Need more inspiration?  Here's what I just filed.

Comments of Keryn Newman
Docket No. AD25-7

“Breaking the internet” is a figurative phrase coined to describe an overwhelming surge in web traffic that impedes the operation of the World Wide Web. In an ironic twist, the internet is now breaking us, or more precisely our grid. The generators, transmission lines and distribution systems that make electricity available to everyone can no longer function in the same way they have for decades because they have been overwhelmed by new service requests from artificial intelligence data centers.

This enormous surge in electricity demand is breaking energy transition goals, bedrock regulatory principles, how we plan the energy system, and PJM’s capacity market, just to name a few. It is also breaking consumers ability to pay for the electricity they need. Soon it could even impede their ability to receive service at all as the amount of electric generation continues to shrink and the amount of electricity required by artificial intelligence skyrockets. We are sacrificing our real, human world for an artificial one that exists inside machines.

Our entire energy system and the way we regulate it needs to be torn down and rebuilt to efficiently and cost effectively serve today’s reality. Of course, that cannot happen. We no longer have the luxury of time. Elected officials and regulators have ignored the clear warning signs that were present for a number of years in favor of indulging in politicized industry fantasy. The fantasy is over. It’s now reality.

At FERC’s Resource Adequacy Technical Conference, Commissioner Christie asked whether states should require load-serving entities to acquire enough generation to cover their load forecasts in advance, requiring that they build or buy sufficient generation to meet load. That ought to be the first condition to be a member of a resource sharing organization such as PJM Interconnection, but it is not. PJM states such as Virginia are raking in the cash and benefits created by new data centers and leaning on other states to supply the power they need to enable those new data centers. As Commissioner Christie pointed out during the technical conference, when everybody leans on everybody else, everybody eventually falls down.

Importing more electricity from a neighboring state to serve increased demand is not smart energy policy. It’s a house of cards that cannot stand. PJM has become a group of “haves” and “have nots.” PJM’s State Import-Export Map shows a real time picture of which states are importing electricity, and which states are exporting it. West Virginia and Pennsylvania are consistent electricity exporters. Virginia, Maryland, Washington DC, Delaware and New Jersey are consistent energy importers. It is no longer an equitable sharing of resources among states. There are states that have energy, and states that have not. There are states that are givers, and states that are takers. Where’s the value of PJM membership for the states that are consistent exporters and perpetual givers? There is no value when one state is consistently taken advantage of over and over again. West Virginia has been treated as the east coast’s sacrifice zone, exploited by corporations to benefit wealthier states and treated like a dump that becomes the butt of rude jokes. But, perhaps artificial intelligence is also breaking West Virginia’s victimhood. This year West Virginia approved a new law called the Power Generation and Consumption Act, which allows companies seeking to build data centers in the state to create their own, independent energy grids to power them. West Virginia is getting into the data center game, trying to lure the industry here where energy is plentiful and data centers can bring their own generation and be part of the solution, not just the problem. It makes so much more economic and engineering sense to bring the load to the power than to try to bring the power to the load. West Virginia has found a way to accommodate data centers that does not create financial burden on other ratepayers, or land use burdens on private property.

Over the past several years, PJM Interconnection has planned and ordered more than $11B worth of new baseload transmission to import more and more electricity to Northern Virginia’s “data center alley” from West Virginia and Pennsylvania. These new transmission lines do not provide benefit to West Virginia and Pennsylvania. They are nothing more than gigantic extension cords for the purpose of exporting resources to “have not” taker states, mainly Virginia.

The resource adequacy crisis needs an immediate solution. Satisfying new data center demand can be done three different ways. The fastest and cheapest way is to restrict new data centers to locations with onsite or nearby available power. The second would be to build new generation near data center load, but that takes more time to permit and build and the price is steep. The last, most time consuming and expensive option would be to build transmission extension cords from existing generation to new data centers in other localities. Instead of selecting the fastest and cheapest option for the grid, PJM and the Commission have opted to rely on the slowest and most expensive way to power new data centers, building new transmission. This is not a viable solution and will take much too long to implement because new transmission is never a sure thing.

The impacts of Virginia’s skyrocketing data center load will be devastating to West Virginia, which is primarily bearing the brunt of the Commission’s broken regulatory system that no longer assists consumers in obtaining reliable, safe, secure, and economically efficient energy services at a reasonable cost through appropriate regulatory and market means, and collaborative efforts. West Virginians will pay more than $440M to construct and operate two new transmission extension cords for Virginia's data centers. The MidAtlantic Resiliency Link is a new 160-mile 500kV line that will take a new 200-foot wide right-of-way through private property. Valley Link is a new 261-mile 765kV transmission line that will take an additional 200 ft. wide right-of-way through private property. In Hampshire and Jefferson Counties, West Virginia, these two separate transmission lines will converge to create a transmission superhighway as wide as two football fields laid end to end. Hundreds of homes may be taken and demolished to make way for Virginia’s insatiable appetite for new data centers. There are no benefits for West Virginia, just impacts. Membership in PJM and the Commission’s transmission planning and cost allocation procedures no longer work to provide benefit to West Virginians. We’re being used to benefit other states.

The Commission has been constantly tinkering with interconnection queues, markets and other forms of regulation but has yet to find a solution to the growing problem of resource adequacy. There seems to be little the Commission can do in the face of rapidly increasing load from data centers. All its tools no longer work. What the system needs is more generation near data center load. Because Virginia refuses to build it, other states are being torn apart for new extension cords and consumers are quickly being priced out of being able to afford basic electric service. The system is broken.

