...the permit holder has made good faith efforts to engage with landowners and other stakeholders early in the applicable permitting process...

Taking the time today to listen to property owners and adjust plans in response to their concerns, they hope, will lessen the likelihood of drawn-out legal or political battles delaying the project later.

Christina Hayes, executive director of Americans for a Clean Energy Grid, said the two Minnesota utilities are following the best practice of early stakeholder engagement to avoid later potential litigation.

The third powerline was the last straw for Marla Britton.  Her and her husband’s 40-acre farm near Brainerd, Minnesota, is already framed by electrical wires on the east and south. When she learned of plans for a new project running along the north end of her property, she took action.  Britton wrote to state utility regulators and contacted the companies behind the planned Northland Reliability Project. The 180-mile line will eventually make it easier to move clean electricity between central and northern Minnesota.  Soon, a utility representative was at her doorstep to discuss her concerns and ideas for rerouting the line where it would have less impact on her and her neighbors.

“They listened to me and wrote down what I said,” Britton said. “They agreed it was way too much for my property.”

It’s yet to be seen how Britton’s feedback will be reflected in the final route, but the interaction illustrates the type of engagement that project backers say they are aiming for with the project. Taking the time today to listen to property owners and adjust plans in response to their concerns, they hope, will lessen the likelihood of drawn-out legal or political battles delaying the project later.

PJM’s Reliability Analysis presentation at the August 8, 2023 TEAC demonstrates a marked concern for routing/siting/permitting/scheduling risks of certain component segments submitted in 2022 RTEP Window 3.  I appreciate that PJM is considering these factors.  After all, what good is a transmission project that cannot be built due to opposition?

My review of the projects submitted in Window 3 finds that several of these projects are reinvention of old projects, either in whole or in part, that PJM approved years ago and then later abandoned or suspended.  Three of these historic projects are the Potomac-Appalachian Transmission Highline (now FE-23 and FE-837), the Mid-Atlantic Power Pathway (now Exelon-691), and the Independence Energy Connection (now Transource-487).  These projects have cost PJM ratepayers hundreds of millions of dollars in development and legal fees despite never being built.

No matter what reason PJM recorded for the suspension and abandonment of these three transmission projects, the fact remains that each of these projects was met with a wall of resistance from landowner groups, state/local governments, elected officials, public interest groups, and impacted communities.  Opposition to PATH, MAPP and IEC prevented approval and construction of these projects and added considerable delays to their schedule.  Entities that opposed these projects the first time around are knowledgeable and prepared to oppose them again.  The impacts of these projects, which made them objectionable in the first place, have not changed.  The only difference now is that the opposition is better educated and better prepared to win this battle.

I asked during the TEAC how PJM could receive comments from impacted communities to consider as part of their constructibility studies for the projects.  I heard from you that stakeholders could voice their concerns during TEAC meetings, as I was doing, or contact something called “Stakeholder Engagement Group.”  Neither option actually incorporates the stakeholder comment into the constructibility report outcome.

I have read some of PJM’s “constructibility reports” in the past.  The one for the Independence Energy Connection particularly stands out in my mind, as that constructibility report found significant opposition would not occur because the project was routed on “undeveloped land.”   That “undeveloped land” is prime farmland, important to its owners and the community it supports.  The owners of this “undeveloped land” are highly educated, well connected, and capable of preventing this project from being constructed as originally ordered by PJM.  In conclusion, PJM’s constructibility report was dead wrong because the entity that prepared it was woefully uninformed about transmission opposition and real conditions on the ground.  These are areas where public comment and consultation can be incorporated into the constructibility report to improve its historic lack of accuracy.

