er2401998.pdf
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potomac_edison_designated_entity_acceptance_letter.pdf
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MARL’s in-service date is already slipping. Why is that relevant? Because the electric grid abhors a vacuum. When a planned transmission (or generation) project fails to come online when needed, other projects will take its place. That’s exactly what happened with the PATH project, and what is likely to happen with the MARL project, including the Potomac Edison portion that is the subject of this filing. 

This transmission project may never happen, but PJM and the utilities involved feel they should pursue it anyhow. Is that because there are no other options? Or is it because there’s no harm done to them if it fails. All the burden of failure falls on ratepayers, and this encourages the utilities to take more of a chance than they would it they had some skin in the game. Utilities shoulder no risk, while collecting all the rewards. 
​
Consumers have zero control over the project’s risk factors, but they are the ones left holding the bag when it fails. As consumers, we simply cannot afford to continue to financially cover the failures of grid planners and transmission developers simply because we are the one entity without a voice in incentive awards. 

"We must recognize that many of the challenges we face today which are accelerating very quickly — namely concerns over sufficient transmission capacity, loss of electric power generation and the inability to site and build new baseload-power generation — are tied directly to poorly-thought out state public policies which have prioritized political considerations above the needs of consumers.
For example, while many states surrounding Pennsylvania have touted their climate goals and reductions, they have conveniently ignored that they have achieved many of these goals simply by shutting down their in-state generation. As a result, they rely on imports of electricity from states like Pennsylvania, which is the largest electricity exporting state in the nation, increasing transmission costs, line loss due to distant transport of electricity and increased risk of blackouts or brownouts."

"Other state policies have upset the balance of competitive power generation by subsidizing
preferred energy resources — many of these resources incapable of providing baseload power generation on demand — or threatening coal and natural gas generation with onerous carbon taxes.
For example, just the prospect of Pennsylvania entering the Regional Greenhouse Gas Initiative (RGGI) has cost the commonwealth billions of dollars in private capital investment and thousands of jobs, and at the same time failed to demonstrate any commensurate environmental benefit to the public. Too often energy policy is being hijacked to serve politically expedient objectives rather than to meet the most fundamental objective that it should serve: ensuring the lights go on when
we flip the switch."

​The MPRP is a 500,000-volt (500 kV) transmission line designed to respond to growing electric needs in Maryland and the surrounding region. Transmission reliability is key to supporting Maryland’s energy future.

• Will PSEG want access to my property before I agree to grant an easement for the project?
  
• ​PSEG may request prior access to conduct preliminary work such as a survey, delineate wetlands and/or conduct an appraisal to determine the amount of land needed and the value of an easement. In that case, the land owner will be asked to sign a right of entry document allowing PSEG onto the property for only these limited purposes.

Ensure that any representative acting on the applicant’s behalf states their full name, title, and employer, as well as the name of the applicant that they represent, and presents a photo identification badge at the beginning of any discussion with an affected landowner, and provides the representative’s and applicant’s contact information, including mailing address, telephone number, and electronic mail address, prior to the end of the discussion.

Ensure that all communications with affected landowners are factually correct. The applicant must correct any statements made by it or any representative acting on its behalf that it becomes aware were:
(i) Inaccurate when made; or
(ii) Have been rendered inaccurate based on subsequent events, within three business days of discovery of any such inaccuracy.

Ensure that communications with affected landowners do not misrepresent the status of the discussions or negotiations between the parties. Provide an affected landowner upon request a copy of any discussion log entries that pertain to that affected landowner’s property.

Provide affected landowners with updated contact information whenever an applicant’s contact information changes.

Communicate respectfully with affected landowners and avoid harassing, coercive, manipulative, or intimidating communications or high-pressure tactics.

Except as otherwise provided by State, Tribal, or local law, abide by an affected landowner’s request to end the communication or for the applicant or its representative to leave the affected landowner’s property.

Except as otherwise provided by State, Tribal, or local law, obtain an affected landowner’s permission prior to entering the property, including for survey or environmental assessment, and leave the property without argument or delay if the affected landowner revokes permission.

Refrain from discussing an affected landowner’s communications or negotiations status with any other affected landowner. 

​Provide the affected landowner with a copy of any appraisal that has been prepared by, or on behalf of, the applicant for that affected landowner’s property, if any, before discussing the value of the property in question.  

impacted_landowner_comments.pdf
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pjm_transmission_cost_order.pdf
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...that the time has come for this Commission to take the lead in its convening role to initiate a proceeding, such as a Notice of Inquiry, a series of technical conferences, or by initiating an FPA section 206 proceeding outside this docket, posing such important questions, among others, as: What is the proper definition of a public policy transmission project? Does the definition of public policy transmission project need to be changed for purposes of regional cost allocation? How should public policy transmission projects be cost-allocated in a multi-state RTO? In my view the states themselves need to be at the forefront of deciding these questions, as it is their own state policies that are largely making these questions unavoidable, as these two recent PJM RTEP cases graphically illustrate. 

As a factual matter, there is no question that the Commonwealth of Virginia has – as a matter of public policy – for years given generous tax subsidies directly to one very specific type of industry: data centers.  Virginia’s entire I-95 corridor between Northern Virginia and Richmond may accurately be called “Data Center Alley.” Did these tax subsidies cause Data Center Alley? Under the economic principle of “if you want more of something, subsidize it,” it is logical to assume that Virginia’s tax subsidies did incent the construction of more data centers than would otherwise have located in this corridor, although the exact marginal impact remains unknowable. But the Maryland People’s Counsel and Intervenor Newman make a logical argument to consider the necessary construction of reliability lines in PJM due to load growth from the explosion of data center development in Virginia, as driven – at least at the margin – by Virginia’s own public policy of subsidizing data centers. 

These comments logically raise the question whether a law such as Maryland’s mandate to close fossil-fueled generation units located in Maryland has a more direct, intentional and causal impact on the need for new reliability transmission lines than state tax subsidies to high-load customers such as data centers. At a minimum, both Maryland and Virginia state commenters make arguments that are worthy of serious consideration.