PJM's Implausible Deniability

 Regional grid planner/operator PJM Interconnection says that it selects proposed projects based, in part, on their "constructibility."  Other factors PJM considers are cost, and whether or not the proposal solves all the grid issues in the RFP (which PJM calls an "Open Window').

PJM's credibility goes right out the window, though, when it ignores "constructibility" issues and pretends the projects it selects are "constructible."

What is "constructibility"?  It's the likelihood of permitting problems, the ease of getting equipment and supplies, and OPPOSITION.  Let me say that again... the likelihood of opposition to a transmission proposal developing makes it less likely that the project will actually ever be built.  That's why utilities should never site new projects on old routes from abandoned projects that developed opposition.  If a transmission project was opposed at that location in the past, there's a 100% chance that opposition will develop there again.

If PJM really cared about "constructibility" it would conduct public outreach before selecting new transmission projects.  But what if PJM is simply erecting a smoke screen of "plausible deniability" so it can pretend unconstructible projects that it favors are actually viable?

And if PJM was constructing a "plausible deniability" constructibility scenario, it would rely on the most implausible claims of the utilities that have proposed the projects.

Here are some actual claims made by project proponents in their proposals to PJM.

A large scale set of projects that solve the growing congestion issues in the southern Pennsylvania/northern Virginia/Maryland/West Virginia area. The project involves strategic rebuilds, substation upgrades, and greenfield transmission lines that primarily follow existing corridor. This strategic use of existing corridor greatly reduces the risk of projects being delayed due to opposition.

Colocating the line with the existing transmission line helps mitigate viewshed issues and permitting risk.

No.  It does not.  Cutting a new corridor next to an existing one does not prevent opposition.  Those folks with existing corridors on their property don't want another, and they don't want to lose more land to an electric line that provides no benefit to them.  You can't expect the same people to make the same sacrifice over and over again for the benefit of others who never make any sacrifice.

A cultural resource professional assisted with the routing process to identify and minimize impacts to known areas with historic sensitivities.

The utility hired the right contractor who didn't find what he was paid not to find.  Why should anyone believe a paid utility consultant?  This contractor's idea of "historic" is probably not the same as yours.  If it's not on the Historic Register or preserved in some way, it is likely to be destroyed.  Opposition doesn't care about some contractor's opinion.  Opposition forms and acts based on it's own opinion.  Hiring a contractor does not increase constructibility.

There are no unique or sensitive environmental concerns or impacts with the proposed transmission line that cannot be addressed.

But you didn't ask the landowners who live there what they think and they are the ones who control opposition.  What does "addressed" mean?  It means the utility blows a lot of smoke and nonsense and plows ahead according to its own plan.  Then the utility can say it "addressed" your concerns... by telling you your concerns are stupid.

The combination of these three elements provides a comprehensive solution for the current requirements in the area.  Four documents are attached to show the progress already made on this...

Except you forgot to mention that the PA PUC already denied your application for this project the first time it was ordered by PJM.  Ordering it a second time does not change the PA PUC's mind.  And it certainly does not change the minds of the impacted landowners who created massive opposition.

But, but, but....

The Rice-Ringgold 230kV Route is the result of a robust siting and outreach process which included input from landowners, local officials, and key stakeholders on a multitude of study segments. The proposed route will be 130 feet in width, parallels existing rights-of-way including interstates, roads,railroads, and existing transmission lines for 42% of its length, and best minimizes potential impacts to the natural and human environments. The extensive Siting Study is available for review under PA PUC docket A-2017-2640200. In addition, the Proposing Entity has been able to obtain 70% of the required ROW, via option agreements or easements, for the Rice-Ringgold 230kV line route.

Oh, you mean the PA PUC docket where they denied your first permit application?  The landowners refused to go along with the transmission plan.  What good is their "input" when it consisted of a firm "no."  And speaking of "robust" how many of those landowners have you consulted about bringing this project back from the dead?  I'm going to bet it is ZERO.  They will oppose this project again.  Guaranteed.

But, but, but...

The project will use steel, monopole structures with foundations. The use of steel monopoles was determined during the siting of the Proposed Solution due to significant landowner opposition to lattice towers, particularly in agricultural areas.