The presentation at yesterday’s TEAC mentioned “Utilization of existing ROWs and brownfield development/expansion.”  Existing ROWs include more than just transmission or utility ROWs.  New technologies and policies are opening existing transportation ROWs to new transmission infrastructure.  These ROWs are ideal for burying HVDC for the purpose of transporting electricity from one market to another, not serving communities along the way.  Window 3 seems to concentrate on importing new power supply to the data centers.  HVDC buried on transportation ROWs may be a solution supported by impacted communities. See more: https://theray.org/technology/transmission/

Expansion of existing transmission ROWs by adding parallel lines is NOT a solution to routing issues.  PJM needs to re-think this unworkable approach.  While existing transmission built in the last century may have been routed on agricultural land, aka “undeveloped land”, the land use conditions that existed when the transmission line was built in 1950 will not be the same in 2023, especially in the growing PJM region.  Many former farms have been sold and re-developed into new housing communities and other uses.  The community has built itself up around the existing transmission line, often with new homes, schools, and other expansion right up to the edge of the existing ROW.  Expanding the existing ROW cannot happen without destroying this new development.  This was one of PATH’s biggest problems in Jefferson County, West Virginia.  Housing developments had sprung up to surround existing transmission lines and expansion of the ROW would begin to destroy portions of these communities.  This problem has not changed in the 15 years since.  In fact, it’s gotten much worse.  However, FirstEnergy’s submitted projects depend on expanding these ROWs to build new lines parallel to existing ones.  While I recognize PJM does not design the routes for its projects, it still must be cognizant of the project’s shortcomings and risk in order to be successful at what it does do.

There’s a lot that PJM (and its member utilities and constructibility report contractors) do not know about the dynamics of transmission opposition.   Much can be learned from study of scholarly research on the social aspects of opposition.  It is not simply a “NIMBY” issue that can be solved by routing elsewhere.  Impacted people need to examine the problem and be involved in the creation of a solution.  PJM has historically ordered transmission and left the designated entity to approach the community with a pre-determined transmission solution and consult with them about where to put it.  This is not a choice for the impacted community and they will reject it every time.  While investigating the basis of the need for the project, the community will develop other solutions to solve the problem, such as use of existing rights-of-way, upgrading of existing lines, burying lines, allowing the market to demand new generation before building transmission, as well as other demand side solutions such as energy efficiency and distributed generation.  The designated entity and PJM have resisted any and all suggested modifications to their plans, and as a result the project never gets built.  Is PJM about building workable solutions, or spending eternity trying to foist its will on a public that doesn’t want or need it?

PJM prides itself on its “transparency”, but lacks any avenue for true stakeholder participation.  Stakeholder consultation should begin in the project planning phase so that PJM doesn’t waste time and money pursuing projects that are not constructible.  Allowing stakeholders to make comments that are never considered or acted upon is a parody of democracy.  I ask that PJM create a way to accept public comments and incorporate them into its planning, particularly for such an enormous undertaking as Window 3.  I have tried to find the “stakeholder engagement group” you suggested during the TEAC, but cannot find anything like that on PJM’s website.  I would appreciate a substantive response to this comment/suggestion, not just an acknowledgement it has been received (and ignored).

“Initially, the town was told it would be 100 percent by rail,” said Glenville Town Supervisor Chris Koetzle of what CHPE first said when they explained that part of the land-based section of line would go through his town. 

But over the last few months, [the town] started getting phone calls from residents of the Woodhaven neighborhood who were contacted by CHPE for easements.

Negotiations over the easements and the idea the land could be taken through eminent domain has some people contacting their lawyers.

“I’ve had a couple of people call me,” said Patrick Seely a lawyer with the Jones Hacker Murphy firm in Troy. He hasn’t actually been retained, but noted that in easement cases, there is often a negotiation. “A little bit of horse trading goes on all the time,” he said.

Project title:  Mid-Atlantic Power Pathway (MAPP)

Project description:  Exelon is proposing a 230 mile, 500 kV AC / 400 kV DC high-voltage transmission line originating in Northern Virginia, crossing Maryland, traveling up the Delmarva Peninsula and terminating in southern New Jersey.

When four representatives of National Grid came before Concord City Council on Monday to start the long process of expanding a power line through the state bringing electricity from HydroQuebec, they soon encountered a ghost.

“Our community still suffers from PTSD with regard to Northern Pass,” Councilor Jennifer Kretovic told them. “When you mention the words HydroQuebec, that will automatically raise concern.”

The four representatives nodded glumly.

