Merry Christmas, Transource opponents! The Power Plant Research Program of the Maryland Department of Natural Resources (PPRP) filed a Motion to Dismiss the Transource application on December 20.
The PPRP says that Transource and PJM failed to carry out an analysis of alternatives required by Maryland §7-209 of the Public Utilities Article. This statute requires an analysis of the use of existing transmission in lieu of installing new transmission on new right of way.
PPRP also notes the applicant's changing "need" for the Independence Energy Connection.
The PPRP says that Transource and PJM failed to carry out an analysis of alternatives required by Maryland §7-209 of the Public Utilities Article. This statute requires an analysis of the use of existing transmission in lieu of installing new transmission on new right of way.
PPRP also notes the applicant's changing "need" for the Independence Energy Connection.
In addition, given its responses to data requests and Transource’s filings in the Pennsylvania proceeding, it appears that Transource is modifying its position as to the need for and benefits of the Project from a straightforward purpose of lowering some customers’ electricity costs as a “market efficiency project” to now asserting other benefits associated with emerging reliability concerns. However, if PJM has now determined that there are reliability concerns and an associated need for transmission system enhancements, it would be more appropriate to first investigate reasonable alternatives within the relevant PJM processes rather than latching solutions on to this discretionary market efficiency project.
Bingo! It sure appears that PJM and Transource are changing horses in midstream after the one they were riding came up lame. And who can actually believe anything these two say anymore when their story changes like that? Besides, this isn't the way PJM evaluates transmission to serve reliability needs. PJM is simply making it up at they go along.
PJM's process for evaluating and ordering market efficiency projects does not comport with Maryland statute.
PJM's process for evaluating and ordering market efficiency projects does not comport with Maryland statute.
Furthermore, even though PJM’s market efficiency processes do not incorporate Maryland statutes, it is incumbent on the Applicant to meet the State’s requirements for a CPCN by presenting alternatives to the Project that use existing lines. The PJM process is not a substitute for Maryland’s statutory requirements and its determination that a project is the most effective solution should not allow that project to circumvent Maryland’s comprehensive siting process.
BOOM! Maryland isn't buying PJM's assertion that it is some omnipotent grid oracle who must be obeyed. The real oracle here is the State of Maryland. PJM's role is that of a planner who suggests transmission. Maryland has the role of deciding whether or not the transmission proposed is a good idea.
PJM never seriously considered using existing transmission to meet the supposed "need" for the IEC. PJM purports that such an examination is not part of its process. PJM pretends it is prisoner to projects proposed by its members and cannot require (or even think about) modifying proposals to reduce impacts by using existing transmission to solve the "need." Well, guess what, PJM? Your process is incorrect and needs modification! PJM's process is more in love with the idea of competitive transmission proposals than it is with promoting efficiency and reduced impacts. That needs to change. And if the IEC changes to include the use of existing transmission, it would be much more efficient and cost effective to award the project to the incumbents who own the existing transmission in question. Where's the cost effectiveness of awarding the project to some third party who must pay the incumbent for use of its right of way and towers? That's adding unnecessary cost to the project, when market efficiency projects are supposed to be all about lowering costs. And we know it's just not possible for PJM to force the incumbents to allow free use of their infrastructure to a third party. IEC is a failure on so many levels!
PJM is also a failure. PJM's insistence on the necessity for this badly planned project is failing the electric consumers PJM supposedly serves. And it's costing them a lot of money to continue to entertain this bad idea. What's it going to take to make PJM give up this charade? An order from the Federal Energy Regulatory Commission to change its competitive transmission process? It not only prevents unnecessary spending, it also makes great common sense for PJM to incorporate an analysis of existing transmission use and a real "constructability analysis" into its planning. The IEC is a dead dog. Stop the bleeding and fall on your sword, PJM, this project is dead. It will never be approved by the states, and the states have final authority on whether or not it will be built. Quit wasting my money tilting at the windmills of inevitability that this project is going to be denied. There are a multitude of options available to PJM to cancel or suspend the IEC right now.
However, the Maryland PSC has set a deadline for responses to the Motion to Dismiss of January 7. After that, the Commission will make a decision. Let's hope it's a sensible one!
PJM never seriously considered using existing transmission to meet the supposed "need" for the IEC. PJM purports that such an examination is not part of its process. PJM pretends it is prisoner to projects proposed by its members and cannot require (or even think about) modifying proposals to reduce impacts by using existing transmission to solve the "need." Well, guess what, PJM? Your process is incorrect and needs modification! PJM's process is more in love with the idea of competitive transmission proposals than it is with promoting efficiency and reduced impacts. That needs to change. And if the IEC changes to include the use of existing transmission, it would be much more efficient and cost effective to award the project to the incumbents who own the existing transmission in question. Where's the cost effectiveness of awarding the project to some third party who must pay the incumbent for use of its right of way and towers? That's adding unnecessary cost to the project, when market efficiency projects are supposed to be all about lowering costs. And we know it's just not possible for PJM to force the incumbents to allow free use of their infrastructure to a third party. IEC is a failure on so many levels!
PJM is also a failure. PJM's insistence on the necessity for this badly planned project is failing the electric consumers PJM supposedly serves. And it's costing them a lot of money to continue to entertain this bad idea. What's it going to take to make PJM give up this charade? An order from the Federal Energy Regulatory Commission to change its competitive transmission process? It not only prevents unnecessary spending, it also makes great common sense for PJM to incorporate an analysis of existing transmission use and a real "constructability analysis" into its planning. The IEC is a dead dog. Stop the bleeding and fall on your sword, PJM, this project is dead. It will never be approved by the states, and the states have final authority on whether or not it will be built. Quit wasting my money tilting at the windmills of inevitability that this project is going to be denied. There are a multitude of options available to PJM to cancel or suspend the IEC right now.
However, the Maryland PSC has set a deadline for responses to the Motion to Dismiss of January 7. After that, the Commission will make a decision. Let's hope it's a sensible one!
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