Only 2 days left!

Twice a year, PATH is required to hold an "Open Meeting" to discuss their transmission revenue requirements with "interested parties."  If you're interested in grilling PATH about how they're spending your money, or simply listening in as others do, then you're an "interested party."

PATH used to have real meetings at their outside counsel's DC office, but then they got all shy and punted on the live meetings in favor of phone "meetings."

Just because PATH is a party-pooper doesn't mean we are!  We're still having breakfast parties twice a year, only instead of some stuffy legal conference room where the sound system doesn't work, we're holding the meeting on my patio (weather permitting) and serving donuts and mimosas.  We'll connect to the "meeting" via phone and you're all invited to listen in and ask questions.

However, you need to "RSVP" for the meeting with PATH's counsel so you will be allowed to participate.  Seating is limited (over the phone?) so reserve your seat today!  The deadline to RSVP is Thursday, October 13.  Details of what you need to do can be found here.

The "Open Meeting" will be held on October 19 at 10:00 a.m. and will last about an hour (or until we run out of questions, so bring your questions!)  Once you have sent in your RSVP, you will receive meeting materials and details for hooking into the phone meeting via email the afternoon before the meeting.  Just in case PATH sends you a toll call number (in order to discourage your attendance, since you'll have to pay for the call), check back here before the meeting to see if we've found an 800 number to use instead.

If you're coming to the party at my house, let me know at least a day in advance so I can have enough food and drink for everyone.  If you can't make the party, you can still listen in to the call from where ever you are, but you need to RSVP with PATH to do so.

I promise you the "meeting" will be entertaining!

The "Rapid Response Transmission Team's" pilot project to "fast track" seven transmission projects has been written about ad nauseam.  Unfortunately, most of the reasons given by various government officials for this "fast tracking" it is pure fabrication.  Let's take a look at some of the claims being made:

1. Will create 10,000 direct and indirect jobs.  Will put America "back to work."  Have you noticed that there's nothing to back up this claim?  Ten thousand jobs on 7 transmission line projects is an absurd number!  They're probably counting the same workers on different projects as different "jobs" in order to inflate this figure, if they are counting anything at all.  For all we know, the administration pulled this number out of their... hat.  As we have seen here in West Virginia during the construction of the TrAIL transmission line and the planning of the PATH transmission line, all the temporary jobs associated with a new transmission project go to out-of-state companies who import workers for the duration of whatever specialized task related to construction is being performed.  The transmission project owners hire a general contractor (for TrAIL & PATH it was Kenny Construction, an Illinois company).  Land clearing and road construction (Supreme Industries, Connecticut), wires (PAR Electrical Contractors, Texas), land acquisition (Contract Land Services, Texas), engineering and environmental (Burns & McDonnell, Missouri; Louis Berger Group, New Jersey) and every other aspect of the project will be bid on by and awarded to specialized, out-of-state companies who do this type of work on location as their business.  When a helicopter crashed while stringing wire for the TrAIL project, it turned out to be owned by an Oregon company, and the workers on board were from Georgia, Kentucky and Indiana.  All these professionals already have jobs -- their job is to construct a certain specialized portion of transmission lines on temporary location.  A transmission company will not be hiring local labor or putting anyone "back to work."
2. New transmission projects will "upgrade the grid."  New transmission lines won't do a thing about existing, 40 year old transmission lines.  There are no plans to remove or take current lines permanently out of service.  New transmission projects are simply an addition that does nothing to "upgrade" our current grid.  The new lines are high capacity projects intended to trade electricity over long distances.  What we should be doing to "upgrade the grid" is rebuilding existing transmission lines completely within existing rights-of-way to increase their capacity and update their technology.
   
3. Will give consumers "more energy choices."  You're not going to be getting a "choice" of where your electricity comes from.  Electrons can't be categorized by source -- whether wind, solar, coal, gas or hydro generates your electricity, it's all mixed up in transmission lines.  While you may be able to choose your own electric provider, you will never be able to choose your transmission company or energy source.  Your local electric provider buys power off the grid for the cheapest price it can, no matter who or where it comes from.
4. Will transport renewable energy.  Not necessarily.  The Susquahanna Roseland project, one of the 7 "pilot" projects, is part of PJM's Project Mountaineer, a scheme to transport an additional 5000 MW of coal-fired electricity from the Ohio Valley to the East Coast.  Check out this post on The Power Line to learn how some of the other projects are really intended to increase reliance on coal-fired electricity.  See also Piedmont Environmental Council's coal dressed as wind map.
   
