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Transource + RGGI + Pennsylvania

10/9/2019

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In case you missed it, Pennsylvania's Governor recently signed an Executive Order leading to the state joining RGGI.  What's RGGI?  The Regional Greenhouse Gas Initiative is a voluntary market-based "cap and trade" program intended to limit carbon emissions.  The initiative sets a regional "carbon budget" and member states auction off a set number of carbon allowances that correspond with the budget.  All carbon emissions must be offset with allowances purchased at state auctions.  The regional carbon budget is incrementally reduced each year, shrinking the amount of carbon released into the atmosphere.  The states auctioning off the carbon allowances use the proceeds for whatever they like, such as energy efficiency programs, low-income energy assistance, or subsidies for new "clean" generators.

Does it work?  Depends on who you ask.  Some say it has reduced carbon emissions and electric prices.  Others say it has had no effect on carbon emissions and has raised electricity prices in member states.  And all opinion on the matter is political.

One thing I found interesting is that RGGI fans claiming reduced emissions and prices are giving RGGI credit for factors it had nothing to do with, namely cheap natural gas and the huge shift from baseload coal to baseload gas electricity generation.  In order to properly evaluate RGGI, you must do it in a vacuum.  Our complicated regional electricity markets don't allow such a vacuum, therefore it is truly impossible to determine whether RGGI works or not.

Another interesting tidbit is that RGGI caused emissions "leakage" to non-participating states.  If it's too expensive to emit carbon generating electricity in a participating state, the same generation can happen cheaper in a neighboring, non-participating state.

One thing unavoidable is that requiring generators to purchase carbon allowances creates revenue for a state, and that revenue creates a whole new cost for generating electricity.  Who pays for that?  Electric consumers.  Whether RGGI works to lower prices to offset the new costs gets into a lot of complicated stuff that can be used to bolster claims of success or failure of RGGI.

Pennsylvania is the biggest exporter of electricity.  Generators in the state produce much more than Pennsylvanians use.  Enter Transource.

The Transource transmission project was dreamed up to export cheap energy from Pennsylvania.  Energy in Pennsylvania is cheap because there is a surplus.  Transource will export Pennsylvania electricity to Maryland, Virginia and Washington, DC.  Maryland and Virginia import a lot of electricity, instead of generating their own.
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Transource will essentially take from the land of plenty and give to the land of scarcity.  Cheap power into expensive markets.  This lowers prices in Maryland and Virginia, while raising them in Pennsylvania.  This fact was proven during state utility commission hearings on Transource's application to build its project and is no longer debatable.  It's reverse Robin Hood, robbing from the poor to give to the rich.

So, how might RGGI affect Transource's already fragile cost-benefit ratio if it is implemented in Pennsylvania?  Will it lower the amount of electricity Pennsylvania exports?  Will reductions in the amount of electricity produced in Pennsylvania raise its electricity prices?  If the price of electricity in Pennsylvania rises, will Transource actually save money for electric customers in Maryland and Virginia?  What purpose will the transmission line serve if the electric price differential it's based on evaporates?  There's going to be lots of geeks at PJM Interconnection hunched over their abacuses trying desperately to continue the charade that the Transource project serves some purpose other than to provide parent company American Electric Power with a double digit return on its investment.

The answer is a wishy-washy "who knows?"  What is certain is that the Transource project is going to cost regional electric consumers hundreds of millions of dollars in increased electric bills.  Cost = certain.  Benefit = uncertain.

Just one more reason to halt this dated project.
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Knocking A God From Its Pedastal

9/15/2019

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There was a news article many moons ago that quoted PJM Interconnection's government schmoozer as saying "PJM answers to no one."  True in practice, but maybe not on paper.  To whom do the handful of regional transmission organizations and Independent System Operators answer?  On paper, perhaps, it's the Federal Energy Regulatory Commission.  In practice, it might as well be no one.  FERC does little to make RTOs/ISOs answerable to the consumers they're supposed to serve.  As a result, RTOs do whatever they please and answer to no one.

The RTO does whatever it wants and suffers no consequences.  If its planning or data is off, there is no accountability.  Payment of damages is not the solution since RTOs are not-for-profit entities wholly supported financially by electric consumers.  Essentially, consumers harmed by the actions of an RTO would be suing themselves.