Data centers are not just another electricity customer who must be accommodated using existing rules that share burden among all customers. The Commission should take a page from West Virginia’s book and require data centers to bring their own power to wherever they choose to locate, or locate where they may directly connect with generators with excess capacity. Those localities that will not allow data centers to build their own generation cannot continue to lean on the system to support their own economic development. It’s parasitic. Once data centers are separated from the host they have been feeding on and become self-reliant, the resiliency problem solves itself. We simply don’t have any more time to wait while the Commission slow rolls minor fixes here and there and hopes for results.

Stand up for West Virginia!  It's not going to change until you do!

YOU get a substation!  Everyone gets a substation!

Has NextEra promised you a substation?  Has another transmission company that wants to run a transmission line through your county or district offered you a substation?  Does your county actually NEED a new substation, or is it being promised as a speculative draw for new data centers or industry in your county?

Talk is cheap.  Reality is expensive.  Really, really expensive.  A new 500kV substation costs around $50M to build.  Even looping MARL (or another new line) through an existing substation in your county costs about $20M.  Who do you think is going to pay for that?  If there's no actual NEED for a new substation, your county or district is going to pay for that.  All of a sudden, it doesn't sound like such a bargain, does it?  After all, your county doesn't have $50M to invest in speculative infrastructure to attract new businesses, does it?

All those promises about NextEra "dropping a substation" in your county or district are likely not only false promises, they are actually ludicrous to anyone who knows anything about how transmission is planned and built.  Don't parade your lack of knowledge around like a blinking beacon.  It's time to look your gift horse in the mouth.  It's just not happening.

Here's the reality about how transmission lines (and substations connected to them) are planned.  In the case of the MARL 500kV transmission project, the NEED came from increased load requests in the Dominion Power zone in Northern Virginia.  Dominion could not serve all the requests it had received to hook up new data center proposals in its service territory.  Dominion's load forecast is made up of actual requests from customers, not speculative requests from politicians or local county planners.  Only electric companies that serve actual customers can add new service requests that become part of the electric company's load forecast at PJM.  If there is no actual customer or NEED for new service, it doesn't go into the load forecast and it doesn't get to PJM. 

Those new service requests at Dominion got added to Dominion's load forecast that was sent to PJM.  In response, PJM opened a new proposal window to serve that need using the transmission system.  MARL was one of the proposals that is purposed to provide 7,500MW of new electricity imports from coal-fired plants in northern West Virginia.  Dominion and its future data center customers are counting on that new extension cord to build.  Those customer requests were made several years ago and cannot be connected until the transmission line is built.  Customers in Northern Virginia can expect to wait up to seven years to get service (if the project is built on time).

If a new data center wants to locate in Hampshire County, West Virginia, it would first make a new service request to the local electricity provider, Potomac Edison.  Potomac Edison would make a determination if it could serve the new customer using the existing system.  If not, Potomac Edison would add the new request to its load forecast that feeds up to PJM for transmission solutions.  However, that new service request would become part of a new planning window, it would not simply "jump the line" to take service away from customers waiting for service in Northern Virginia.

However, if there is no customer in Hampshire, and no new service request for Potomac Edison to serve, Potomac Edison would not add speculative load to its forecast.  The utilities only build the service we actually need.  They don't overbuild their systems based on speculation or political promises.  That's because new transmission and substations are paid for by ALL Potomac Edison customers, and for lines (and substations) 500kV and above, the costs are actually allocated to all consumers in PJM's 13-state region.  Utilities can only charge ratepayers for infrastructure that is used and useful to them.  It cannot charge ratepayers for speculative projects that don't even have a user.

So, where did NextEra's substation promises come from?  Most likely from lobbyists... those sweet talkers who will promise elected officials anything they want to hear in exchange for getting what the company wants.

MARL was originally planned to begin at the 502 Junction substation in Greene Co., Pennsylvania.  It was an unbroken "fly over" transmission line until it reached Frederick County, Virginia, more than 100 miles to the southeast.  There, MARL would build a new 500kV substation to connect MARL with the existing 500kV transmission line called Bismark-Doubs.  That new substation has been named Woodside.  From Woodside, both the existing Bismark-Doubs and the new 500kV MARL line will continue east another 60 miles or so until they connect with an existing 500kV substation in Loudoun County's "data center alley" called Goose Creek.

However, when transmission lines have really long spans between connecting substations, they can lose voltage.  Transmission system owner FirstEnergy noticed that the long span between 502 Junction and Woodside was going to cause unacceptable voltage drop, so they proposed to PJM that the line not simply bypass its existing Black Oak substation as originally planned, but connect there instead on its way east.  According to PJM, the loop into Black Oak is to provide voltage support to the MARL line.  It is NOT to serve new customers in Allegany County, Maryland, as it may have been sold to them in order to gain their support for MARL.  It will actually be taking power from Black Oak, not delivering it.

But, since the Black Oak connection worked so well to snow Allegany County elected officials that they were "getting something" in exchange for hosting the transmission line, perhaps NextEra simply couldn't resist using the same tactic on other elected officials in other impacted communities?  Next thing you know, everyone gets a substation!  And they're just going to "drop" out of the sky, like magic... free magic!  Do these elected officials think that NextEra is paying for all these free, unneeded substations?  Sorry, NextEra has a hard cost cap on the MARL project.  Any freebies they give away are coming out of NextEra's profits.  Also, an unneeded substation is unlikely to be permitted by state regulators.  PJM would have to testify that such a substation is NEEDED and, as as explained above, there is no NEED.  As well, NextEra doesn't serve any end use customers in West Virginia and never will.  Any new service request would be made to Potomac Edison.

In fact, when I asked PJM's planners about the possibility of a substation being "dropped" in Hampshire County (or any other county on MARL's route) I was told that there's currently no plan to do that.  In fact, PJM said that any new customers in those counties would have to make a request to the local electricity provider (Potomac Edison) before anything was planned.  Now go back where we started and read again about how new transmission and substations are planned to serve new customers.