5. Will accommodate the growing number of electric vehicles on America’s roads.  A transmission line by itself does not provide electricity for cars or anything else.  A power generating source does.  Locate more of them in close proximity to the "growing number of electric cars" and you're in business.  Transmission lines are NOT needed to power electric cars.  In fact, some are thinking about using the batteries from plugged in electric cars to provide additional power to the grid at times of peak demand.  Seems that the grid needs the cars more than the cars need the grid.
   
6. Will help avoid blackouts.  This has to be the most ridiculous "reason" to "fast track" transmission projects.  Additional wire in the air does not make a system more reliable.  Out-of-control grid additions will actually make it LESS reliable and prone to blackouts as control of the grid gets more complicated and harder to manage.  The most reliable "grid" is one where generation is located as close as possible to use.  We don't need more transmission lines to avoid blackouts, we need more generation of power on a small, localized scale close to where it will be consumed -- distributed generation!
   
7. Will enable restoration of power more quickly when outages occur.  No, it won't.  An outage is an outage -- until it's repaired, it will exist.  Most of the outages experienced by consumers are due to faults in the DISTRIBUTION system, not the TRANSMISSION system.  Distribution lines bring power from a substation in your area to your home.  Transmission lines transport electricity from a generating source to a substation.  If your power is out, another transmission line isn't going to get it back on any faster, unless the distribution system that brings it to your house or business is repaired first.
   
8. Will reduce the need for new power plants.  As stated above, a transmission line without a generation source is just a wire.  If we need more electricity, it has to be produced by new power plants.  To really trip up the idiots parroting this myth, ask them how these transmission lines will increase renewable power if no new wind or solar farms (power plants) are built.  Then have fun debating further about which came first, the chicken or the egg.
9. Getting a new transmission project permitted takes a decade or longer and must be "fast tracked."  Allegheny Energy's TrAIL project went from drawing board to reality in 5 years.  Other recent projects have been built in less than 10 years.  A transmission project that drags on for 10 years or more is rare.  Most projects that can't get approved are cancelled or withdrawn voluntarily by their owners or regional transmission organizations when the need for them cannot be demonstrated. 
   
10. Will serve as important links across our country to increase our power grid’s capacity and reliability.  Who says we need to increase our grid's capacity from coast to coast?  The industry, who wants to turn electricity into a commodity to be traded over great distances in order to make a hefty profit.  They're not doing it out of the goodness of their corporate personhood hearts in order to "give you more choices" and "make electricity cheaper."  Gimme an E, gimme an N, gimme an R, gimme an O, gimme an N.  What does that spell?  Enron!  Enron!  Rah!  Rah!  Rah!  In addition, these "important links across our country" will cost hundreds of billions of dollars to construct that will be paid for by electric consumers, raising your electric rates.
    
11. Will move our nation toward energy independence.  "Energy independence?"  What is that?  The vast majority of electricity in this country is produced from coal and natural gas, both domestically plentiful.  In order to be truly "energy independent," install your own solar or wind system and stop feeding at the corporate energy trough of centralized power generation and expensive transmission lines.  Those "economies of scale" are getting smaller and smaller as the cost of new transmission lines to transport centralized generation get added to their cost, while the price of installing your own solar generating system gets cheaper and cheaper.
    
12. Will promote energy savings.  No, new transmission projects will make your cost of electricity go up.  Someone has to pay for the new transmission projects (and profits to their developers) and that someone is Y-O-U!  Another way to make energy cheaper is to locate new generation near load.  Transmission lines will not "promote energy savings."
13. Will increase energy efficiency.  Not in your wildest dreams!  There's nothing "efficient" about transporting electricity hundreds or thousands of miles.  Transmission lines "leak" electricity.  The longer the distance, the more electricity is lost and wasted.  Go hold a fluorescent light tube underneath a transmission line at night, if you don't believe me.
    
14. Will "speed up" federal environmental reviews.  Let me introduce you to NEPA, the National Environmental Policy Act.  It's a LAW.  The only way to speed up a law is to circumvent it.  Is the Obama administration suggesting that the federal government break the law?  Seems that way if the rumors that the outcome of the NEPA review of the Susquehanna Roseland project has already been "fixed" by agency heads in collusion with industry lobbyists.