Except now the Texas Supreme Court is considering whether the Electric Reliability Council of Texas (ERCOT) should pay damages to a company that built several new power plants based on ERCOT projections that subsequently went under because ERCOT's projections turned out to have been wildly wrong.
Panda Power built three power plants earlier in this decade, investing billions of dollars based on projections from the state’s grid manager that Texas desperately needed more generation to meet growing electricity demand. But those projections turned out to be wildly wrong — Texas, in fact, had plenty of power — and Panda ended up losing billions of dollars and putting one of the plants into bankruptcy, unable to sell electricity at prices sufficient to cover debts.
The Dallas company is now in court, alleging that the Electric Reliability Council of Texas intentionally manipulated the projections to encourage new power plant construction and relieve the political pressure that was building on the grid manager to increase generation in the state. The case has implications that reach beyond whether Panda gets its money back to issues as profound as the reliability of power grid, the integrity of the wholesale electricity market and the accountability of an organization whose decisions affect thousands of businesses, millions of people and billions of dollars.
The Texas Supreme Court is considering whether ERCOT, a private, nonprofit corporation, is entitled to sovereign immunity, a well-established legal principle that protects governments and their agencies from lawsuits. The high court’s decision, expected later this year, could determine whether electricity buyers and sellers can hold the grid manager responsible for pricing errors, mistake-ridden forecasts or life and death consequences of power outages.
Sovereign immunity?  What's that? Sovereign Immunity is a judicial doctrine that prevents the government or its political subdivisions, departments, and agencies from being sued without its consent. The doctrine stems from the ancient English principle that the monarch can do no wrong.

Ahh... here were are again at the question of RTO godliness.  Except RTOs are not governments or government entities.  They are industry cartels, run by a membership of for-profit utility corporations, sanctioned by a federal regulator.  So, who is responsible when an RTO makes a huge mistake that costs another party financial harm?  The consumers who "benefit" from the RTO actions are also responsible for its mistakes.  Is it that RTOs just provide so much benefit that they are allowed to make some mistakes that come off the "benefit" tally?

It seems that way, if you take in the big picture.  RTOs routinely make mistakes in their transmission planning.  Often, an RTO has ordered a new transmission project that is proven to not be needed.  Once an RTO orders a transmission project, consumers pay for it.  But what happens when a transmission project consumers have been paying for is found not to be needed after all?  Consumers still pay for it.  Even when it is not built, the utility "ordered" to build it is held harmless (because it was only doing what it was ordered to do), and is shielded from taking any financial responsibility for the project.  Abandoned transmission ideas are fully recovered from ratepayers, plus interest.  And we're not just talking about minor costs here, we're talking about billions of dollars paid for bad transmission ideas that were cancelled before putting a shovel to the ground.

But what if RTOs found themselves liable for their mistakes?  In the Texas case, it would mean that the company who built the unneeded power plants is made whole, and consumers in Texas would foot the bill for the failed power plants.  How is that any different that what happens every day as a result of failed transmission plans?  A transmission line is fully recoverable, but a generator is not?  Is that because a transmission line is "ordered" and a generator assumes its own risk based on RTO forecasts?  Why are transmission lines more necessary than generators?  They ought all be put in the same basket.

This is an interesting case to follow.  Will RTOs finally have to answer to someone?  Will consumers get tossed under the bus again?  And how do we fix the escalating problem of RTO mistakes?  No accountability increases mistakes.  If there is no penalty for a mistake, accuracy goes out the window.

And what about those for-profit utilities that constitute RTO memberships?  When are they going to be held responsible for their own errors?  In reality an RTO rarely comes up with a transmission idea of its own.  A transmission idea is brought to the RTO by the for-profit utility, and since the RTO is membership driven, the RTO is merely a rubber stamp for its members.  The RTO gives the for-profit utilities a mantle of immunity, a sense that it answers to no one, and failure becomes unimportant because someone else will pay for it.

This article perhaps suggests that RTOs should be government entities, not for-profit utility cartels.  Would that cure the error rate?  Doubtful.  It would just grant immunity to a bunch of inept governmental functionaries captured by for-profit utilities.

Perhaps the member utilities should be responsible for the costs of failed RTO planning?  Of course, as the article points out, they would simply pass these costs onto their customers.  However, the costs would become more visible to consumers and the for-profit utility would have to wear the failure in the court of public opinion.

If RTOs do not enjoy sovereign immunity, perhaps it's time to start holding them financially accountable for their mistakes.