That flat out never happened.  Landowners objected to the project itself, not just the tower structures.  The utility simply made up a landowner preference for monopoles.  It's sort of like asking... would you rather be shot or stabbed?

As the Proposed Solution continues to move forward, representatives will continue to be available throughout construction to answer questions from landowners.

And that stops opposition how?  Landowners have long ago stopped believing any of the lies the utility tells them.

The Peach Bottom - Doubs Route is mostly in rural areas. Northern portion of the route is located in southern Pennsylvania with rural and farmed properties and then the route heads to the west. The route is to the north and west of Westminster and then heads in a south-westerly direction to Doubs.

Rural people hate transmission at least as much (or more) than suburban/urban people.  This is because those rural farm folk depend on their land to make a living.  When portions of the land are removed from production and devoted to new transmission lines, it reduces the farm's income.  Just think... what if a transmission line in your back yard took part of your paycheck away from you every pay day?  Rural siting does not make a project more constructible.

PSE&G will coordinate all outreach, real estate-related requests, and efforts to identify environmental and non-environmental conditions affecting the properties along the proposed Project route. Working collaboratively with our internal Outreach Team, PSE&G will coordinate stakeholder engagement and public outreach with land acquisition planning. This level of collaboration will help to ensure proactive and cohesive stakeholder communications in order to better serve landowners and impacted individuals and entities. PSE&G contemplates the need for access roads and areas, as part of any lands to be acquired
 
PSEG has identified several properties that are suitable for this proposed solution. The Project Team has initiated contact with the property owners and will continue to work to acquire site control in the event of award. The Project Team will work with impacted stakeholders, municipalities, and local authorities to obtain the necessary property rights to construct and maintain its facilities. While this solution is located outside of PSE&G territory, PSE&G is committed to a transparent, timely, and efficient land rights acquisition process for any site control required. PSE&G intends to utilize the same land acquisition professionals from start to finish, ensuring landowners have the same team assigned to their negotiations throughout the process.

You get the same annoying land agent showing up unannounced at your home, and maybe your job, and calling you incessantly.  Maybe they'll even contact other family members, neighbors or friends and ask them why you're resisting.  Land agents are aggressive jerks.  Having the same one bothering you is not a benefit.

Outreach is just another word for outrageous lies and one-way information.  Any suggestions you make will be ignored.  You will be promised all sorts of stuff (but never in writing).  Reality is going to be very different.

It doesn't matter how much "information" you spew, landowners still don't want your project and will form a wave of opposition.

The greenfield transmission line between North Delta station and Northeast station will require an ROW with a width of 85 feet in residential areas and 100 feet farmland.

But it's the same project in both places!  Why take more land if it's a farm?  Do you think farmers have more to spare?  Inequitable treatment fuels opposition.

ROW will be acquired to widen the existing transmission line corridor from 150 feet to 200 feet.  Approximately 102 acres of additional ROW will be acquired, which is all privately owned.  Negotiations with private landowners will be based on fair market values determined by a third-party  appraiser. Negotiations with private landowners will be conducted by PPL ROW Agents and PPL contracted ROW agents.

That third-party appraiser?  He's just another hired utility contractor paid to find what the utility wants him to find.  He likely lives in another state and has never even set foot in your county.  His job is to research land sale prices in your county and find the lowest ones he can so the utility can offer you rock bottom and tell you it is "fair market value."  The utility only pays you for the value of the land in the easement.  It does not pay damages to the remainder.  It does not pay for decreased property value.  It does not pay for permanent loss of income.  This is nothing more than standard procedure for ROW acquisition.  There's nothing special about it that makes it more likely the project can be constructed without opposition.

PPL Electric is committed to open communications and transparency throughout the project lifecycle. As such, PPL Electric develops a project-specific Community and Outreach Plan based on the unique conditions associated with each project. To communicate clearly and transparently, PPL Electric utilizes a wide variety of strategies including, in-person meetings with local municipalities and regulators, direct mail, project websites, fact sheets, frequently asked questions, and public open houses. For example, during previous projects, PPL Electric has developed a strategic public outreach program that served as the cornerstone of project success. The program included soliciting input from, and providing timely updates to, external stakeholders from the onset of the project through to completion. This was achieved using face to face meetings, direct mailings, multiple rounds of open houses, fact sheets, press releases and an interactive website.