I know there are more, so I'm asking you to add to the list.  A few days ago, I found a long article with vapid quotes from all the federal agency heads who don't know diddley squat about the electric grid that had me snorting with laughter.  Unfortunately, being away from home for 5 days with only a blackberry and a borrowed, crappy microsoft pc (not recommended!) caused me to lose the source of my mirth.  The myths are out there...

It's been a year in coming, but PATH's ROE Settlement was finally made public on Friday.  No more 14.3% ROE!

Here's a summary of what's in the Settlement (warning, gigantic file).

1. PATH's base ROE will change from 12.3% to 10.4%, effective January 1, 2011.  That was the only part of the ROE that was subject to change as per FERC order.  The 200 incentive points they were awarded back in 2008 (50 pts. for membership in PJM and 150 pts. for the "risks and challenges" of the project) will not change.  When the existing 200 pt. incentive ROE adders are added to the new base ROE, this brings PATH's ROE down to 12.4%.
2. PATH will pay the PJM ratepayers a lump sum refund of $2,741,000.55, which includes interest, on the difference between the 14.3% that has been collected since March 2008 and the new 12.4% ROE that was effective January 1, 2011.  This refund will be made in the next billing cycle after approval of the settlement by FERC.
3. Within 7 days of approval by FERC, PATH will file a Re-Revised 2011 Projected Transmission Revenue Requirement, which will include a refund of the difference between the 14.3% ROE they have collected thus far this year and the new 12.4% ROE.
4. Within 14 days of approval by FERC, PATH will file a Revised 2012 Projected Transmission Revenue Requirement reflecting the new, lower ROE.
5. PATH will also file a revision to their 2010 Actual Transmission Revenue Requirement within 14 days of approval.  The settlement states that this will change the refund of over recovered revenue to ratepayers from $4,899,780.42 to $4,597,741.90.  I'm not sure why PATH is now keeping $300K of the refund they owed to us, but the filing should tell us eventually.
6. None of the settling parties can request a change to PATH's base ROE or incentive adders for 4 years.  However, in the event PATH is cancelled, this will not affect the rights of any party to argue what ROE (if any) should be applied to abandoned plant costs.

PATH got taken to the cleaners in this settlement!  Hats off to the other power companies who engineered this settlement while "our" state consumer advocates sat on their hands instead of protecting our interests.  PATH should have been paying attention to the enemies they were making when they insisted on keeping all the gold in their own pot way back when.

PATH's original award of incentives was completely ridiculous, and everyone's been aware of that for over three years.  PATH's 14.3% ROE was way outside of any other project's ROE.  So, let's see how PATH's ROE stacks up now when compared with its three sister Project Mountaineer projects, who were also awarded incentives in 2007 & 2008:

• Susquehanna-Roseland            12.93%
• MAPP                                      12.8%
• TrAIL                                       12.7%
• PATH                                       12.4%

How does it feel to go from the top of the heap to the bottom of the pile, PATH?

Look at it this way -- PATH's ROE fell by 1.9%, which nearly equals their 2% incentive adders and pretty much negates them in their entirety.  PATH isn't as profitable as it once was, so why doesn't AEP & FirstEnergy just take their ball and go home?   We all know this project is never going to happen.  However, until the project is officially "cancelled," they will continue to collect this ROE on the amount they have invested in the project.  The difference between ROEs is going to lower their yearly return (profit) by about a million bucks.

Here's how it works (which I was trying to explain in vain in Bill's comments over the weekend):

