The Atlantic off-shore wind transmission backbone moved one step closer to reality yesterday when The Bureau of Ocean Energy Management issued a finding of "no competitive interest," granting the project needed right-of-way.

Unfortunately for AWC, they still need PJM's approval.  Good luck there, fellas!  :-)

So why doesn't Obama add this to his er-tit, instead of trying to ram through an unneeded transmission line designed to ship coal-fired electricity to the east coast?  Susquehanna-Roseland is going to be obsolete in about 10 years, although we'll still be paying for it for another 60 years after that.

Bob Mitchell is a bit disturbing with his idiotic plans to use the project to transport "low cost" power from Virginia to New Jersey.  Has he been drinking Dominion's Kool-Aid?

Meanwhile, a New Jersey blogger gets up on his predictable soap box to complain about the project's $5B cost and the fact that they were awarded CWIP in rate base by FERC.  Guess what, Tom?  The development of land based wind to serve New Jersey's RPS is predicted to cost ratepayers over $2 TRILLION, according to transmission line building AEP CEO Nick Akins.

"The electric utility industry needs to spend about $2 trillion over the next two decades just to refurbish the existing grid," new American Electric Power CEO Nick Akins said last month at his company's annual shareholders meeting in Tulsa." (Don't pay any attention to the rest of that article, it's chock full of propaganda I just don't feel like dealing with right now.)

Off-shore wind makes both financial and engineering sense for east coast load centers.

Behold!  It's Donny, FirstEnergy's "regular guy."  He looks almost as stiff as his brand new FirstEnergy embroidered shirt, doesn't he?  Where's the ball cap and t-shirt?  Silly me!  I forgot Donny is the one who sounds like he's reading from a report during FE's earnings call, and he can't act either.  What a waste of a goofy looking face!  Of course, who can blame him, being yanked from his office, dressed in a special shirt, and shoved in front of a camera.  FE should have rounded up the boys and taken Donny out to the bowling alley, loaded him up with beer, and then filmed it there.  If they had, they would have already answered AEP's new "jobs" commercial featuring regular folks who also work for AEP.  (heh, lobbyists!  good one, AEP!)

AEP scores a big casting win in their newest "balanced" ad.  The fat guy in the suit looks just like the FE guys I saw!  Now that's realism!

But it's not just about the commercials any longer.  AEP also puts FirstEnergy's confused "fact sheets" to shame.  FE made it way too complicated.  Sometimes it's very easy to get too far off into the weeds when trying to convince people with facts.  FE needs to tighten up here because it's too complicated for regular folks.  AEP's new fact sheets are perfectly understandable to anyone, whether they're true or not.

Which company is right here?  Who cares?  AEP definitely has the better public relations firm in this tit for tat contest.

Just how deep does the scheme to protect incumbent generators at PJM go?  You might be surprised!

PJM's "independent" Market Monitor filed a complaint at FERC earlier this month, seeking to make a certain state-sponsored generation project increase the price bid into PJM's RPM auction, or alternatively, allow all other bidders to re-work their prices.  The MM also asked that FERC delay the auction until this matter is settled.

At issue here are programs in the states of Maryland and New Jersey that have been put in place to encourage the development of new in-state generation, instead of continuing to rely on imported electricity (mostly produced from burning coal) from existing western generators which will be transported to the states via new high-voltage transmission lines hundreds of miles long.

PJM has been championing incumbent generators' strangle-hold over eastern markets at FERC, and recently had the rules changed as a means to prevent New Jersey and Maryland's generation projects from clearing the auction, which is a requirement for moving forward.

When "Project X" (okay, why are we pretending here?  we all know it's Maryland's project) made a bid that was low enough to clear, the IMM filed a complaint accusing them of not following the rules.  The IMM says:

"Selective use of favorable modeling assumptions also creates the potential to distort market outcomes because it can make a more expensive project appear to be cheaper. The result could be that the more expensive project clears in the RPM auction while the less expensive project does not clear. This would be a non-competitive outcome."

