they do their planning. 

Here's the result of PJM's work over the past year.

PJM uses PATH (and MAPP) as an example of how their planning process "ha[s] impeded PJM’s ability to plan for its system with any certainty."  PJM ended up with a whole bunch of egg on their face when they persisted with their Project Mountaineer plan to use their RTEP process as a vehicle to promote purely economic projects as reliability projects.  It was embarrassing and inconvenient for PJM and its profit-driven transmission owner "stakeholders" to have the projects they determined were "needed" drop out of the RTEP in future years because they weren't "needed."  PJM's planning process was too rigid and based on clearly defined criteria with no room for opaque, subjective camouflage of superfluous projects.  PJM set out to create a new process where a project, once included in the RTEP, could never be omitted.

It didn't turn out much different than I thought it would.

PJM has added what they call "sensitivity studies, modeling assumption variations and scenario analysis" to their process.  In the future, when need for a dead dog like PATH becomes shaky, PJM will have the ability to just add a few more mystery spices to the planning pot in order to create a new reason to continue to pursue a loser project.  It's not just about "reliability" anymore:

"PJM believes there is merit in allowing for flexible planning criteria and proposes to expand its analyses
beyond a strict application of the reliability criteria in order to identify the most effective transmission system upgrades to satisfy the needs of the system. This proposed balanced approach starts with defined criteria and then allows PJM to look further to identify and evaluate potential transmission system needs using sensitivity studies, modeling assumption variations and scenario analyses, including Public Policy Objectives."

And about those "public policy objectives"...  PJM isn't just going to consider "public policy requirements" of state (or federal) mandates that are actually enacted statutes and regulations, but also "public policy objectives" that are "public policy initiatives of state or federal entities that have not been codified into law or regulation but which nonetheless may have important impacts on long term planning considerations."  So, as if it's not bad enough that you may end up having your property taken for a transmission line made necessary by the laws of another state, you may now also lose your property to a transmission line made necessary by the idea for a "public policy" in another state.  I can't wait to see this tested in a court.  I'm sure the wait won't be long.

PJM has also made a couple other changes, in order to show FERC how impartial, open, transparent and loved their planning process turned out.  PJM has added a new committee to their stable of "stakeholders."  The "Organization of PJM States, Inc. (“OPSI”), by unanimous resolution officially endorsed forming an Independent State Agencies Committee (“ISAC”) comprised of interested state agencies within the PJM footprint."  This committee will be composed of state public service commissions, who are still your only official line of defense against unneeded, prohibitively expensive, greed-driven transmission projects.  Despite PJM's attempt to make it sound like the states are enthusiastically supporting their new planning process and their new role at PJM, it looks like the states are suspicious.  And they should be.  Their authority to permit and site transmission projects within their borders has been under constant attack by the industry, FERC and PJM, who are pushing for a single federal transmission siting and permitting process whereby the states and citizens have a very limited voice.

PJM also proposes that they will "expand and enhance its planning procedures with respect to the communications and interaction around all phases of the process":

"The Transmission Expansion Advisory Committee shall be open to participation by: (i) all Transmission Customers, as that term is defined in the PJM Tariff, and applicants for transmission service; (ii) any other entity proposing to provide Transmission Facilities to be integrated into the PJM Region; (iii) all Members; (iv) the electric utility regulatory agencies within the States in the PJM Regional and the State Consumer Advocates; and (v) any other interested entities or persons."

Yeah, they talk a big game, but they get madder than a wet cat when a mere ratepayer intrudes into their playground.

Because PJM's new plan is a Section 205 filing, anyone, including YOU can comment, protest or intervene within the next 21 days.  If you need more info. about these processes, let me know.