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PJM Never Seems To Learn Its Lesson

5/23/2019

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Someone shared this with me.  It's PJM's recent Market Efficiency Update with the 2018/19 Market Efficiency Window list of submitted projects.  For the four identified "congestion drivers" (congestion points to be solved), PJM received 34 proposals (including two with no congestion driver at all - everyone into the pool!).  Of those 34 proposals to relieve congestion, 25 of them are greenfield projects.  A "greenfield" project is one that is built in a place where no transmission currently exists (let's turn that green field into an ugly transmission mess!) and needs new siting on new right of way.
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Only nine of the projects make use of existing infrastructure that can be upgraded.  Just 9!  Prices for relieving "congestion" range from $0.1M to $291M, with the higher price tags being attached to the greenfield projects.  Of course it costs more to build new than upgrade existing.

Here's the first problem:  MARKET EFFICIENCY PROJECTS SHOULD NEVER BE GREENFIELD PROJECTS!

Greenfield projects need new rights of way, "negotiated" under threat of condemnation through eminent domain.  Nobody's property, and I do mean NOBODY, should be taken through the use of eminent domain just so someone else far, far away can save a few pennies on their electric bill.  The lights won't go out if market efficiency projects aren't built.  Instead, the market will provide its own solution to congestion if PJM allows it.  But PJM never does.

Therefore, with this slate of bad news on its table, here's a little advice for PJM.

Constructability studies:  Make sure you do them properly this time.  Factors that must be included are land use and ownership, to include recognition of historical properties, century farms, conservation land, and residential areas.  These are the kinds of property takings that inspire entrenched opposition.  This kind of opposition is what kills transmission proposals.  Another is "transmission fatigue" -- repeated attempts to site new transmission in a community.  Once a community comes together to oppose transmission, it is better armed for the next battle.  Even waiting a generation to try again doesn't make for success.  It is imperative that any constructability study recognize the possibility of opposition.  But, pretty much ANY greenfield project is going to meet with opposition, and you never know what you're going to get until the community finds out about the project.

How could PJM overcome this?  How about a public community meeting to discuss the finalists that make PJM's finalist list?  Go see what the community thinks about your proposal BEFORE you approve it, PJM.  BEFORE your transmission owner goes crying to FERC about needing the abandonment incentive.  How about BEFORE any consumer money gets spent on another hare-brained greenfield market efficiency project, PJM?  How about that?

PJM still hasn't learned its lesson.  Market efficiency projects aren't compelling enough to build new lines.  Ever.  Better give those upgrades another look.
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PJM admits that existing lines are a viable alternative to Transource

5/16/2019

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PJM filed rebuttal testimony in Maryland last week, and in Pennsylvania on Tuesday, admitting that existing infrastructure is a viable alternative to the IEC-East.  In his new testimony, PJM Vice President for Planning Steve Herling stated that two existing lines owned jointly by BGE and PPL present a feasible alternative to the Transource IEC-East.
 
Both of the existing lines were completely rebuilt within the last five years, and stand empty on one side of the towers.  Both lines originate within two miles of the new Transource-proposed substation, and can be reached from the substation via an abandoned transmission right-of-way.  Both lines operate at the same voltage as the IEC, and one of the lines, the Conastone-Otter Creek, terminates in the same substation as the proposed IEC-East. 
 
Addressing the new statements from PJM, Stop Transource spokesman Barron Shaw stated, “Finally PJM has admitted what was clear to the rest of us long ago: those brand new lines owned by other utilities could be used instead of the IEC-East.   It has taken them nearly two years to admit this, and they only did it under immense pressure from the state of Maryland.  Not only is their process flawed, but their defense of this unnecessary project has been dishonest.  PJM has lost all credibility.”
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PJM Interconnection Gets Gored on Social Media by Mama Bear

4/29/2019

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This is an aerial view of Amanda Elisaon-Scott's property, where she recently constructed her "dream home" in Harford County, Maryland.  It's just a few feet from the new right of way for Transource's proposed Independence Energy Connection.  Her house is about 300 feet from the tree line, and Transource plans to put its right of way in between her house and the tree line.  This puts the transmission line less than 200 feet from her house, and even less than that from the backyard swing set where her three small children play.  Moreover, because the right of way is just off her back property line, she will receive absolutely no compensation for what could be taken from her.  She worries about her children and her family living within the shadow of giant electric transmission lines.  And she's not going to stand for it.  She's a self-admitted "Mama Bear," and everyone knows what happens when you get between a mama bear and her cubs.