The amount of money PATH invests in project assets will be returned to them through depreciation over the life of the transmission line.  PATH has invested $138,773,015 in the project through the end of 2012.  In exchange for investing their capital in the transmission project, PATH will earn a return (profit or interest) on their money yearly.  The amount they earn each year is determined in their Formula Rate template and based on the incentives they were granted back in 2008.  PATH was granted a hypothetical capital structure of 50% equity and 50% debt.  This means that until the project is actually completed, no one knows how much of the cost will be equity (PATH's money) and how much they will have to borrow to finance it (debt).  FERC has set the percentages at 50-50.  This means every year PATH will now earn 12.4% on the hypothetical equity half of the amount in the rate base, and a much lower percentage on the half that is hypothetically debt, or borrowed money.  The debt percentages are 6.64% for the PATH-WV (AEP) half of the project and 6.76% for the PATH-Allegheny (FE) half of the project.  As shown on this redlined template sheet from PATH's settlement, the two different percentages are averaged and the resulting percentage is applied to the rate base and becomes PATH's yearly return, or profit, which is recovered along with all other yearly expenses (such as marketing, administrative costs, a share of PATH's parent company expenses, a portion of their start-up costs incurred prior to incentives being granted in 2008, taxes and depreciation) every year.  As a result of the settlement, PATH's yearly profit margin has dropped from 10.47% on PATH-WV's half and 10.53% on PATH-Allegheny's half to 9.52% for PATH-WV and 9.58% for PATH-Allegheny.

If you actually look at the new templates submitted as an attachment to the settlement, you will notice that PATH neglected to change these numbers in the template, however, mistakes like that seem to be par for the course for PATH and its team of crack accountants.

What some of us are wondering now is if the filing of another revised PTRR for 2011 and a revised ATRR for 2010 will extend the discovery period currently underway on previous filings.  Since PATH's Formula Rate Implementation Protocols sets out a 150 day discovery period for interested parties to request information, and another 30 days to file a Challenge, a whole bunch of new filings near or after the closing of discovery on the original filings leaves no time for interested parties to avail themselves of the procedures outlined in the protocols.  As we've found out over the past couple of years, when the protocols are put into practice they are quite inadequate as written, aren't they?  No one ever envisioned the sticky situations PATH has gotten itself into in the past couple of years, apparently.  Planning for the unexpected should have been a "best practice" when planning an unneeded transmission project.

Any questions?  Or is it still about as clear as mud?

The Powerline has been doing a fine job of analyzing the preposterous "RRTT" scheme announced by the seemingly witless Obama administration yesterday.  The industry-driven Really Ridiculous Tendentious Team smacks of political and governmental malfeasance at the hands of a greedy and arrogant industry.

If the Obama administration had bothered to research any of the propaganda they've been spreading, they would have quickly realized that they're being taken for a ride by a frustrated and dying industry that will stoop to new depths of depravity in order to sink their greedy claws into the American consumer one final time in an attempt to maintain their obsolete business model.

The new transmission line projects selected for the "pilot project" will not make electricity cheaper or more reliable.  The billions of dollars spent on these projects will be recovered from electric consumers, along with "incentive" rates of return of 12% or more, providing their energy conglomerate owners with a steady source of income for decades at a time when demand for electricity is decreasing due to increased efficiency and demand management.  Additional long distance transmission lines will be connected with existing, unmaintained, technologically obsolete, and decrepit transmission infrastructure.  Trading electric power over hundreds of miles as a commodity will make our grid subject to increased risk of massive failure.  The most reliable power source is located as close as possible to where it is used.

The contention that these transmission projects will create "thousands" of jobs is completely disingenuous.  Building high voltage transmission is a highly skilled and technical endeavor undertaken by only a handful of experienced general contractors.  They won't be hiring local workers, but instead subcontracting with other specialized companies who bring their own employees and whose business is following these projects from place to place.  The only "jobs" that will be created would be a by-product of the imported labor temporarily living in cheap motels and eating at your local McDonalds.  Bottom Line:  Temporary jobs for workers from other states whose employment future is already secure.  It's not going to do anything for the local unemployed who don't have experience building high voltage transmission lines.

A statement from PEER quoted today said:

"The Secretary and the Director have unofficially committed to the companies that the NPS will select Alternative 2, the alternative preferred by the companies but which is the most damaging to the resources and scenery of the parks.  In return, the companies have reportedly agreed to pay $60 million for land acquisition and administration inside and near the NRA."

Now the companies who stand to make a huge profit off the Susquehanna Roseland project are resorting to greasing the skids with financial inducements in an attempt to buy off the National Park Service in return for approving their unneeded and destructive project.  However, "the companies" aren't "paying $60 million for land acquisition."  The acquisition of land for the S-R project is a capital expense that will be recovered from electric consumers as part of the project, with 12.8% interest every year for PPL and PSEG, over the expected useful life of the project.  That's right... the power companies are attempting to buy off the NPS with YOUR money! 