Sounds just like every other transmission "outreach plan."  It's a flurry of secret gladhanding meetings with public officials, a lot of lies, and a complete lack of compromise.  Landowners aren't fooled by this.  Opposition will develop.  There was never a "success."  Landowners were harmed and they hate you.

Most high-voltage transmission projects will require a state siting approval. To begin the siting approval process, Proposer plans to hold pre-application meetings with the regulatory agency to introduce Proposer and the Project, as well as confirm its understanding of the process. Shortly thereafter, Proposer will simultaneously begin collecting siting data and start its outreach efforts so that public siting input is incorporated at the earliest stages of the Project. Once the Proposer identifies a preferred site/route and at least one viable alternative site/route, Proposer will carry out environmental and detailed engineering work in order to establish a highly- detailed Project plan to support the siting applications.

Oh yes, secret meetings with their friends at the regulatory commission before they file an application and before the landowner or the public knows about it.  "The earliest stages of the project" has long passed by the time the public finds out about it and starts making suggestions for alternatives.  That's the one thing that scares these clowns the most... you finding out about their plans before they want you to know... and trying to change the project in publicly beneficial ways.  There are many ways to build transmission (or not), but the utility wants to do it THEIR way on YOUR property and they doesn't want to hear any suggestions from you.

And finally, here's the ultimate word salad about "robust public outreach" that only begins after all the important decisions have been made and the only role left for impacted landowners and the public is to comply.  This is how opposition forms.  Landowners matter!

The Company is committed to working with all interested stakeholders through a robust public outreach program to address/respond to community concerns and inform the public about the project to the greatest extent practicable. The Company believes a well-designed public outreach program can have numerous benefits, including fostering a cooperative relationship with landowners and other stakeholders, expediting the regulatory permitting process, and assisting with project development. In general, the purpose of the community outreach plan is to gain community support for the project. In the affected communities, the Company’s public outreach plan will educate the public and relevant stakeholders on specific project details to enable timely regulatory approvals and construction activities. Elements of the public outreach plan will include the following:1) Identify potential issues at an early stage by engagement with key community stakeholders at the outset; 2) Broaden the community engagement process to identify potential and relevant community benefits that can facilitate community support for the proposed project; 3) Develop a broad base of community support for the proposed project before the regulatory agencies; and 4) Develop a comprehensive administrative record documenting the community outreach process that can be presented to the regulatory agency or, in the event of a legal challenge, to the appropriate court.  The outreach plan proposes to dedicate considerable time and resources in engaging the community, and specifically the affected community during the planning process to identify highly sensitive areas that have the least amount of cultural, environmental, and social impacts on the community. The plans will reflect avoidance of impacts rather than mitigation. However, in some cases, if avoidance is not possible, then the Company will involve the community in providing appropriate and practical mitigation measures. The Company will commence its public outreach activities following project award.

Landowners will NEVER cooperate or support the transmission project.  This old public relations schtick has been tried over and over again and it is always a miserable failure that starts a wildfire of opposition that makes a transmission project unconstructible.

"Community benefits"?  What's that?  It's rewarding the larger community unaffected by the transmission project with trinkets and gifts for their cooperation.  The "community" loses nothing and makes no sacrifice.  It's all gain and no pain.  The landowner, however, takes one for the team and is not comforted at all by the new library across town.  "Community benefits" attempts to split your community into sacrificial lambs and greedy pigs.  Landowners must be compensated by law because they are losing something tangible.  "The Community" isn't compensated because it's not losing anything.  There's a reason for that.  Not all communities can be bribed to throw their neighbors under the bus.  In fact, it may actually increase opposition.

This is the reality that PJM does not want to hear.  It prefers to live in the land of lies created by the transmission companies where it can claim plausible deniability because the transmission companies filled their proposals with lies about constructibility.

Isn't it time you gave them a little reality so that they have to evaluate these projects honestly?