Let's talk about "fair" and "competitive," shall we, IMM?  If your incumbent generator PIGS were required to include the $6B cost of new transmission projects to transport their "cheap" electricity to eastern markets in the prices they bid into your auction, what would the true price of their electricity be?  If we're going to be truly fair, that's the only way to do it.

Instead, in PJM's unfair and uncompetitive electricity markets, the true cost of western generation is subsidized by all consumers in PJM via PJM's region-wide postage stamp cost allocation for transmission projects 500kV or over.  This enables PJM's incumbent generators to make artificially low bids into the RPM because new transmission necessary to get their generation to load on the east coast will be subsidized by ratepayers far from Maryland or New Jersey, with the beneficiaries of these transmission projects paying only a fraction of the cost of supplying them with electricity.  When new generation is built in Maryland or New Jersey, the entire cost of the project will be borne by that state's ratepayers.  When new transmission is built to import incumbent generators' electricity into the state, Maryland and New Jersey only pay a fraction of the cost.  This is not "fair" or "competitive."

PJM's ball of twine just keeps unraveling.  Now they've even screwed up their own auction with their continual kowtowing to the financial wants of certain incumbent utility conglomerates. What's next?  Are we going to see the incumbent generators' front group spring into action?  Spare us the posturing.  We aren't buying it.

Grab your tin foil hat and crank up the generator, Armageddon is nearly upon us!  In a complaint filed yesterday, Primary Power LLC asks FERC to restore ownership of its SVC projects to Primary Power no later than July 13, and issue an immediate order preventing FirstEnergy and Dominion from beginning construction of the two projects that they stole from Primary Power by exerting their incumbent power over the PJM cartel.

"Primary Power respectfully submits that the actions of PJM and the Incumbent Transmission Owners addressed in this Complaint raise grave concerns for the future of new competitive transmission development in the United States. This is essentially the “Armageddon scenario” in which PJM and the Incumbent Transmission Owners have acted in a concerted, and unduly discriminatory, manner to prevent a potential new entrant from building new cost-of-service transmission facilities in PJM, despite the fact that there is a Commission order directly on point telling PJM to designate Primary Power if any of the projects that it sponsored were included in the RTEP. If Primary Power cannot be designated to build its SVCs in this well documented proceeding that already is the subject of a Commission order, then who can? If PJM’s actions are allowed to stand, it will provide a roadmap for incumbent transmission owners across the United States on how to block entry by competitors, and it will send a chilling signal to independent transmission developers and investors that the Commission is not willing to intervene to enforce its open access requirements. This Complaint thus represents a critical test case for the Commission’s commitment to opening up the market for transmission development to competition, which, as the Commission found in Order No. 1000, can result in more efficient and cost-effective solutions for ratepayers."

At issue here are two projects that will supply reactive power to the grid, without the building of new transmission lines.  Primary Power spent 5 years and $5M developing these projects and shared them with PJM and its "stakeholders" during the approval process.  PJM initially approved the projects and assigned them to their sponsor, Primary Power, for construction.  However, after all the work of design, development and approval was completed, PJM incumbent bullies and PIGS Dominion and FirstEnergy decided they wanted to build the projects instead.  So, what did PJM do?  They reassigned the projects to their favored incumbents, of course, and told Primary Power to go suck wind. 

I'm sure this doesn't come as any surprise to PATH opponents, who have had a front row seat to PJM's favoritism of its incumbent bullies  for the past 4 years.  PJM's bald favoritism of certain companies flies in the face of even the most basic logic, and it's way past time for FERC to rein them in.  Primary Power is but one more example of PJM's collusion with a handful of power conglomerates to increase their profits with the building of unnecessary infrastructure, and to prevent competitive markets.  Primary Power gets quite dramatic in their filing, however it's all true and well deserved.  The continued skewing of PJM's markets to favor certain incumbents keeps the prices consumers pay for electricity high and fails to provide the consumers with state-of-the-art, least cost options for electric service.  If PJM's arbitrary and capricious decision in Primary Power is allowed to stand, Primary Power will go belly-up and it's going to be a cold day in hell before another new company proposes an innovative (or cheaper) solution to identified transmission needs.  The incumbents will have exactly what they desire, a lock on all new transmission projects, similar to their current stranglehold on the development of new generation.  This does not serve electric consumers!