Amanda took it home to its source at PJM Interconnection, in the wake of Saturday's Maryland Public Service Commission Public Hearing.  Amanda went to PJM's Facebook page, where she saw many posts about PJM's community involvement and a recent "take your child to work day."  But there was no place for her to make a post.  PJM has shut off that feature, preferring a "one-way street" for its social media presence, where only PJM may disseminate information.  The only place for the public to interact with PJM on social media is by posting a comment on one of PJM's posts.  And even then, those comments are "hidden" and not viewable by anyone other than their author and that person's Facebook friends.  This is what Amanda posted:
PJM Interconnection why do you filter the comments on your page, why do you not allow the public to share comments or post concerns??? Don't appreciate it when the public calls you out on your lies??? After our community hearing with the Maryland Public Service Commission I am back into full fledged pissed off mama bear mode, and I have ZERO plans of backing down. The entire project is unfounded, unjust, unnecessary and provides no benefit to anyone but YOU and your own financial gain. It will be a cold day in hell before I willingly allow you to destroy my community, our homes, property or my childrens back yard.
*EDITED*, I never expected all the shares, so I wanted to write a bit more of an explanation for those who aren't aware of that's going on.
PLEASE SHARE AND TAG TO SPREAD MORE AWARENESS!!!!!
I'm reaching out to everyone single person I can and through every single avenue there is. Crazy long story short for those who have no idea what's going on. A huge multi million dollar electric company PJM Interconnection has plans to build a new high tension powerline in northern Harford county MD, Washington county MD and Franklin county PA. This is a powerline that serves no purpose, and does nothing to benefit the general public, only the big power companies will reap the benefits. To make matters worse, there are existing underutilized towers that could solve the problem, without having to build a new transmission line. Currently they have plans to enforce eminent domain (steal our land) to build this line, and plan to disrupt homes, farms, orchards and small businesses. They have intentionally chosen farms in agricultural preserve because the land is "cheaper", and hold "less value", so therefore more cost efficient for them to steal. Unfortunately if the state allows this to happen, it will set a precedent that huge money hungry corporations can steal land from whomever they chose for their own financial gain. Does this directly impact you now ?? Maybe not, but I certainly never thought I'd be facing this issue, but here I am. Please Help spread the word. Share share share and share again!! They currently plan to go directly through my husbands great grandparents farm that we were blessed to have been able to build our dream home on, the land that we thought would allow our 3 small sons to safely grow, learn, play and explore. This project, if approved is going to ruin those hopes and dreams. So please, help make this issue known, and spread the word.

PJM exists to serve electric ratepayers in its 13-state region.  All PJM's money comes from ratepayers.  Each one of the 66 million ratepayers in the PJM region pays a portion of PJM's budget (and it's huge!)  And, in return, what do they get?
Can't even make a public comment on PJM's Facebook page.  PJM thinks the ratepayers who pay its bills should have no voice.

Here's what PJM thinks it does:
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Does that say "understand customer needs"?  How could PJM understand customer needs when it shuts itself off from communication with those very customers?  PJM is out of touch with its customers and has no idea what they need.  However, it is very in tune with its "members," like Transource, whose "needs" trump customer needs every time.  It's the epitome of "cartel."

So, like Amanda asked, share.  It's time for every one of those 66 million PJM customers to let their "needs" be known.

To learn more about Amanda's story, watch this video.
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Take a Drive, PJM!

4/28/2019

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Stop Transource filled the house yesterday at the Maryland Public Service Commission public hearing on the Transource project.  It is estimated that around 200 people gave up their Saturday to come out and show their staunch opposition to this project.

Transource opponent Patti Hankins asked PJM to take a drive...
Welcome to our Mason-Dixon Community. A Community at risk due to a broken PJM process.

PJM holds the view, that agricultural land is “undeveloped land” ready and waiting for their transmission projects. PJM fails to consider or care about the negative impacts their transmission projects have on our local economy, local agricultural businesses, rural pastoral viewsheds or the rural Community in general. PJM fails to recognize that agriculture is an intended land use designation. Harford County retains approximately 75,000 acres, or 27%, of the County’s land area dedicated to farming. Agricultural land is in decline and both MD & PA have made preserving agricultural land a priority. We can’t make more farmland.

On November 6, 2017 members of this Mason-Dixon Community, along with elected and appointed officials from both MD & PA met with PJM staff, Paul McGlynn (PJM System Planning), Matthew LaRocque (Manager Regulatory Affairs for MD, VA & NC), and Darlene Phillips (PJM State and Member Services) as a result of a written request to PJM’s Board Chairman. The purpose of this meeting was to resolve the need for any new “greenfield” transmission projects in our Community.