There are currently NO PLANS for new substations to be "dropped" along MARL's route.  Anyone who believes that had best check their facts.  

A new substation is not any more likely than the promises of millions of dollars of new property tax revenue and jobs, jobs, jobs.  It's just not happening.  Oprah can give away cars, but NextEra cannot give away substations.  Don't look like a fool.

Ever feel like the filling in a tuna sandwich?  The "stuff" inside an Oreo?  Well, that's exactly what you are if you're on the Jefferson County section of PJM's 502 Junction to Goose Creek transmission project.  We're being sandwiched between NextEra's MARL on the western side, and FirstEnergy's Gore-Doubs-Goose Creek project on the eastern side.  We're the one remaining area without any maps or information.  Apparently we're being saved for last because we're the ones FirstEnergy is most worried about.  We're the ones who are supposed to remain compliant and in the dark because FirstEnergy has not given us any notice.  Well, wake up folks, this is your notice!

FirstEnergy has finally emerged from their bat cave to disseminate public information about the eastern half of the project.  As I told you several weeks ago, FirstEnergy is calling the eastern half of MARL the melodious Gore-Doubs-Goose Creek project.  You can continue to call it MARL if you like.  It doesn't matter what you call it, as long as you don't call it late for the financial incentives buffet (haw, haw, haw).

But, FirstEnergy is only willing to share information about the Maryland part of its project, and says it wants to file an application with the Maryland PSC by the end of the year.

Despite PJM's empty promises about "using existing rights of way" for eastern MARL, FirstEnergy is planning to expand existing easements and acquire more property.

Fact sheet?  What fact sheet?  Maybe it's on their website?  What website?  The only information you're going to get is going to be in person at the ONE and ONLY "Open House" FirstEnergy is holding for this project.

A public information session on the project is scheduled for June 11 from 6 to 8 p.m. at the Upper Montgomery County Volunteer Fire Department in Beallsville.

This is your only chance to get information.  Be there.

Meanwhile FirstEnergy continues to slink around, approaching landowners with predatory proposals before giving them complete information about the project.

Don't just sit there.  Do something!

The West Virginia Public Service Commission's mission statement is:

However, when a customer filed a general comment with the PSC recently regarding the way FirstEnergy is shirking its duty to provide public information, this is the response she got:

The consumer corrected the PSC with this response:

And then the PSC's Director of Communications responded by passing the buck and telling the consumer to go away.

Aren't there any lawyers at the PSC that can acknowledge that the company has an obligation to notify impacted landowners via certified mail once an application is filed?  That's what the customer was looking for.  She filed a general comment seeking help with the fact that FirstEnergy is approaching landowners to seek Right of Entry on their properties without providing any information about their project.  FirstEnergy has provided no information whatsoever about their project to the impacted communities.  Do impacted landowners have to wait until an application is filed to get basic information about the project and what it intends to do to private property?

Furthermore, a different segment of the same transmission project has absolutely failed to provide effective engagement with other impacted landowners.  NextEra has been holding "Open House" meetings in West Virginia that leave landowners confused and angry.  The meeting setup is loud and confusing.  The maps are not labeled.  The comment cards cannot be filled out later and mailed in.  Attendees cannot have normal conversation with project representatives because they cannot hear what they are saying and answers are non-responsive or misleading.  The company's website is devoid of meaningful explanation or information about this project.

The 500kV MARL project is failing at public engagement on all fronts.

But yet when consumers go to the officials who are supposed to protect them from predatory and outrageous behavior by the public utilities it regulates, they get told their comments cannot be accepted.

In the case of FirstEnergy, impacted landowners and consumers do not even have a contact for the company in order to "file your protest with the company."  Landowners are being preyed upon and nobody is stepping up to protect them.

Keep filing your general comments with the WV PSC, even though they claim they cannot accept them.  And keep a record of your correspondence.  Please forward any refusal of the PSC to accept your comment to your state delegates and senators and ask for their help.    These public servants work for us!

To file a general comment with the WV PSC, go to this link and fill out the form.  Maybe if they receive enough comments about the outrageous behavior of regulated public utilities they will have to do something?

Landowners are not just asking to intervene before an application is filed.  They are commenting on the current process before the application is filed.  Communities deserve an open and transparent process leading up to the filing of an application and they deserve to have their right to information protected by the Public Service Commission.  After all, that is the PSC's mission!

Keep filing your comments with the PSC regarding your concerns with public engagement (or lack thereof).  The PSC has rules that must be followed.  The least it can do is accept and acknowledge your comments about these major transmission projects that have been proposed to cross our state.  Let them know what you think about what's happening now, even if an application has not yet been filed.  Don't let them pass the buck!

An out-of-state utility company hoping to build the MidAtlantic Resiliency Link, or MARL, has been telling local elected officials that its project will bring millions of dollars of new tax revenue to county coffers.

But, will it really?  Or is this just a pig in a poke?

Has anyone bothered to ask the company to show you their math and verify that it actually agrees with the utility tax scheme of your state?  I don't think anyone has.  I've heard that when details are sought, the subject gets changed, or when pressed they say we will find out the details during the state PSC case.  That's magic math, according to one of my elementary school teachers -- where the answer appears out of thin air without showing your work to calculate it.

How ARE utility taxes assessed and paid?  If you don't know, it's time to find out.  There's a whole lot of confusion and nobody at the local county level seems to know.  Don't take some out-of-state company's word about how your own tax system works.  Here's the skinny on how it works in West Virginia...

Utility property taxes are not handled by local government.  It's handled by a state office.  Counties have no authority over the rate or the collection of these taxes.  Once the state has assessed these utility taxes, the utilities appeal and negotiate these rates to have the tax lowered.  Once a deal is reached, the state tax office apportions the utility tax it has collected like this:

 "...the value of the property therein of every such owner or operator as valued or assessed hereunder and the relative value of such operating property within each county compared to the value of the total operating property within the state, to be determined upon such factors as the Auditor shall deem proper;".