It's time to clean house at PJM.  The dirty dealing could be peeled off in layers at this point, and it's starting to stink up the place.  Once they've cleaned all the stink out of PJM, FERC should prohibit lobbying of any kind at PJM in order to prevent a recurrence.  Lobbying has no place in a competitive electric market that benefits consumers.  And while FERC is at it, they need to prohibit lobbying in their own house as well.  Regulation should never be subject to lobbying as lobbying does nothing to further just and reasonable, nondiscriminatory rates.

Remember The Shell Answer Man?  Whatever happened to him anyhow?  Never fear, friends, now we have Pablo, The AEP Answer Man!  Pablo and his hideous, neon green shirt want to be your best friend and patiently explain everything to you so that you, too, will want to keep AEP sustainable so that they will still be there later to compete with the FirstEnergy bullies when they jack up rates after stealing all AEP's customers.

Go ahead, ask Pablo a question!  You know you wanna!

Perhaps you could ask a question about shopping, like "Connie E." did:

"Q. I’ve seen ads claiming AEP is trying to prevent us from shopping for lower rates. Is this true?
A. That is absolutely false. Customers are able to shop now. In addition, AEP Ohio has proposed a plan being considered by the Public Utilities Commission of Ohio that continues the opportunities for consumers to shop for lower rates."

Gosh, I guess it's really not about shopping after all.

AEP jumps ahead of FirstEnergy again in the Ohio electric consumer leapfrog battle by pumping out the plain folks propaganda with a little CEO face time.  Pablo is just a regular guy, isn't he... stumbling over his little speech while posing in front of his corporate ego wall.  Best of all, you're sure not to lose him on the golf course dressed like that!  Golf course?  But, of course!  You don't think you'd find a guy who makes six figures slumming at the bowling alley, do you?

Fortunately for FirstEnergy, this could be a slam dunk for them, if they'd just get in the game!  Pablo's FirstEnergy counterpart looks so goofy, he's a natural for a plain folks commercial.  Can't you just see Donny in a greasy ball cap and torn Simpsons t-shirt, cracking a smile while bent over the beer display at Wal-Mart and asking you to pull his finger?  In fact... he even looks like Homer Simpson, doesn't he?  D'oh, FirstEnergy!  Another missed opportunity!  Would you please start paying attention here?  You're losing!

Dominion contractors showed up on Old Cave Road in Jefferson County today to begin work on a portion of the Mt. Storm - Doubs rebuild project, and immediately got down to business annoying residents and tearing up Willingham Knolls Park.

This is what that stretch of right-of-way looked like before Dominion showed up.

We'll be watching to see how it changes.  A conclusion that shows Dominion's respect for the landowners wouldn't see much change at all.

However, this is what happened when Dominion's contractors began cutting an access road:

Dominion's disrespectful contractors also made themselves at home by parking their unmarked vehicles in the entrance to the subdivision across the street from the work zone and blocking the road and residents' access to mailboxes and a school bus stop.  How rude!  If Dominion is working on Willingham Knolls Park property, there's a perfectly good gravel parking lot at the park just down the hill and a short walk from the work site.  A little exercise would do these fellas good.

Not quite the auspicious beginning you promised us, Dominion.  Please show a little more respect for the residents to foster a mutually beneficial working environment.  We'll be watching...

*cue the circus music*  FirstEnergy has finally lobbed a ball at AEP in the corporate dodge ball game going on in the state of Ohio.  Unfortunately, FirstEnergy throws like a flabby, middle-aged nerd, but hey, at least they finally showed up for the game!

FirstEnergy finally abandoned their loser ad campaign and has upped their budget to create a real commercial that answers one of AEP's very creative commercials, the "dodge ball" commercial.