PEER is the acronym for Public Employees for Environmental Responsibility.  Its members are public employees who cannot publicly speak out against corruption for fear of losing their jobs.  A document on PEER's site, written by someone "on the inside" claims:

 "PPL and PSE&G have, understandably, sought to gain approval from NPS officials of the power line route that the companies seek. Towards that end, company representatives and lobbyists have met repeatedly with Secretary Salazar, his deputies former Assistant Secretary Strickland, Deputy Secretary Hayes, NPS Director Jarvis and former Deputy Director Wenk. PEER is attempting to obtain a list of the meeting dates during 2009-11, which would be a first step toward establishing the degree of project proponent’s attempt to influence the decision-making process. There is nothing criminal or improper about meetings by themselves. However, what is suspect is the degree to which high level officials of the DOI and NPS have countermanded and overruled local park managers in manipulating the NEPA review process to reach the outcome demanded by PPL and PSE&G.

For at least three years, the NPS has been developing an environmental impact statement (EIS) to consider the PPL/PSE&G proposal, following the National Environmental Policy Act (NEPA) and NEPA rules, adopted by the Council on Environmental Quality. The draft EIS is expected to be announced for public comment before the end of 2011.

But in the last ninety days, under relentless pressure from the companies and their lobbyists, the Department has short-circuited the NEPA processes. NPS Director Jarvis has ordered that the draft EIS include at least one alternative (#2B) demanded by the companies that is untenable from a safety perspective. He also ordered that the draft NOT consider at least two other alternatives that were reasonable and would lessen impacts to the park’s scenery (#6 and 7). The reason behind these orders is that the companies do not want the NEPA process slowed down by consideration of the other alternatives.

More damaging is that the Secretary and the Director have reportedly unofficially committed to the companies that the NPS will select Alternative 2, the alternative demanded by the companies. It is one thing to select an alternative AFTER the conclusion of the NEPA process, but is something else to decide on the alternative BEFORE the process is even announced to the public for comment. Even worse than this procedural violation, the alternative the Secretary and Director have already decided upon, Alternative 2, is one of the worst for the resources and scenery of the parks. To be sure, they have exacted a price from the companies – a reported $60 million for land acquisition and administration inside and within the vicinity of the NRA in exchange for giving the companies the corridor they want.

Alternative 2 is among the worst of the alternatives insofar as impact on the scenery of the parks. Yet, the Interior Department decisions culminated in the late summer of 2011 with verbal assurances to adopt the companies’ alternative by Secretary Salazar and Director Jarvis themselves in a meeting with company officials this past summer.

Unfortunately and despite the clear mandates of the law, these top officials are paving a path so that the Roseland to Susquehanna Overland Transmission Project will impair the core values of Delaware Water Gap and the Appalachian Trail."

The NPS is also being pushed by their own internal throne of political skullduggery, under the influence of corporate lobbyists, to look the other way and approve the project.  Outrageous!

The Obama adminstration is so desperate to push their "jobs" agenda that they've now sold their soul to the Great American Corporate Satan.  Welcome to Hell, America!

The natives are getting restless!  In addition to Maryland and New Jersey going after PJM's jugular, the Attorneys General, Offices of Consumer Counsel, and Public Utilities Commissions of 6 New England states filed a formal complaint with FERC last Friday.

In their complaint, they allege that the Base ROE FERC set for all New England ISO transmission owners in 2007 is much too high.  The 11.14% ROE was based on a very different 2004 - 2006 pre-recession market.  The complainants provide expert testimony whereby a more reasonable 9.2% is arrived at through an updated DCF analysis.  This Base ROE is the rate of return (or interest) transmission owners will earn on their investment in new transmission projects.  The Base ROE is exclusive of any transmission incentive adders, which were dealt with separately in a joint filing in the transmission NOI.  It wasn't lost on me that the same law firm, Spiegel McDiarmid, seems to be behind both filings.  As I mentioned last month when all the NOI comments began flooding in, pay particular attention to the comments Spiegel McDiarmid wrote for various clients.  They really get it.

Therefore, ratepayers in New England are being overcharged.  How much?

"The Complainants calculate that, assuming a forecasted 2011 investment base of $6.309 billion, New England electric consumers would be required to overcompensate New England Transmission Owners by $113 million annually under the current 11.14 percent Base ROE, compared to rates using the recommended ROE of 9.2 percent.  With New England’s Pool Transmission Facility investment base expected to increase to approximately $11.474 billion by 2015, that overpayment would increase to $206 million annually."