Bottom line?  Counties have no control over utility taxes on transmission lines and the tax rates can fluctuate.  Counties only get a small portion of what is collected.  Go ahead, check with your county clerk to find out how much utility tax revenue your county received last year, and then figure out how much of that was actually due to electric transmission lines that cross your county.  Maybe you can buy a cup of coffee with it?

So, where did the company get  the numbers it is using to entice local support?  Did they sit down with the West Virginia Board of Public Works and the state tax commissioner and negotiate a deal?  Did they calculate how the value of the utility property will depreciate over the years until it's nothing but salvage?  Did they mention that transmission utilities don't buy real estate, they simply take an easement and the landowner continues paying taxes on his property, including the easement?

I doubt it.

Corporations are old hands at manipulating local governments to believe that there's a pig in their poke, and not a mangy alley cat, when the corporation is selling new development projects to us "locals."  And so they have developed a computer program to help them out that would make P.T. Barnum proud.  But, instead of calling it something fitting like "Circus Sideshow Software" its name is IMPLAN.  IMPLAN calculates job numbers, taxes, and other economic development numbers that excite local elected officials based on the capital costs of a proposed project.  If the utility company isn't using IMPLAN to come up with these pie-in-the-sky tax revenue numbers, it's using another very similar software company.

And you know what they say about computers -- garbage in, garbage out!

Economic factors calculated by a computer algorithm are not realistic.  You'd get more tax revenue and jobs out of a new fast food restaurant than you'd get from a new transmission line passing through your county and delivering nothing of value on its way.

Job predictions are extremely inflated.  I have seen transmission full-time jobs predicted over the long term that don't even make sense!  Building high-voltage transmission is a highly specialized skill.  Contractors from other states hired to do the actual build will import their own workers for the duration of the job in your community.  IMPLAN and its computerized cousins calculate all the economic impact that such transient workers will cause and then try to sell it to local elected officials as a "benefit."  Hotel rooms, fast food, and gas for their vehicles for the month or so they're onsite isn't really going to make a difference on a local level.  In addition, IMPLAN will spit out some number of full-time, permanent jobs created in your community by the project.  I'm sorry, but this just doesn't happen.

Once the line is built, there are no local jobs associated with it.  Operation and maintenance of the line is handled by remote teams.

But, back to those tax revenue claims...

Ask the company how it has balanced the actual reduction in local tax revenue caused by the project  with the fictional number spit out by IMPLAN.  It hasn't done that at all.

New transmission lines across your county are going to devalue the real estate in your tax base.  A property crossed by a transmission line loses value and the owner of that parcel can appeal his assessment because of the devaluation the transmission line has caused.  In addition, the transmission line can impact many planned developments and future land uses.  What development is currently going on, planned, or dreamed about by your county?  Maybe you want to lay that out on a map to see how close it is to the proposed transmission line route?  New subdivisions, business parks, commercial developments, or maybe just some community improvement like parks, schools, or community services, can all be impeded, or cancelled altogether, if the new transmission line interferes with the proposed development.  Whittled down to its most basic level, it's going to harm local landowners and investors who planned to monetize their land in the future, whether it's for retirement or simple profit.  New transmission lines cause a decrease in your county's current tax base and any future prospects that might increase it.

Also consider that the transmission company actually pays no taxes at all on the transmission lines it builds... you pay those taxes!  A utility collects its cost of service from ratepayers (plus regulated profit).  Everything the company spends on its transmission lines, including real estate, personal property, business and income taxes, is reimbursed to them by electric ratepayers as the expense is incurred.  All persons in your county who pay an electric bill (including the county itself) are paying those taxes!

Think about that while you're comparing the transmission company's bulging poke with reality.  The cat's out of the bag!

Yesterday, the Jefferson County Commission passed a Resolution that nobody seemed to understand, maybe not even the Commissioners themselves.

I made public comment at the Commission meeting yesterday morning, completely oblivious to the Jefferson County First Resolution that was added to the packet after it was originally posted on Monday.  Unfortunately, nobody involved in the power line battle saw it ahead of time and I left the meeting for other adventures before it was discussed.  My bad.  It sure would have been nice if the Commissioners had been more upfront about their Resolution that will impact hundreds of county residents.  Even when asked before the meeting what the mysteriously-named Resolution was about, a Commissioner professed ignorance.

I addressed the Commissioners yesterday morning before the meeting specifically because I had heard a rumor being spread by state legislators that Jefferson County had no power over the transmission lines and that there was federal authority to approve it if West Virginia rejected it.  It seems this untrue rumor came from Del. Linville, who misspoke about the transmission lines at the February 20 meeting.

Jefferson County has enormous power over the fate of the transmission lines, although it has no direct permitting authority.  Jefferson County's power comes from its ability to influence the future decision about the power lines from the West Virginia Public Service Commission.  The County Commission speaks with a louder voice and can advocate for the county and its people as a whole.  We need and appreciate their support!

THERE IS NO FEDERAL BACKSTOP ON PERMITTING FOR THESE LINES!  I told the Commission that yesterday.  No wonder I got such odd looks.  I do understand the prohibition of having direct dialogue with a public commenter so I can't fault them for not saying anything.  However, you'd think that if they were doing something great for the citizens of the County who will be personally impacted by the transmission lines, they would have wanted to spread the word so we could be there to cheer them on.  It's sad that we can't have that relationship.  We're on the same page, but we're not reading from the same book.  I have been working in both the state and federal transmission planning and permitting realm for nearly two decades now.  I have a wealth of experience and knowledge that I can share with you until your eyes roll back in your head and your brain shuts down.  It is incredibly complicated with a lot of moving parts that need to be fully understood before decisions are made.

