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.
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.
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