In FE's version of the game, AEP runs from the game and hides behind a bunch of little kids.  I give it a 5 on the scale of creativity, but you just can't quite dance to it.  I said creative, FE!  Isn't there one among you who's twisted just enough to be truly creative?  Keep trying, I know you can do it!

The only real humor to be found in the commercial is the actor FirstEnergy hired to portray themselves... young, good looking and athletic.  I'm sorry, but I've seen you guys before, and I didn't see anyone even close to that guy.  Character FAIL!

So, what are these companies fighting about anyhow?  I know you are all insanely curious.  Here's a simplistic explanation:  FirstEnergy is buying electricity AEP generates at bargain basement prices and then marking it up in order to resell it to AEP customers at lower prices than AEP charges.  AEP makes money by competing to sell electricity it generates, and FirstEnergy makes money by being the middleman and reselling it to you at a lower price.  What's at issue here is the amount AEP can charge for its electricity.  AEP wants to raise the price so that FirstEnergy can no longer make a big profit as the middle man.  This would effectively kill the current competition going on in AEP's Ohio service territory and stop AEP's customer migration to FirstEnergy and other competitive suppliers.  To further simplify, it's all about money.  Both companies are greedy shysters who are milking consumers for every dime they can.  Neither one is any better than the other.  You might as well toss a coin, or make your selection based on how hard their commercials make you laugh.  The company with the funniest commercial wins the customers!

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Parties had 30 days to file requests for rehearing on FERC's March 30 Order on Remand reaffirming that PJM's "Postage Stamp" rates for transmission lines 500kV or greater are just and reasonable.  Several parties filed requests, and I've just now managed to plow through them all.

The Illinois Commerce Commission is the winner for style.  In addition to pointing out the reasons why FERC's Order fails to meet the 7th Circuit's standard of showing benefit commensurate with costs, ICC adds so many zingers, it's like a treasure hunt.  "The Commission’s statement in this regard calls to mind the story of the fellow with one arm in the freezer and one arm in the oven who, on average, was quite  comfortable." or "In making that statement, the Commission shows mastery in the art of understatement."

ICC points out that the 500kV lines (TrAIL, PATH, MAPP and Susquehanna-Roseland -- the Project Mountaineer collection) were designed to alleviate reliability violations in eastern PJM (New Jersey, eastern Pennsylvania, eastern Maryland, Delaware, Northern Virginia) caused by this area's demand for imported electricity.  In addition, these projects were touted to reduce economic congestion and cause a drop in electricity prices in eastern PJM.  They also get pretty tweaked about those PJM "positive externalities" that the Commission used to attempt to show benefit to western PJM flowing from their membership in PJM.  ICC pointed out that the PJM report cited was not properly brought into evidence and that the report is highly disputed.  It's apparently just some PJM fluff they issue every year to justify their miserable existence.  At any rate, the "benefits" of PJM membership flow from PJM itself, and not from the 500kV lines.  In other words, western PJM would receive those "benefits" whether the lines were constructed or not.  They also took issue with the Commission's redefinition of what is east and what is west by including West Virginia in western PJM in order to show that PATH and TrAIL were providing some benefit to western PJM.  West Virginia was never the intended "beneficiary" of those transmission projects, just the victim.

"Clearly, the Commission’s re-definition of “western PJM” is nonsense and the purpose of that re-definition is to obscure and mislead regarding the extent that true Midwestern utilities benefit from the 500 kV and above transmission lines planned and built in eastern PJM.  Notably, using the Commission’s creative new definition of western PJM, the Commission designates significant 500 KV projects such as TrAIL and PATH as being at least partially located in “western PJM”, particularly noting the State of West Virginia as being in western PJM.  The Commission states that TrAIL and PATH, which are both major 500 kV and above projects, “were approved to be located in western PJM, and to address reliability violations in western PJM.” Once again, the Commission particularly cites the state of West Virginia as being in western PJM."

Also be sure to read Bill's post about the history behind postage stamp rates and his take on the ICC filing.