Transmission siting and permitting is completely under state jurisdiction, except in the event that a line is sited in a designated National Interest Electric Transmission Corridor (NIETC).  A NIETC was proposed for Jefferson County (and other parts of the tri-state area) last year, however, that potential corridor was ABANDONED by the DOE in December 2024.  There is currently NO NIETC, and therefore no federal authority over the two proposed transmission lines in Jefferson County.  There is no other federal mechanism to usurp the jurisdiction of the West Virginia Public Service Commission.  The two transmission lines will live or die by the decision of the West Virginia Public Service Commission, which is a process where Jefferson County (and its citizens) can participate to influence the outcome.

This morning, we woke up to this.

The County Commission discussed their Resolution and unanimously supported its passage.  Unfortunately, the story doesn't say where the Resolution was sent.  It's not a bad Resolution, until it gets to the end where Jefferson County appears to give up and beg for a transmission owner lobbyist to simply whisper the magic words... "this transmission line will attract data centers to Jefferson County", even though that's not true at all.

How DO data centers get power?  Data centers use enormous amounts of power, equalling the power load of small cities in some instances.  When a county has attracted a data center customer (more on that later), the customer will request power service from the local distribution utility.  In our case, it's Potomac Edison.  The customer estimates how much power it will need, often beginning with a baseline amount that ramps up over time as the data center is built out.  Potomac Edison considers this request and determines if it can serve the load from its local system.  If not, it gets added to Potomac Edison's future load forecast that is subsequently relayed to PJM Interconnection  for planning purposes.  If the local utility cannot meet load requests, then it asks PJM to add it to its planning.  Remember, PJM's only tool is transmission.  It cannot order new generation, which is perhaps the better solution to large new load requests.  PJM uses these local load forecasts to create a regional load forecast.  Once PJM has its regional load forecast, it plugs that into its transmission planning and determines how much new transmission might be needed to meet the load requests (because it can't order new generation).  PJM opens a competitive transmission window to solve load (think RFP) and selects the transmission projects that it believes will meet the load.

This is a multi-year, multi-tiered process.  The two transmission lines through Jefferson County are the product of load forecasts and planning that occurred in 2022 and 2024.  The load that was forecast for PJM in those years is slated to occur in Loudoun and Prince William Counties, Virginia.  It's not for load requests from Jefferson County.  The power that these transmission lines will export is already spoken for by load requests that were made in earlier years by new data centers locating in Virginia.  Just because a new line will travel through Jefferson County doesn't mean it will serve new growth here.  

Attracting data centers to your locality is about much more than welcoming new transmission extension cords designed to serve data centers in other states.  It's about offering the data center companies incentives to locate here and providing the infrastructure they may need.  Just as crucial as a local supply of electricity, data centers need a fiber connection.  When Frederick County, Maryland, wanted to attract new data centers to a local campus, they arranged for a fiber backbone connected to Virginia's data center alley.  Jefferson County doesn't have this kind of infrastructure.  Data centers also need a vast supply of water for cooling.  If Jefferson County is going to allow a California company to come in here and pump and sell our water supply to outsiders, we won't have enough left for data centers.  Frederick County located its data center campus at the site of a former aluminum smelter.  Aluminum smelters use a lot of power (but nothing approaching data center proportions) so the site already had a 230kV transmission connection and substation.  Frederick County is using the existing lines to power its campus, not building new ones.  Frederick County maintains that its data center campus is not the reason for new transmission lines.  However, it is curious that both the new transmission lines proposed through Jefferson County land at substations in Frederick County before routing south along the river to make connections in Virginia's data center alley.

If Jefferson County wants to have data centers here, it needs to create a realistic plan, not just throw wide the doors for transmission extension cords for data centers in other states and hope that data centers develop through osmosis.

However, Jefferson County should also spend a great deal of time investigating how data centers have changed other communities that initially welcomed them for economic development purposes.  People are migrating here to live precisely because Jefferson County doesn't have data centers.  Citizens in Virginia hate living with them and can't wait to get out of the hellscape they have created under the guise of economic development.  Jefferson County is the peaceful, rural environment that has disappeared from Northern Virginia.  A good and affordable place to buy a home and raise a family.  Jefferson County needs to be very careful and deliberate with planning for new data centers so it doesn't turn itself into Loudoun County West.  Attracting data centers is something the West Virginia legislature should be studying as well.  State incentives are needed to attract data centers, not just local economic development efforts.

Does Jefferson County currently have any interest from companies wanting to locate new data centers here?  Have those companies developed their plans enough to make a request for service from Potomac Edison?  Or is this Resolution simply a blind expression of hope?  If so, it is unlikely to get to the right place.

Transmission companies use the same playbook every time.  By now, I know it by heart.

Projects are planned by the regional grid operator that many people don't even know exists.  Although the process is open to "stakeholders," those stakeholders have no idea that such an organization is planning a new transmission project that is going to cross their land and, perhaps, take their home.  Once approved by the grid operator, the utilities conduct secret meetings and grease the right palms.  They engage with your state agencies and elected officials to convince them that the project is a good idea.  It's all one big, happy party... SECRET happy party.  Your elected officials and your state agencies don't engage you or send notice.  They leave that up to the utility, and the utility doesn't want you to know until it's so far into the routing process that you can't have any real impact on where it goes.  You're supposed to remain dumb and happy until the last minute.  Then the utility springs it on you as a fait accompli and conducts a farcical public information and notification process.  At this point, they hope you're out of options and that you will jump into action to push the project off yourself and onto your neighbor.  That's the first reaction of the vast majority of people, until someone finally figures out it's not about where it goes, it's about whether it goes.