Component title:  Fort Martin - Doubs 500 kV #1 Line

Project description:  Construct ~158 miles of new 500 kV line from Fort Martin Substation to Doubs Substation.Terminate the new transmission line and revise relay settings at Doubs and Fort Martin substations.Install fiber OPGW along the new line route. The construction of this new line will require the acquisition of 158 miles of new right-of-way, forestry clearing, permitting, and access road construction. Re-terminate the Bismark 500 kV Line at Doubs Substation. Aerial LiDAR will be required. This new transmission line will require Proposal Components 1 (Doubs Substation - Install500 kV Breaker), 2 (Doubs Substation - Expand 500 kV), and 4 (Fort Martin Substation - Install 500kV Breaker) to be completed.

This new 500 kV line will be constructed in West Virginia, Virginia, and Maryland. Full Applications will be required in each state. - It is assumed that the new 500 kV line will parallel existing ROW for approximately (85.6) miles and require (74.4) miles of new ROW not adjacent to existing ROW. It is assumed that no existing lines will be overbuilt with double circuit structures, but existing line rebuilds will be considered where applicable. - Approximately (695) parcels will be affected by the line route. Assumed 5% condemnation (35 parcels).

The right-of-way width is assumed to be 200 ft. This width is based on the widest ROW needed for 500 kV and does not account for structure configuration or span lengths. Widths needed may vary upon final design.

The new Fort Martin-Doubs #1 500 kV Line will be constructed on double circuit 500 kV tubular steel monopole and two-Pole structures. The second 500 kV circuit is to be left vacant and installed at a future date. - The average span length is 1200 ft. - It is assumed that the new double circuit monopole structures will have an average height of 180 ft. Final structure heights will need to be determined during project development. FAA filing and application may be required. - The new structures will utilize custom 500 kV V-string and double I-string suspension and dead-end insulator assemblies.

This new 500 kV line provides a direct connection from the west side of the system to the east side. - This new line provides the ability to install a second Fort Martin - Doubs 500 kV Line on the same structures, without additional right-of-way acquisition. - This new line route will provide the opportunity to loop the Fort Martin - Doubs 500 kV Line into Bedington and/or Black Oak substations in the future, if necessary for reliability or resiliency. - Greenfield construction is assumed due to outage constraints, but existing rights-of-way and corridors to rebuild lower voltage lines will be considered where applicable.

Component title:  Meadow Brook - Doubs 500 kV Line

Project description:  Construct 55.3 miles of new 500 kV line from Meadow Brook Substation to Doubs Substation.Terminate the new transmission line and revise relay settings at Doubs and Meadow Brook substations. Install fiber along the new line route. The construction of this new line will require the acquisition of 55.3 miles of new right-of-way, forestry clearing, permitting, and access road construction. Re-terminate the Meadow Brook - Loudon & Meadow Brook - Front Royal 500 kV lines at Meadow Brook Substation. Aerial LiDAR will be required. This new transmission line wil lrequire Proposal Components 1 (Doubs Substation - Install 500 kV Breaker), Component 2 (Doubs Substation - Expand 500 kV), and Component 3 (Meadow Brook Substation - Expand 500 kV) to be completed.

This new 500 kV line will be constructed in Virginia, West Virginia, and Maryland. Full Applications will be required in each state. - It is assumed that the new line will parallel existing ROW for approximately (22.8) miles and require (32.5) miles of new ROW not adjacent to existing ROW. It is assumed that no existing lines will be overbuilt with double circuit structures, but existing line rebuilds will be considered where applicable. - Approximately (146) parcels will be affected by thel ine route. Assumed 5% condemnation (7 parcels).

The right-of-way width is assumed to be 200 ft. This width is based on the widest ROW needed for 500 kV and does not account for structure configuration or span lengths. Widths needed can vary upon final design.

This new line will be constructed on single circuit 500 kV tubular steel monopole structures with an average span length of 1200 ft. - The new structures will utilize custom 500 kV V-string and double I-string suspension and dead-end insulator assemblies. - New single circuit structures will have an average height of 150 ft.

This new 500 kV Line will provide an additional and much shorter electrical path between Meadow Brook and Doubs linking the Black Oak-Bedington corridor with the 'AP South' corridor. - Greenfield construction is assumed due to outage constraints, but existing rights-of-way and corridors to rebuild lower voltage lines will be considered where applicable.