What was and is still disturbing is the failure of PJM and their staff to acknowledge that, as citizens, we know what is best for our Mason-Dixon Community. On November 6, 2017, those PJM staff chose to ignore the invitation by Councilman Chad Shrodes to take a five-minute drive to see the underutilized transmission line, the Otter Creek-Conastone line near Shaw’s Orchard in Norrisville. In fact, the Otter Creek-Conastone line parallels and is located within sight of the proposed Transource IEC-East line almost the entire proposed pathway. To validate this one only has to take a drive.

In addition, we were told that “some states have requirements” to utilize existing brownfields vs. building new greenfield transmission. And that “we are all working with the states to work within and respect the state’s regulations”. And that (the project) “was submitted based on state policy”. If those statements were true, PJM wouldn’t have approved Transource to build an unnecessary, redundant IEC-East transmission line in a Community already beset with existing underutilized transmission lines. Something that is very clear to the members of our Community. All one has to do is take a drive.

We expressed concern to PJM staff that the Benefit/Cost analysis only included costs of siting, costs of ROW’s, substation and equipment costs – transaction and infrastructure costs only, costs specific to building the project. A member of the York County Planning Commission told PJM staff, “those are transaction and infrastructure costs only, project costs specifically related to building the project. You are not looking at the farm economy for local farms. Where is the B/C for the Community? We need to come up with this impact.” There was just silence from the PJM staff present. Matter of fact, our Community still has yet to receive an answer from PJM. So, PJM what is the negative impact to our Community? Are you ever going to answer?

Our Mason-Dixon Community urges the Commission to provide that answer to PJM. Tell PJM that their project, the Transource IEC Project is denied. Tell PJM that existing underutilized transmission infrastructure is the best solution for “Market Efficiency” and/or “emerging reliability issues”. Tell PJM that the next time they propose a problem and search for solutions that they need to just take a drive.
Too bad PJM officials couldn't be bothered to give up their Saturday to listen to citizens concerned about the impact of a project PJM supports.  You drive me crazy, PJM!
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Maryland PSC Public Hearings!  This is Your Moment, Folks!

4/24/2019

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Starting this Saturday, the Maryland Public Service Commission will begin public hearings on the Transource Independence Energy Connection project.  The public -- that's you!  It's time for you to be heard!

It's a rare moment indeed when a government commission volunteers to work on a Saturday in order to provide the widest opportunity for working folks to participate in the very important public hearing process.  In fact, I've never heard of one like this before.  Don't let this important process go by without your comments!

When:  Saturday, April 27.  Hearing begins at 11:00 a.m., but please come early in order to sign up to speak and find a good seat.

Where:  North Harford High School, 211 Pylesville Rd., Pylesville, MD

What:  The Maryland PSC, who will make a decision whether or not to permit this project to happen, wants to hear from the public in order to inform their decision.  If you want to address the Commission briefly (3 minute limit), sign up with the PSC personnel in the lobby before the meeting.  If you think you can't speak, or the idea of doing so simply gives you the willies, you may submit written comments to the PSC staff at the sign-up table.  If you're undecided, come prepared for either action.  However beware that a certain magic happens at these hearings.  The feeling of camaraderie and community you will experience listening to the heartfelt comments of your friends and neighbors has been known to inspire even the most squeamish to trek back out to the lobby to add their name to the speakers' list.  And if you think you don't have a comment to make, please come and listen.  You may find that you want to participate after the hearing gets going, and that's okay.  Many in your community have been working hard, contributing both time and money to preserve your community and stop this expensive and unnecessary project and they would welcome your support during this important hearing.
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Who:  YOU!  You don't have to be a Maryland resident to participate.  You don't have to be an affected property owner.  You're probably an affected ratepayer who will end up paying for this project through increased electric bills for the next 40 years.  Even if you spoke at the Pennsylvania public hearings last year, you may speak again.  This is a whole new commission, making a completely different decision.  Make sure they make the right one!

If you miss this hearing, or it's too far away, you'll have another opportunity on May 18 at Smithsburg High School in Smithsburg, MD, also beginning at 11 a.m.  If no one shows up for this hearing, what message does that send to the PSC Commissioners?  Please make time to attend the hearing closest to you!