But, until you finally receive notice, you should know that the utility has been very busy consulting with everyone except the landowner who would be forced to host the transmission line on his property.  And don't you know it, NextEra has been very busy trying to schmooze a path for its portion of the MidAtlantic Resiliency Link (MARL).  This presentation recently surfaced, although it's been common knowledge to a bunch of people who were hiding it from you for months.

Perhaps your most important take away from this little peek into what's been going on behind your back is this slide.  Click to download the above file to see a larger version.  

This is the roadmap of NextEra's routing process.  The red box is where "we" are.  It's a point called "Engage Counties and KEY STAKEHOLDER With Preliminary Route."  Right... KEY STAKEHOLDER... but that doesn't include the most important KEY of all... the landowners who will be asked to host this project.  When are impacted landowners notified?  Three turns away at "Open Houses", which is nearly the last pit stop on this highway to hell.  By that time, everyone else that won't see it from their house has been consulted about the route and brought on board.  Landowners come last on this journey.

Landowners are presented with a couple of routing options and are expected to spend all their time fighting each other over where it goes, instead of joining forces against the real enemy.  And they call this "community consultation"... when the decision has already been made.

DAD - Decide, Announce, Defend.  DAD is a top-down, minimally participatory method of public management.  You're sheep and they are the sheepdogs.  This never works on a smart, engaged public because the last "D" never ends.  People won't give up when their very home is on the line.  And when the utilities are put on the defensive, they say and do the stupidest things, most of them dishonest.  Nobody is buying it.  We all know how to smell a rat.  Propaganda is a useless waste of money.

​So, what else is in that power point?  Well, there's a full map of the MARL project, including FirstEnergy's portion.  NextEra has been pretending that the eastern part of the project doesn't exist and that their project simply ends in Frederick County, Virginia.

But it's clearly shown on a map that the end of NextEra's MARL is simply the HANDOFF POINT.  That's where their transmission line connects directly to FirstEnergy's transmission line.

We're all in this together, folks!  Landowners and communities impacted by NextEra's MARL are in the same boat as landowners impacted by FirstEnergy's MARL.  Neither one of these line sections can happen without the other.  Kill one, kill them both.

Here's what the landowners impacted by NextEra's MARL are facing:

Landowners on FirstEnergy's portion are facing the tear down of an existing 138-kV transmission line, expansion of the existing easement at least 100 feet, and the building of a new 500kV line with a 138kV circuit on the same new towers.

Pay attention, people!  It's coming!  Although the most FirstEnergy has done is threaten to "survey" its existing easements on its part of this project, you should also know that they are working behind the scenes, much like NextEra, to schmooze KEY STAKEHOLDERS to accept the project before you even realize that they've decided on a route across your property.  The announcement will come later, with Open Houses of our own.  By that time, the route is set in stone.  Be prepared to fight!

Jefferson County is going to need a new slogan for roadside signs soon.  I suggest the above, maybe bolstered by some fine print... "All the electricity that makes Loudoun the wealthiest county in the nation comes through here first!"  What is Jefferson County getting from all this?  Homes and businesses taken using eminent domain, multiple huge new transmission lines of the highest voltage built in the U.S. in close proximity to our homes and schools, and higher electric bills.  What does Loudoun County get?  Data centers, lots and lots of new "economic development" data centers.  Loudoun County ended 2024 with a budget surplus of over $250M, thanks to all the data centers it has approved and built.  Loudoun County gets the gold, and West Virginia gets the shaft.  Again.

When are West Virginia lawmakers going to *wake up* and realize that we don't have to export the electricity generated here using our coal and gas resources?  We could use it right here to increase our own economic development!  Instead, we've been shipping the excess power we generate out of state so other areas can get rich using it to attract economic development like data centers.  Why not create incentives for data centers to locate here in West Virginia, right next to our existing generators?  West Virginia could finally start growing its own tech industry and use its plentiful resources to attract new business.  Data centers are hungry, hungry, hungry for steady, dispatchable electricity and promoting West Virginia as the ideal location for new data centers is win-win for West Virginia.  Exporting our electricity to Loudoun County over huge new high-voltage extension cords is lose-lose for West Virginia.

Yesterday, PJM Interconnection's Transmission Expansion Advisory Committee met for more than 4 hours.  A handful of intrepid electric ratepayers and citizens attended to make comment and ask questions.  At the end of the day, PJM stuck with its previous recommendation to order and build another new transmission line through Jefferson County.  Last year, PJM ordered the building of a different transmission line through our county.  Over the past two years, PJM has ordered two new major transmission lines crossing through Jefferson County on their way from West Virginia coal-fired generation stations to Loudoun County's data centers.  Yesterday, PJM informed us that it will be opening two more bidding windows in mid-2025 to solicit even more power lines for Virginia's data centers.  PJM is having trouble keeping up with Virginia's data center demand, and the only place with available power left is West Virginia.  Funny that Virginia hates our coal-fired power stations, and Virginia is on target to meet its VCEA requirement to reduce its carbon emissions to zero by 2045, but Virginia has no problem at all importing more and more coal-fired electricity to use in its data centers and pretending they're still meeting their environmental goals because it is not generated in Virginia.