Dayton Power & Light's filing has to be the substance winner.  Although it's 150 pages, their filing provides documentation of all points raised, ad nauseam!  If you like references and statistics, this is a great read!  DPL's filing starts out with this great quote that they attribute to Everett Dirksen, Senator from Illinois"

"A billion here and a billion there and pretty soon you are talking about real money."

In addition to fleshing out and backing up ICC's points, DPL spends ink pointing out the true beneficiaries of Project Mountaineer's transmission projects.

"Even the two transmission lines that start in western Pennsylvania or central West Virginia to points east were not proposed by PJM to resolve any reliability problems within West Virginia or western Pennsylvania."

They also provide granularity* on the congestion costs argument.  When construction of transmission lines cause lower prices on the east coast, they also cause the equal and opposite reaction of causing higher prices in the west, where the transmission line originates.  This is undisputed fact.  Here are the benefits received by eastern PJM from Project Mountaineer:  increased reliability, lower prices, and only a fraction of the costs of the transmission project.  In addition, DPL turns one of FERC's arguments about "benefits" received by western PJM on its head.  The supposed "benefits" to the western "generation" area all flow to the utilities owning generation and transmission, and not to the ratepayers!

DPL has great statistics, for instance: 

"...the TrAIL line alone (already built and in-service) provides Pepco (D.C. and Maryland) and BG&E (Maryland) annual benefits in the form of lower energy costs in excess of $100 million. PSEG in New Jersey receives an estimated $99 million annually, and the big winner is Dominion Resources in Virginia with annual LMP savings of $835 million. The PATH line (currently delayed) provides the same pattern of benefits, again with Dominion Resources, Pepco and BG&E receiving more than $100 million annually in a reduced LMP benefit."

Here's a breakdown of an analysis of the cost of the Susquehanna-Roseland Project (and the exhibits do a similar job on all 4 Project Mountaineer projects):

"PJM analyses identified numerous overloads on critical 230 kV circuits across Eastern Pennsylvania and Northern New Jersey and the proposed fix to the problem was the $1.161 billion Susquehanna-Roseland new 500 kV transmission line to be built from eastern Pennsylvania into New Jersey. Significantly, application of the DFAX methodology would result in virtually all
the costs of the line being allocated to New Jersey  utilities and eastern Pennsylvania utilities operating directly across the river from New Jersey. Eight  variations of a DFAX analysis were presented in this proceeding for this project using different time periods or other different assumptions, including multiple scenarios submitted by a witness opposed to the DFAX method. Under each analysis, 92% to 99% of the load on the facility that was overloaded and created the reliability problem came from the same eastern utilities that then would be assigned between 92% and 99% of the costs of the solution. 

Consider again the $1.161 billion Susquehanna-Roseland new transmission line. Socialization would result in the eastern Pennsylvania and northern New Jersey zones paying only 23% of the costs, while the rest of PJM would assume 77% of the costs."

And, just one of many comparisons in the data:

"Under socialization, PSEG‘s shareholders and/or customers pay only $12.6 million of the annual costs, but enjoy $31 million per year in energy savings..."

DPL also points out another eastern PJM benefit -- incentive rates of return (which FERC granted in part because of congestion cost reductions) that flow only to the utilities constructing these transmission projects.

The Captain Obvious award still sits on a shelf, however, because nobody pointed out how socialization of costs region-wide skews PJM's markets in favor of incumbent generators.  When an eastern PJM state, say for instance New Jersey, has reliability issues that need to be solved, the violations can be solved any of three ways:  increased transmission, increased generation near load, or load reduction.  Load reduction is the cheapest option, but is never PJM's choice to solve violations.  Increased generation will be paid for only by local load that benefits from it, making it the most expensive option.  However, new transmission lines will be paid for by the entire region, making local New Jersey costs for transmission less than building new generation.  This skewing of PJM markets in favor of transmission, as the "cheaper" solution, favors incumbent generators, and as we all now know, PIG rules!

