If you haven't been keeping an eye on PJM's Order No. 1000 compliance filing at FERC, you've been missing out on a remarkable display of overreaching greed and self-importance.
The main issue of contention appears to be PJM's state agreement approach to cost allocation for "public policy" transmission projects driven by individual state renewable portfolio goals. PJM's approach is to have these type of projects proposed by the states whose RPS requires them, and who agree to pay for them in their entirety. Entities who stand to profit from building this type of transmission believe they should be free to develop these projects without input from the beneficiary states and that these projects provide some hard to identify regional benefit and therefore should be allocated to all consumers in the PJM region, either in whole or in part.
Since "public policy" is a state matter, decided by state legislators on behalf of their constituents, who the heck do these for-profit transmission builders and Pollyanna environmental organizations think they are to take over administration of individual state policies and direct how they will be fulfilled and paid for?
The transmission builders are representing their own interests to profit from new transmission to meet "public policy" goals, and the environmental organizations are representing their own ivory tower, academic, environmental goals. Neither of these groups represents the consumers who will pay for new transmission. The only entities here representing the most important "stakeholder" of all (YOU!) are the states. The Organization of PJM States makes it quite plain that transmission owners and environmental organizations simply don't have the authority to propose and force "public policy" projects.
"Absent an explicit legislative directive for a project’s construction, turning a “public policy” into a “transmission need” for a project that is not economic or needed for reliability will likely require the interpretation and/or extrapolation of laws or regulations. Such policy decisions and pronouncements are appropriately made by governmental entities and not by private interests or regional transmission planners. OPSI agrees with FERC that the regional transmission planning simply is not the forum for making policy decisions as “[i]t is not the function of the transmission planning process to reconcile state policies.” No employee in the PJM chain of command is appointed or elected by the citizenry to interpret, implement, or reconcile state laws and regulations. The State Agreement Approach appropriately identifies that only authorized policymakers should make the policy decisions and pronouncements that will be required to convert “public policies” into “transmission needs.”
PJM knows that allowing self-interested entities to dictate how individual state energy policy is implemented is a recipe for disaster and has wisely chosen to allow the states to direct and allocate costs of these projects. It's the only way anything is going to get built, ever. However, these gung-ho entities refuse to see how their rabid attempts to force the issue are going to tie "public policy" transmission up in the courts forever. Whatever, fellas, the lights aren't going to go out if these projects don't get built, and the delay will only serve to prove that the most reliable and economic deployment of renewables is through distributed generation, not centralized utility-scale generation. So, keep on holding your breath until you turn blue, it's quite amusing!
I do, however, have to hand out an Audacity Award to the glad-handing shysters at Clean Line Energy Partners for their suggestion that merchant "public policy" projects should also be partially allocated on a regional basis.
A merchant project is paid for entirely by the entity who builds it. All risk is assumed by the transmission owner, who may recover their costs of building the line from the generators and customers who subscribe the line. No costs are allocated to captive customers. Costs are voluntarily assumed by entities who buy the "renewable" transmission.
However, Clean Line's merchant business model is falling apart before their very eyes and now they want YOU to help them pay for it. "Renewable" merchant projects like Clean Line's are not economically feasible. The cost of building the line makes the cost of its product more expensive than competing "renewable" generation. Clean Line has been relying on subsidization of generation costs through the production tax credit to lower the cost of its product. Now with the PTC on the chopping block, Clean Line is looking for another sugar-momma to subsidize its uneconomic business model through allocation of costs to captive ratepayers who will not purchase one electron transmitted over the line. Give up, Clean Line and quit wasting the Zilhkas' money. Thanks for pointing out how ridiculous the rest of the whiner entities' proposals about regional allocation of "public policy" projects can be when extrapolated out to fill your own pockets. Every circus needs a clown. Or is it a monkey on a bicycle? ;-)
The main issue of contention appears to be PJM's state agreement approach to cost allocation for "public policy" transmission projects driven by individual state renewable portfolio goals. PJM's approach is to have these type of projects proposed by the states whose RPS requires them, and who agree to pay for them in their entirety. Entities who stand to profit from building this type of transmission believe they should be free to develop these projects without input from the beneficiary states and that these projects provide some hard to identify regional benefit and therefore should be allocated to all consumers in the PJM region, either in whole or in part.
Since "public policy" is a state matter, decided by state legislators on behalf of their constituents, who the heck do these for-profit transmission builders and Pollyanna environmental organizations think they are to take over administration of individual state policies and direct how they will be fulfilled and paid for?
The transmission builders are representing their own interests to profit from new transmission to meet "public policy" goals, and the environmental organizations are representing their own ivory tower, academic, environmental goals. Neither of these groups represents the consumers who will pay for new transmission. The only entities here representing the most important "stakeholder" of all (YOU!) are the states. The Organization of PJM States makes it quite plain that transmission owners and environmental organizations simply don't have the authority to propose and force "public policy" projects.
"Absent an explicit legislative directive for a project’s construction, turning a “public policy” into a “transmission need” for a project that is not economic or needed for reliability will likely require the interpretation and/or extrapolation of laws or regulations. Such policy decisions and pronouncements are appropriately made by governmental entities and not by private interests or regional transmission planners. OPSI agrees with FERC that the regional transmission planning simply is not the forum for making policy decisions as “[i]t is not the function of the transmission planning process to reconcile state policies.” No employee in the PJM chain of command is appointed or elected by the citizenry to interpret, implement, or reconcile state laws and regulations. The State Agreement Approach appropriately identifies that only authorized policymakers should make the policy decisions and pronouncements that will be required to convert “public policies” into “transmission needs.”
PJM knows that allowing self-interested entities to dictate how individual state energy policy is implemented is a recipe for disaster and has wisely chosen to allow the states to direct and allocate costs of these projects. It's the only way anything is going to get built, ever. However, these gung-ho entities refuse to see how their rabid attempts to force the issue are going to tie "public policy" transmission up in the courts forever. Whatever, fellas, the lights aren't going to go out if these projects don't get built, and the delay will only serve to prove that the most reliable and economic deployment of renewables is through distributed generation, not centralized utility-scale generation. So, keep on holding your breath until you turn blue, it's quite amusing!
I do, however, have to hand out an Audacity Award to the glad-handing shysters at Clean Line Energy Partners for their suggestion that merchant "public policy" projects should also be partially allocated on a regional basis.
A merchant project is paid for entirely by the entity who builds it. All risk is assumed by the transmission owner, who may recover their costs of building the line from the generators and customers who subscribe the line. No costs are allocated to captive customers. Costs are voluntarily assumed by entities who buy the "renewable" transmission.
However, Clean Line's merchant business model is falling apart before their very eyes and now they want YOU to help them pay for it. "Renewable" merchant projects like Clean Line's are not economically feasible. The cost of building the line makes the cost of its product more expensive than competing "renewable" generation. Clean Line has been relying on subsidization of generation costs through the production tax credit to lower the cost of its product. Now with the PTC on the chopping block, Clean Line is looking for another sugar-momma to subsidize its uneconomic business model through allocation of costs to captive ratepayers who will not purchase one electron transmitted over the line. Give up, Clean Line and quit wasting the Zilhkas' money. Thanks for pointing out how ridiculous the rest of the whiner entities' proposals about regional allocation of "public policy" projects can be when extrapolated out to fill your own pockets. Every circus needs a clown. Or is it a monkey on a bicycle? ;-)
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