Here's a copy of the complaint.  For the sake of file size efficiency, I have stripped off the exhibits.  If your idea of fun is reading the supporting DCF analysis, get yourself on over to FERC's e-library and search for Docket EL11-66 and download the whole complaint.

If you've read and understand FERC's PATH decisions, you'll appreciate all the snide little references to PATH in the complaint, which were used to bolster the case.  PATH will live in on infamy for a long, long, long time in FERC's legal world.

While one could argue that this complaint is collateral damage resulting from FERC's Transmission Incentives NOI, it also represents another symptom of a bigger problem.  FERC's favored RTO model and its attendant bias toward the interests of a particular RTO's most powerful members, to the detriment of smaller industry players and consumers, is coming under increasing scrutiny.  Yet to be factored into the larger argument is the way FERC is stomping on state authority with its end run around Congress in an attempt to claim federal transmission siting authority.  Retaliatory complaints and other issues related to FERC's power grab haven't even begun yet.

This complaint is another concrete example that the transmission party is over for FERC, the RTOs and the industry players who have been making a bundle of cash at ratepayer expense.  There ARE cheaper, easier and smarter non-transmission alternatives that will ultimately be deployed, and that's where the energy policy train is now heading.  All aboard!!!

We've been reporting that New Jersey has grown tired of paying the high prices for electricity caused by PJM's failed reliability pricing model, which was supposed to attract new in-state generation.  Now Maryland has joined the parade, and on Thursday the Maryland PSC issued an order requesting proposals for new natural gas-fired generating capacity in Maryland's BG&E and Pepco zones by October 7.

The problem, according to the Maryland PSC:

"The Commission finds that Maryland continues to face the threat of insufficient new capacity, as PJM's capacity market construct, the Reliability Pricing Model ("RPM"), has been unsuccessful in attracting appreciable new generation to the State since its inception in 2007,  despite the fact that RPM has imposed prices in the Southwest MAAC zone that are approximately double that of the rest of the PJM region. The resultant risk to Maryland's long-term reliability is further heightened by several factors including (i) Maryland's status as a net importer of electricity, importing about 30 percent of its electric needs each year; (ii) the cancellation or postponement of certain large scale transmission projects coupled with the unpredictable transmission planning process that has become characteristic of PJM's Regional Transmission Expansion Plan; (iii) the potential that load forecasts could rise unexpectedly; (iv) the increased reliance the State has had to place on demand response to compensate for anemic electric capacity growth; (v) the risk that Environmental Protection Agency regulations and future State and federal emissions legislation could cause substantial retirements of base-load generation, especially coal plants, in the State and throughout the PJM region; (vi) the fact that Maryland relies heavily on coal plants for its electric generation needs; and (vii) the significant number of renewable resources anticipated to come on-line within PJM as a result of Maryland and other state Renewable Portfolio Standards, which, because of the variable nature of their output, will increase the need for regulation services from exiting and new conventional generation."

Maryland tries to be a bit "nicer" than New Jersey about it, but the message is clear.  Maryland is no longer content to be a victim of PJM's skewed markets which favor transmission solutions that provide huge profits to incumbent, coal-dependent, Ohio Valley mega-utilities such as AEP and FirstEnergy.

"Although the Commission recognizes and appreciates PJM’s role in planning regional transmission solutions, Maryland law directs this Commission to ensure an adequate and reliable supply of electricity to Maryland citizens. Where that supply may fall short, Public Utilities Article § 7-510(c)(6) authorizes this Commission to require investor- owned electric companies in Maryland to “construct, acquire or lease, and operate generating facilities in order to meet long-term anticipated demand in the State for standard offer service and other electricity supply.”

"Because market forces have not produced new generation in our region, the Commission may need to invoke its authority under §7-510(c)(6) if the record in this case demonstrates long-term risks of a projected capacity shortfall in an upcoming Delivery Year and that ordering the construction, acquisition, lease or operation of additional capacity resources would satisfy the long-term anticipated demand in Maryland for Standard Offer Service or other electricity supply."

PJM and the coal gluttons need to realize that the transmission party is over.  The two biggest victims of the scam are taking matters into their own hands and providing the solutions that PJM couldn't and wouldn't.

Bravo, Maryland and New Jersey!