DPL also uses a creative argument I know all you readers of this blog and TPL have heard a thousand times before.  Referencing the recommendations in the official report on the 2003 blackout, DPL points out:

"Not one of those 46 recommendations was to build new high-voltage transmission lines. The Joint Task Force
Report did not conclude, for example, that more high voltage lines should be constructed in Ohio, Michigan, Ontario or New York or eastern PJM (or within any PJM zone) to prevent future cascades."

PJM's (and their "pigs") plan to build new transmission lines to transport 5,000 MW of coal-fired electric power to the east coast provides no benefits to the state of West Virginia and in fact causes higher electricity prices, additional destruction of the environment and a higher than warranted share of the cost of the transmission projects.  Any "benefits" FERC proffered flow only to the utilities, such as increased generation, increased sale of power, transmission line return on equity incentives and ownership of the transmission lines.  No benefits derived from the building of new transmission lines are enjoyed by West Virginia's electric consumers!

Now the ball is back in FERC's court.  Will they man up and reconsider what was a bad decision, or would they rather be embarrassed before the 7th Circuit again?  Keep watching this one!


*stupid business buzzword I despise

Don't you just love the smell of audits in the morning?  I happened to catch this article on Friday.  It seems that FERC (Federal Energy Regulatory Commission),  performed an audit of NERC (North American Electric Reliability Corporation) over several months last year.  NERC didn't like FERC audit staff's findings and now they're having a big, ol' public tantrum about it and whining to the FERC Commissioners.  NERC thinks they are somehow "special" and should have been permitted to "work toward resolution" (read "sweep under the rug if we promise not to do it again") instead of being held accountable for their actions.  Because NERC decided to have a tantrum and contest the audit findings, the whole thing got made public on Friday.  Not too smart, NERC!

NERC describes its mission as: "to ensure the reliability of the North American bulk power system. NERC is the electric reliability organization (ERO) certified by the Federal Energy Regulatory Commission to establish and enforce reliability standards for the bulk-power system. NERC develops and enforces reliability standards; assesses adequacy annually via a 10-year forecast, and summer and winter forecasts; monitors the bulk power system; and educates, trains and certifies industry personnel."

NERC's statutory authority, once designated the ERO by FERC, comes from Section 215 of the Federal Power Act, and they may "allocate equitably reasonable dues, fees, and other charges among end users for all activities under this section;"  I didn't see a definition for "end users" in the FPA, but I will assume "end users" are electric consumers/ratepayers.

So, what did the audit turn up?  Lots of interesting stuff, including a couple of "Holiday Galas" NERC held in 2010 & 2011 that cost us ratepayers $74,748 and $109,474, respectively.  The totals included expenses such as travel, lodging, car rentals, "gifts," food and beverage, entertainment and "miscellaneous."  NERC prefers that FERC audit staff refer to them as "year-end events, or year-end employee dinners and meetings" (pg. 63), although the term "Holiday Gala" came from internal NERC documents.  NERC advertised the parties as "Holiday Galas" in-house, but when the auditors showed up they called them "year-end events."  You can download a copy of FERC's audit report here.  The Holiday Gala stuff starts on page 52 of the report.

So, while senior citizens on a fixed income and single parents are struggling to pay their monthly electric bills, NERC is spending nearly $185,000 on holiday parties.  Nice.  NERC is statutorily permitted to spend funds on activities necessary for its duties under Sec. 215.  Are Holiday Galas necessary to the reliability of the electric grid?  I wonder if there was no holiday party for NERC employees if the lights would have gone out?  Maybe we'll find out in 2012 :-)

NERC needs to get off its "special" pedestal and learn how to behave during an audit.  Don't argue with the auditors, you're not going to win.  Auditors are like The Child Catcher from Chitty Chitty Bang Bang, "There are improper expenses around here somewhere... I can smell them!"  If there's one transaction that isn't quite right in a computer printout 3 inches thick, an auditor will zero in on that particular transaction and start asking for documents, guaranteed.  Quit your whining, NERC, and clean up your act!

And, from an electric ratepayer's perspective... Thank you, FERC audit staff!  We appreciate you, even if NERC doesn't.

Update:  Check out NERC's latest ridiculous hissy fit here.