Pride goeth before destruction, and a haughty spirit before a fall.
PJM President and CEO Andrew Ott doesn't seem to understand his place in the transmission regulatory pecking order.
His response to Maryland Governor Larry Hogan's recent letter to the PJM Board of Managers seemed to insinuate that the only role for state regulators once PJM orders a new transmission project is to find a route for it.
His response to Maryland Governor Larry Hogan's recent letter to the PJM Board of Managers seemed to insinuate that the only role for state regulators once PJM orders a new transmission project is to find a route for it.
While it is the transmission developer’s responsibility to work with state and local planning authorities to identify a designated route that can balance the interests of all impacted parties, it is PJM’s responsibility to identify the need for such a project in the first instance. Understanding both the cost and societal impact a project may have, I assure you we do not embark on this responsibility lightly.
Au contraire, Mr. Ott! The state regulator's role is to determine whether a transmission proposal meets the needs of the state and whether it produces an acceptable balance between the burdens of new infrastructure and the benefit to the citizens. PJM's role is merely to suggest when new projects may be needed. The state regulators have the ultimate and final say over whether a transmission project is permitted to be built. Let's be frank here, Mr. Ott, your own beloved PJM Operating Agreement, Schedule 6, Section 1.7, releases the designated entity from building a project if it does not receive approval from all jurisdictional state regulators.
1.7 Obligation to Build. (a) Subject to the requirements of applicable law, government regulations and approvals, including, without limitation, requirements to obtain any necessary state or local siting, construction and operating permits, to the availability of required financing, to the ability to acquire necessary right-of-way, and to the right to recover, pursuant to appropriate financial arrangements and tariffs or contracts, all reasonably incurred costs, plus a reasonable return on investment, Transmission Owners or Designated Entities designated as the appropriate entities to construct, own and/or finance enhancements or expansions specified in the Regional Transmission Expansion Plan shall construct, own and/or finance such facilities or enter into appropriate contracts to fulfill such obligations.
If a state regulator denies a permit for one of your suggested transmission projects, your project is toast.
It is the state regulator who determines a need for such a project in the last instance. And, really, that's all that matters.
It's no great secret that state regulators in both Pennsylvania and Maryland probably don't love this project the way you want them to, and why should they? The "benefits" of the Transource IEC do not outweigh the sacrifice made by the states, and furthermore, much of any trumped up "benefit" will belong to residents of other states. It's high time this project was properly reevaluated, and that you get out your Mr. Magoo specs and read the writing on the wall.
Your claim that PJM "understands the cost and societal impact a project may have" is a joke, right? PJM is a tone-deaf hermit who pays absolutely no attention to the societal impact of the projects it orders. PJM engineers and orders projects but never interacts with the public or pays any attention whatsoever to state permitting, opposition, or public opinion. It prefers to only hear the fully-sanitized and overly optimistic reports of the designated entity. Perhaps that's because PJM thinks it makes the final determination of whether transmission projects should be built and that none of those factors matter. Your belief in PJM's omnipotence is like running around blindfolded. Eventually you're going to hit a wall or fall off a cliff. And that's where PJM is with the Transource IEC project. *splat*
But, I'm an optimist. I believe we'll hear good news on September 13, since you keep promising elected officials and affected citizens that some magic is going to happen upon reevaluation. Because, if it doesn't, the continued fall to state denial is going to be long and hard. And expensive. Very, very expensive for the ratepayers you supposedly serve.
Do the right thing, PJM, cancel the Transource IEC. It's a vital first step to cutting back on your galling hubris.
It is the state regulator who determines a need for such a project in the last instance. And, really, that's all that matters.
It's no great secret that state regulators in both Pennsylvania and Maryland probably don't love this project the way you want them to, and why should they? The "benefits" of the Transource IEC do not outweigh the sacrifice made by the states, and furthermore, much of any trumped up "benefit" will belong to residents of other states. It's high time this project was properly reevaluated, and that you get out your Mr. Magoo specs and read the writing on the wall.
Your claim that PJM "understands the cost and societal impact a project may have" is a joke, right? PJM is a tone-deaf hermit who pays absolutely no attention to the societal impact of the projects it orders. PJM engineers and orders projects but never interacts with the public or pays any attention whatsoever to state permitting, opposition, or public opinion. It prefers to only hear the fully-sanitized and overly optimistic reports of the designated entity. Perhaps that's because PJM thinks it makes the final determination of whether transmission projects should be built and that none of those factors matter. Your belief in PJM's omnipotence is like running around blindfolded. Eventually you're going to hit a wall or fall off a cliff. And that's where PJM is with the Transource IEC project. *splat*
But, I'm an optimist. I believe we'll hear good news on September 13, since you keep promising elected officials and affected citizens that some magic is going to happen upon reevaluation. Because, if it doesn't, the continued fall to state denial is going to be long and hard. And expensive. Very, very expensive for the ratepayers you supposedly serve.
Do the right thing, PJM, cancel the Transource IEC. It's a vital first step to cutting back on your galling hubris.
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