The project PJM will be recommending to its Board of Managers for approval is a new 765kV transmission line beginning at the John Amos coal-fired power station in Putnam County, and crossing 14 West Virginia counties on its way to data center alley (Putnam, Kanawha, Roane, Calhoun, Braxton, Lewis, Upshur, Barbour, Tucker, Preston, Grant, Hardy, Hampshire and Jefferson) 3 counties in Virginia (Clarke, Frederick and Loudoun) and end in Frederick County, Maryland at a new substation south of Point of Rocks. If you want to see maps of where this project will be routed in Jefferson, find them here.  Here's PJM's awful maps and listing of the project's components.
​

PJM's awful maps are insisting that the "new PATH" project will be constructed on "existing ROW or parallel to existing ROW" indicated by the pink line on the map.  Elsewhere in PJM's presentation was the statement that the new 765kV development would require 100% new right-of-way.  That's right... the new PATH will require a completely new 200 ft. wide right-of-way (ROW).  PJM and the new PATH sponsors are trying to pretend that they can create a new 200 ft. wide ROW directly adjacent and parallel with the existing transmission line corridor in Jefferson County.  PJM believes there is value and risk reduction in a parallel line siting.  That might be true, if there was actually land available parallel to the existing ROW, but there's not.  The existing ROW is lined with homes, schools, businesses and even new solar farms.  A new 200 ft. parallel ROW will destroy everything in its path.  For this reason, I insisted that PJM at least draw its "new PATH" correctly on its awful, out of proportion map as a new greenfield corridor.  PJM refused.   We can't even get a little honesty.

Who is PJM fooling?  Not us!  PJM is trying to fool its Board of Managers by telling them that nobody will mind this new 765kV transmission line and that it won't be taking any new land.  PJM thinks this will make the Board more likely to approve this project as non-controversial.  We're not going to let that happen, but that's another blog post coming soon -- writing to PJM's Board of Managers to insist they deal with the truth about this project.

As part of its creation of its new transmission plan, PJM is required to create a "Constructability and Financial Analysis Report" for the proposed projects to present to their Board when seeking approval.  PJM's Constructability Analysis is a complete joke!  The report starts out by detailing the "Approach", or method, of performing this study.

The approach calls for PJM to do an "in-depth" review of each project's ROW acquisition, land acquisition, and siting and permitting requirements, among others.  As part of this, PJM is required to do a "desk top" investigation of each project's land use mapping (using actual maps!) to include:

These are just a few of the things that must be studied as part of this Constructability study.  Did PJM do that?  No, they didn't.  PJM simply copied the narrative written by the project sponsor in its bid for the project and turned a blind eye to the actual impacts of this "new PATH" 765kV transmission line.

Here's what PJM's Constructability Study concluded about the project:

There's absolutely nothing in there about any of the development bordering the existing corridor they want to expand.  Perhaps if it doesn't have to acknowledge the destruction of Jefferson County's built community, then PJM can continue to believe that a parallel siting is somehow less risky than a new line somewhere else.

PJM negligence becomes even more glaring if you read the analyses of the other projects that were not selected.  Some of these other projects have very detailed narratives of how they will affect the built community.  Read it for yourself (full report).

Here's just a couple examples that caught my eye:

PJM also evaluated these projects based on the proposer's experience building similar lines.  In its report, PJM said that FirstEnergy (proposed owner of new PATH) passed this test.  When I questioned PJM about what 765kV lines FirstEnergy has ever owned or built, PJM said they were actually using the experience of another company, Transource (an AEP affiliate).  When asked how many 765kV lines Transource has ever owned or built, PJM again came up empty.  Ditto on Dominion.  The ONLY utility with this experience in the country is American Electric Power (AEP), parent company of Transource.  PJM's constructability analysis is not based on reality and has enough holes in it to drive a truck through.  The truth is that PJM simply FAKED this report based on biased information it was given by the project sponsors and didn't perform any analysis at all.  If this isn't true, then PJM is encouraged to produce the desktop study with all the required data and make a liar out of me.  PJM's Constructability Report is pure, unadulterated CRAP.

I also questioned PJM about whether the "new PATH" project was actually competitively bid.  Since 2011, FERC has required regional grid planners like PJM to open competitive bidding windows when it needs new transmission projects.  The idea is that utilities will compete with each other to create the best project at the least cost.  Bidders often include "cost caps" and other financial considerations that limit the costs to consumers.  PJM has been running these bidding windows for around 10 years now.  The big investor owned utilities did not like these windows because they don't want to have their profits limited by having to compete for projects.  So, the utilities started building smaller, local, supplemental projects that did not have to be approved by PJM as a way to avoid competition.  Because of this, there were pretty much no opportunities to build new transmission using competitive windows.  Therefore the utilities did not have to compete.  If you try to thwart the deep rooted greed of investor owned utilities, they will eventually find a way around whatever roadblock you construct. And now they have figured out a way around PJM's competitive bidding window.  The three biggest utilities in PJM got together ahead of time and came up with a scheme to limit competition and increase profits with their joint bid into this window.  FirstEnergy, AEP's Transource, and Dominion submitted "joint proposals" that did not have any cost caps or financial considerations for ratepayers.  If they didn't have to compete with each other, then they could score a project with an unlimited price tag.  Of course, this kind of behavior to limit competition and fix prices is what's known as a cartel.  Once the three utilities had their project selected, they have now decided to create a shell company "joint partnership" to own the projects because PJM cannot award a project submitted as a joint proposal to individual companies (that would violate FERC's rules!)  Reality is that this "competitive" window was illegally controlled by a cartel.

Last month, I sent an email requesting that PJM come to Jefferson County and give us a presentation about what it is they do so we can find out about their processes.  This was in response to a disparaging comment one of the PJM staff made to a Jefferson County citizen, telling her to "get a basic education" before asking questions at the TEAC.

This month, PJM came prepared with a long list of online "resources" that we can use to educate ourselves.

