PJM's answer, dated December 24, 2010, has finally been pried out into the open only through an epic feat of persistence.
PJM completely avoided the issue of the conflict of interest presented by their choice of contractor for the Liberty study. PJM claimed that because the conflicted contractor determined that Liberty could not be completed before the 2015 PATH in-service date, there was no need to prepare a similar cost analysis for PATH. Cost is not important when there's such a reliability crisis, so therefore, PATH is the only solution, no matter how much it really ends up costing. Conflict of interest? Bias? Hello?
Regarding the CAD/OPC concerns about PJM's failure to consider the Mt. Storm - Doubs rebuild's increased capacity in their planning, PJM responded with this gem.
"PJM staff explained that the analysis showed the Mt. Storm-Doubs rebuild -- by itself -- would resolve only the overload on the Mt. Storm-Doubs line, and would not solve the other expected reliability violations in the region."
This is particularly ridiculous in retrospect, now that MSD has finally been acknowledged as one of the major factors responsible for PATH falling off the end of PJM's 15 year planning horizon and subsequent removal from the 2011 RTEP.
Lying is a terrible habit that can be quite embarrassing!