Why are public hearings so important?  Public hearings let the commissions know what the affected public thinks about the project and help to drive the opinion they will issue.  A project nobody seems to care about is taken as acquiescence.  But a hotly opposed project causes the commission to take notice that the public who would supposedly "benefit" from the project doesn't want it.

Has public hearing participation made a difference in other states, on other projects?  Absolutely!  Decked out, verbal and prolific public participants have rocked public hearing venues in other states so hard that the project has eventually been denied by the state commission.

It's time to stand up and stand out against Transource.  I guarantee you'll leave the hearing with a full heart, energized and inspired to do the best for your community.  Don't miss this important event!  You'll remember it proudly for a long, long time!
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Maryland State Agencies Recommend Denial of Transource Independence Energy Connection

4/15/2019

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Maryland's Power Plant Research Program (PPRP), the Maryland Office of People's Counsel (OPC), and other intervenors in Transource's Maryland permitting process filed testimony on Friday.  It's not looking good for Transource.  In fact, it's probably high time for them to throw in the towel and quit wasting my money.

The PPRP coordinates the review of seven Maryland State agencies to provide a recommendation to the Maryland Public Service Commission.  The recommendation is denial.
The recommendation by the reviewing State Agencies to deny a transmission project is a
rarity and is not made lightly, or without significant analysis and consideration. Yet, this project contradicts Maryland’s well-established statutory planning and preservation priorities. While, the work of PJM is vital to assure the reliability of the electricity grid that serves Maryland, what is most beneficial for the applicant, or PJM and its stakeholders, is not always what is in the public interest of the State and its residents. This discretionary PJM-driven market efficiency project, and the process used to approve it, demonstrates this divergence. As described by the Direct Testimony of the Secretary of Agriculture, Joseph Bartenfelder, and the Executive Director of MALPF, Michelle Cable, Maryland’s agriculture industry is vital to Maryland as its single largest industry after the federal government, which is why Maryland has prioritized preserving farmland and ensuring the integrity of MALPF easements. Projects that diminish the State’s efforts and devalue its investments to preserve this finite resource should not be approved when existing infrastructure is available. PJM and transmission developers should reasonably be expected to incorporate Maryland’s stated policies and statutes into their project development and approval processes.
PPRP rarely recommends a transmission project be denied, however Transource's project is so awful that denial is the only option.  This opinion also takes PJM to task for approving a discretionary project that doesn't comport with Maryland's energy policy.  This highlights PJM's biggest shortcoming:  states have the ultimate authority to decide on transmission projects.  Over time, PJM has devolved into a regulatory paper tiger that serves the needs of transmission owners, not the consumers it is ostensibly created to serve.  Until PJM considers states the ultimate stakeholder that they are, this incredible waste of time and money will continue.  Since the Federal Energy Regulatory Commission has granted Transource the right to make a filing to recover its costs of this horrible project in the event it is abandoned (and this event is becoming more of a certainty every day), the longer it continues, the more consumers will pay for a project that is never built and never provides one penny of "benefits" to anyone.

The PPRP puts great emphasis on the fact that viable alternatives to the project exist that would make use of existing transmission and rights of way.  PJM put absolutely no value on making use of existing assets, and Maryland law requires existing assets be considered before new rights of way are taken.

PPRP's opinion also points out that emergent "reliability" issues are the baggage of approving the Transource project in the first place.  Once Transource was approved by PJM and placed in its transmission expansion plan, new generators can be proposed that use it.  Since PJM must plan for transmission to serve generators in its queue, all of a sudden the Transource project becomes a "reliability" issue that would never have developed if the project wasn't approved in the first place.  It's a clear case of the tail wagging the dog.  Because PJM can only order new transmission, but not new generation, it becomes an obstacle to market forces that are supposed to drive the development of efficient and useful generation.  This is a fact that PJM's independent Market Monitor has highlighted in recent State of the Market reports.
The MMU recommends the creation of a mechanism to permit a direct comparison, or competition, between transmission and generation alternatives, including which alternative is less costly and who bears the risks associated with each alternative.
Transmission gets recommended long before any market-driven generation can solve issues.  When the only tool you have is a hammer, everything looks like a nail, right, PJM?