Last year, regional grid planner PJM Interconnection approved a new 500kV transmission line from a cluster of coal-fired power plants in northern West Virginia to Virginia's data center alley.  That line is assigned to Florida-based NextEra Transmission (Greene County PA, Mon, Preston, Mineral and Hampshire Counties WV, Garrett and Allegheny Counties, MD portions) and Ohio-based FirstEnergy (Frederick, Clarke, and Loudoun Counties, VA, Frederick County, MD, and Jefferson County, WV portions).  On a map, that combined project looks like this:

Locally here in Jefferson County, the project is proposed to tear down the existing 138kV transmission line and replace it with a combined 500kV line with 138kV underbuild (double circuit) on an expanded right-of-way.  The current line configuration across southern Jefferson looks like this:

The big metal towers will stay the same.  The smaller wooden towers will be torn down and replaced with a big metal tower that has the two new circuits on it.  It will be 30-50 ft. taller than the existing one it parallels.  The end result will be two big metal towers on an expanded right-of-way.

Now PJM needs another transmission extension cord for Virginia's data centers.  The first one just wasn't enough power because Virginia just can't stop building the data centers.  PJM's latest proposal is a 765kV transmission line (the largest AC transmission line in the country) from the John Amos coal-fired power station in Putnam County, WV to Virginia's data center alley.  On PJM's map, the project looks like this:

This new 765kV is proposed by a joint partnership between FirstEnergy, American Electric Power and Dominion Energy.  It is proposed to cross 14 counties in West Virginia (Putnam, Kanawha, Roane, Calhoun, Braxton, Lewis, Upshur, Barbour, Tucker, Preston, Grant, Hardy, Hampshire and Jefferson) 3 counties in Virginia (Clarke, Frederick and Loudoun) and end in Frederick County, Maryland at a new substation north of Point of Rocks.  It is proposed to be built on a new 200 ft. wide right-of-way on towers that look like this:

In Jefferson County, it has been proposed that the new transmission line run parallel to the existing 500/138kV right-of-way that is already slated to be expanded with the addition of a second 500kV line that was approved last year.  If approved, this would expand that existing right-of-way another 200 ft. and add a third transmission tower bigger than the other two.

PJM is still discussing this proposal in its Transmission Expansion Advisory Committee.  The next meeting (and final opportunity for the public to comment) is scheduled for January 7, beginning at 11:15 a.m.  Anyone who is concerned about this proposal is invited to participate, either over the phone, via Webex, or in person at PJM's office in Valley Forge, PA.  Participation requires that you register in advance.  You can sign up for the meeting here.

After the meeting, PJM's committee will recommend that the PJM Board of Managers approve the project and add it to the regional plan.  At that time, we can write to the Board of Managers to ask that they not approve it (but that's a task for another day).  If the project is approved by the Board of Managers, then it is assigned to the responsible utilities who will finalize a route and submit applications to the three state public utility commissions for approval to build it.  If the state commissions approve it, then the utility will have eminent domain authority to take property for its new right-of-way.  This whole process is going to take years, so let's stay focused on the PJM process for the moment.

So, many are asking themselves... am I impacted?  PJM's maps are purposefully vague because PJM is not a transmission line router.  It simply approves a transmission line between two substations... where the route actually goes is a function of the utility assigned to build it, and that route must be approved by the state commissions.  So, we don't know for certain at this time where the new 765kV project will be routed.

What we do know, however, is that this new 765kV project appears in all proposals to be identical to the failed Potomac-Appalachian Transmission Highline (PATH) project that was proposed back in 2008.  That project was subsequently cancelled in 2012, before any state approved a final route.  However, the PATH legacy lives on in the memories of the folks who battled it last time.

I still have the detailed Jefferson County maps from the PATH project.  On these maps, you can zoom in to see an aerial photo of your area and where the existing transmission lines run, along with the proposed location of the PATH project.  Sorry it doesn't have any of the newer fancy GPS features like typing your address into a finder, but we're dealing with something circa 2009 here.  The map tiles should give you a general idea of how the new 765k line may impact your property.  

Couple of notes before you look at the maps.  There is one overview tile (above) and 11 other map tiles that trace the route across Jefferson County, tile by tile.  You'll have to find the tile with your property on it, then you can zoom in to take a closer look.

The PATH route is the yellow dotted line.  In some places, it deviated from the existing transmission corridor due to space constraints.  In some cases, the deviation took it miles away from the existing lines, so keep in mind that this line could be routed anywhere and will not necessarily stay parallel to the existing transmission lines.  In some places, there's a black dotted line that says "rebuild of existing 500kV line".  This was a way PATH planned to snake through narrow areas, however that rebuild can no longer happen due to the new 500kV/138kV line that was approved last year.  FirstEnergy is already using the space that the 138kV line currently sits on for its new 500kV line.  It cannot also use that same space for the 765kV line.  While it is possible to double-circuit a 138kV line with a 500 or 765kV line, it is not possible to double circuit 500 or 765kV lines with each other.  The new 765kV transmission line will have to be routed on a new 200 ft. wide right-of-way.  If you live in one of those dotted black line areas, it is likely that the new 765kV transmission line will take your home.  There's simply no where else to put it unless they deviate miles away from the existing transmission corridor.  It is virtually impossible to avoid everything and everyone.  It is a certainty that homes in Jefferson will be lost.  Yours may be one of them... sacrificed to the data center Gods in Virginia.

Also keep in mind that these aerial maps are 15 years old and cover a portion of Jefferson County that has seen enormous growth over the past several years.  Much of what was once farmland is now solar farms and new housing developments (and the building continues!). If you live in a newer development, your home might be represented in an old photo that shows the farms that were there before.  The true extent of the horror of how this line will impact Jefferson County isn't shown.

Now, the maps.  You may need to open several to find the one where your property is shown.  The tiles begin at the western edge of Jefferson and proceed east.

If your property is anywhere near the route for the failed PATH project, you should be concerned.  PATH is going to have a much harder time routing through Jefferson this time around and some properties will be sacrificed.

It's time to step up and get involved!  It's never too early to oppose new transmission needed only to serve Virginia's data centers.