The PPRP's testimony and recommendation is long and consists of many parts, some really interesting.  Personally, I enjoyed the discussion of rare, threatened or endangered (RTE) species that will be impacted by Transource.  In addition to the bog turtles, made famous by Transource's civil suits seeking a court order to enter private property to survey for them, two other RTE species impacted by Transource were discovered, the Checkered Sculpin and the Allegheny Pearl Dace.  Wow!  Great names for things I've never heard of... what might they look like?  Are they some kind of tiny organism with huge names, or do they fit their auspicious monikers, falling into the realm of chupacabras, sasquatches, or mothmen?  They're fish.  Tiny, rare fish.  But even tiny, rare fish serve an important biological purpose.  And what purpose does the Transource IEC serve?  Oh, right, supposedly it will save someone in the DC-metro area a few pennies on their electric bill.

And, on that topic, the OPC's testimony, also recommending denial, highlighted an important fact.  The cost allocation for the Transource project was fixed in August 2016, when the project was approved by PJM.  The cost allocation, which was based on expected benefits at that time, will never change, although the benefits themselves have and will change constantly.  The testimony included an interesting table showing how the initial benefit/cost allocations have shifted over time.  For instance, in the Dominion power zone (DOM) the initial allocation of cost based on expected benefits from the project was 37%.  Dominion was supposed to see 37% of the benefits, therefore it was assigned 37% of the cost.  But since that time, Dominion's expected benefits have risen to 50%.  Dominion will receive 50% of the project's benefits, however its share of the cost of the project is fixed at 37%.  That means that other zones where benefit percentages have fallen will be paying for 13% of Dominion's benefits.
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As an APS customer, I'm going to receive 6% of the benefits, but pay for 8%, taking on 2% of the costs for Dominion's increased benefits.

The longer this project drags on, and the longer PJM and Transource try to bang a square peg into a round hole, the more my 8% share of the costs increases.

STOP IT, PJM!  You have the power to stop it right now.  It's well past time to cancel the Transource IEC!
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Ut-Oh, Dominion!

3/6/2019

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What happens when a utility manages to buy approval to build a highly controversial aerial transmission project that could have been buried to avoid the biggest controversy?

It blows up in their face, that's what.  And it could end up costing ratepayers millions in increased electric fees.

Dominion spent years trying to permit its Surry-Skiffes Creek transmission line project on 300-foot towers across the James River at Jamestown, Virginia.  It agreed to pay out millions in "mitigation" in order to appease opposition (of course, the mitigation will be paid by ratepayers, not Dominion), and it finally got approval.  But not all opposition was bought out and the National Parks Conservation Association continued its legal battle against the project while Dominion was busy constructing its monstrosity across the river.

Dominion turned on the power last Thursday.

On Friday, a federal appellate court ordered Dominion's permit to build the project void and returned the case back to a lower court.

Read about it here.

What's about to happen next is anyone's guess.  The court could order Dominion to turn off and dismantle the project.  Perhaps it will order changes to the project.  Either way, the cost of winning a legal permit will fall onto ratepayers.

This is absolutely absurd.  And expensive.  It probably would have been more cost effective to bury the project across the river in the first instance.

Who's to blame here?  Dominion.  And grid planner PJM Interconnection, who "ordered" the project in the first place.  But who will end up paying for their mistake?  Electric customers.

PJM, you've got to go.  You're costing electric ratepayers too much money!
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How Much Could PJM's Gaming of the System Cost You?

3/6/2019

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If you live in Pennsylvania, it could cost you $514M in increased electric bills.  If you're a JCP&L customer in New Jersey, it could cost you $102.6M.  If you're a PSEG customer, you could pay $156.3M more.  Most customer zones in PJM will pay more for their electricity if Pennsylvania and Maryland regulators approve the Transource Independence Energy Connection.  The majority of customers who would see their rates decrease from this project are located in BGE (Baltimore), Dominion (Northern Virginia) and PEPCO (Washington, DC).  The net change to region wide electric rates amounts to just $12M.  And to realize $12M net savings, PJM has ordered a transmission project that will cost more than $500M to build.  Are they nuts?  Or are they nothing more than electric Robin Hoods, robbing the poor, politically disenfranchised power zones to benefit the rich, politically connected ones?  Either way, something stinks!

Stop Transource member, land and business owner, and party to the state cases Barron Shaw tells us where that smell is coming from in a new editorial.

Everyone probably already knows Transource would cause increased rates in Pennsylvania (and if they don't, it's up to you to share your knowledge with your friends and family).  What's new is Barron's revelation about how Transource parent company American Electric Power and PJM Interconnection have gamed the Federal Energy Regulatory Commission into allowing a skewed evaluation process for new market efficiency projects, and how Transource gamed the system it had set up to make its project appear "beneficial" by essentially stuffing 10 pounds of electricity into a 5 pound bag.
So how can PJM propose a project that doesn’t really save any money, hurts Pennsylvania ratepayers so badly, and costs nearly $500 million to build? 
 
The answer can be found at the Federal Energy Regulatory Commission (“FERC”), the entity charged with regulating PJM.  FERC allowed PJM to implement a tiered system, with one set of rules for smaller projects, and one for larger projects.  Delineated by voltage, the lower tier rules allow PJM to completely ignore all zones that see increases, while the higher tier rules consider the net change to system production cost.  Transource realized that this created a loophole.  They designed the IEC to run at the highest voltage possible in the lower tier, but carry an astonishing 24 conductors.  Though run at only 230kv, the IEC has so many conductors it would have more power capacity than most 500kv lines that form the backbone of the grid.  One expert witness said it carried more power than any 230kV line he had ever seen.  Testimony showed that if the line were evaluated as a higher tier project, it probably would never have been proposed.

And if that isn’t gaming the system, then consider this: when PJM asked FERC to make the changes in the assumptions for future planned generation – the changes that affected the benefits last week – they didn’t provide much analysis.  In fact, they only gave FERC one table of examples.  Those examples showed what would happen to eight small projects with and without the proposed changes.  In all eight examples, the new rules reduced and usually eliminated the need for those projects by showing the projects no benefit.  PJM clearly was trying to tell FERC that they had historically been over-estimating the benefits of projects, and that the proposed rules would more accurately reflect lower benefits and result in fewer unnecessary projects.  But just days after the rules were changed, the IEC showed a $250M swing the other direction.  Bait and switch anyone?  You can almost hear the laughter in the PJM hallways.

PJM is a cabal of utilities interested in one objective: making money.  They have manipulated the rules to allow the proposal of a project that will lose hundreds of millions of dollars, destroy preserved farmland, and raise rates for Pennsylvania residents, all while ignoring existing alternatives.  If nothing else, this process has convinced any objective onlooker that PJM needs tighter regulation.  FERC has been too trusting, and the effects are clear.
That's right, with the help of AEP, PJM created a two-tiered evaluation system based on voltage that allowed the lower voltage projects in the bottom tier to take no notice of increased electric costs in parts of the region that wouldn't see benefit from the project.  And once that system was set in place, AEP designed (and PJM selected) a bottom tier "lower voltage" transmission project that actually moves more power than those in the upper tier that would have to balance cost decreases in beneficiary zones against increases elsewhere in the region.  Because a higher voltage project normally used to move this amount of power would not pass a cost/benefit test, Transource created a monster of a lower voltage project in order to pass the test.  One has to wonder whose interests PJM has in mind when it approves adding additional conductors (wires) to a lower voltage project in order to make it move as much power as a higher voltage alternative using less conductors.  Which configuration is actually more efficient?  Better designed?  Able to be upgraded without building new lines?  As non-engineers, we can't really say, however we can depend on the knowledge of power engineers who don't build this kind of project.  Transource IEC is truly one of a kind, from an engineering standpoint.    And this leads me to believe it's probably not the best idea.  What were you thinking, PJM?  Aren't you supposed to have the best engineering staff in our region in order to keep the lights on?  This isn't a great example.  In fact, it looks like PJM is part of some kind of conspiracy, like a cartel, or a cabal, or both.

Read Barron's entire editorial.  He makes it easy to understand PJM's outrageous manipulation and abuse of its authority to enrich its biggest members.  PJM needs to go!
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    About the Author

    Keryn Newman blogs here at StopPATH WV about energy issues, transmission policy, misguided regulation, our greedy energy companies and their corporate spin.
    In 2008, AEP & Allegheny Energy's PATH joint venture used their transmission line routing etch-a-sketch to draw a 765kV line across the street from her house. Oooops! And the rest is history.

    About
    StopPATH Blog

    StopPATH Blog began as a forum for information and opinion about the PATH transmission project.  The PATH project was abandoned in 2012, however, this blog was not.

    StopPATH Blog continues to bring you energy policy news and opinion from a consumer's point of view.  If it's sometimes snarky and oftentimes irreverent, just remember that the truth isn't pretty.  People come here because they want the truth, instead of the usual dreadful lies this industry continues to tell itself.  If you keep reading, I'll keep writing.


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