Category:

PJM's Altered Reality

11/1/2023

Yesterday, PJM Interconnection held its monthly Transmission Expansion Advisory Committee (TEAC) meeting. At the meeting, PJM revealed its plan for massive transmission expansion around the Mid-Atlantic region to fix electric reliability issues caused by the closure of 11,000 megawatts of fossil fuel generation combined with 7,500 megawatts of increased demand from the out-of-control building of new data centers in Northern Virginia. It doesn't take a mathematician to realize that these numbers add up to a need for increased electric generation close to 20,000 megawatts. For reference, a good sized coal, nuclear or gas-fired electric generation station amounts to around 800-1000 megawatts. We need 20,000 megawatts of what's known as "baseload" power, generation that can be counted on to generate when called and is not dependent upon weather or other factors to produce electricity. Also for reference, a good sized solar farm may have the capacity to produce up to 100 megawatts, if it has the fuel (sunshine) necessary to generate. We're going to need 20-25 new baseload generation plants, or 200 new large solar farms. PJM does not order new generation to be built. It can only order new transmission to move existing generation around. And that is the purpose of PJM's new transmission plan. PJM plans to import electric generation to Northern Virginia from West Virginia and Pennsylvania, the only two states in the PJM region that still produce excess electricity from fossil fuels. In order to do so, PJM has planned numerous new extension cords from WV and PA that will connect with the "needy" areas in the DC - Baltimore metro areas. On PJM's map, it looks like this:

As shown, much of the burden of importing generation into the DC - Baltimore area is placed on rural areas to the north and west, who are expected to sacrifice their homes, businesses, and communities to make way for these new transmission extension cords.

One such project begins in WV's northern panhandle along the Ohio River at the Kammer substation and meanders southeast for hundreds of miles through 4 states before connecting to a new substation in Northern Virginia's "data center alley." PJM's map of this project looks like this:

At the western end, the extension cord is surrounded by old coal and gas electric generators in WV and SW PA. Look at them all! That's where the power will be produced. At the eastern end, the extension cord is surrounded by data centers. That's where the power will be used. This project proposes to build a new 500kV transmission line on new right-of-way adjacent to an existing line. People who have one line on their property will now have two. In some areas, it proposes to veer off the existing lines and create new rights-of-way in areas without transmission lines. In Jefferson County, WV, the proposal is to demolish and rebuild an existing 138kV transmission line on an expanded right-of-way to create a double circuit 500/138kV transmission line on new lattice steel towers up to 200 feet tall. In some areas of Jefferson, the project will veer off the right-of-way and create new right-of-way in areas that currently do not have transmission lines. Once the project crosses the Appalachian Trail and enters Virginia, it proposes to veer sharply south/southeast and create a new 500kV transmission line through areas that currently do not have transmission lines, such as Waterford. At its end point, it will connect with a new substation along the Dulles Greenway in Ashburn.

To the northeast, PJM proposes a new 500kV transmission line on new right-of-way in areas that currently don't have transmission lines in order to bring power from Pennsylvania produced by gas and nuclear to an existing substation in Frederick County, MD called Doubs. From Doubs, the project will create two new 500kV lines into data center alley built mostly on existing transmission line routes. On PJM's map, that project looks like this:

The major new lines that will require new transmission rights-of-way are in the west and north. Worse yet, PJM has assigned these greenfield projects to competitive transmission builders from other states. Much of the western line is assigned to NextEra, a company from Florida. The northern line is assigned to PSE&G, a company from New Jersey. These companies don't know our communities or how impossible it will be to plow through them with new transmission lines. And at the end of the day, they may not care... they won't be seeing it from the windows of their own homes.

Only in Jefferson County will the west project be assigned to incumbent FirstEnergy/Potomac Edison because it is a expansion and rebuild of a line they already own. These are the same guys who brought us the Potomac-Appalachian Transmission Highline, or PATH, project between 2008-2012. Won't we have fun the second time around?

And with that rough description of the plan presented, here's my report of yesterday's TEAC meeting.

The meeting was kicked off with a brief speech from PJM's Vice President of Transmission, Ken Seiler, who read from some canned speech about how this transmission plan is the result of transitioning to clean energy. You can read more about that here. PJM's can also included that article. But things didn't quite go as planned. I spoke up to state that PJM's plan is nothing more than a giant extension cord importing fossil fuel power from WV and PA into Northern Virginia. I asked how this comports with Virginia's "clean energy" laws. Are Virginia's clean energy goals nothing but a sham they hide behind while actually importing more fossil fuels from surrounding states?

PJM personnel tried to push back that its plan would connect "new resources" but it was half-hearted at best. There are no "new resources" anywhere near these lines.

PJM TEAC leaders explained how their plan would be read twice at TEAC meetings and then submitted to the PJM Board of Managers for approval. Once approved (because *gasp* that can be the ONLY outcome!) the projects would be assigned and the utilities would take it from there. PJM explained it would allow a whopping six, count 'em 6, days from second read to Board meeting. Because being boxed into a time crunch isn't my favorite thing, I asked how we could contact PJM's Board of Managers right now. PJM said it would send me the information, but that only poked the hornet's nest. Many other attendees also wanted the information so they could contact the Board. A gentleman from the Maryland Office of People's Counsel told PJM they should be running this more like a public hearing. Bravo! PJM's "transparency" with stakeholders leaves much to be desired. Many people have tried to sign up for meetings and found themselves in an impossible maze. Even if they finally do manage to sign up, they have to sit in the meeting for hours just to get an opportunity to comment on this plan, which is always the last item on the agenda. Ain't nobody got time for that! PJM offered up that it would take email comments, something I had to force them into months ago. PJM tried to direct comments to some "customer service" email that is nothing but a black hole. I know how to contact the Board directly and it was confirmed yesterday after much discussion. More to come on that front, but get your pencils sharpened and be ready to send your comments!

I asked PJM what would happen if this plan and all its separate parts are not approved and built by the "in service" date selected (June 2027). Will the lights go out? Will the utilities in No. Va. have to tell the new data centers that they cannot supply them with electricity? PJM's answer was long and winding about how much these new projects are "needed" but at its core I saw a glimmer of reality. Yes, they would have to stop serving new load so the lights won't go out. This is where PJM's reality diverges from the one the rest of us live in. PJM thinks these projects (all of them) will be built on time and on budget. PJM won't even entertain the reality that the vast majority of these projects won't be built on time, and several of them won't be built ever.

After the PATH failure, I've worked with landowner groups on at least a dozen other transmission projects around the country that were hotly opposed. Not one of them has ever been built. I know a transmission failure in the making when I see it, and I know how to push it off the possibility cliff. PJM is not being realistic, despite losing a lot of major transmission battles in recent memory.

I asked why PJM changed its plan to allow FirstEnergy to build the west project in Jefferson County at the very last minute before yesterday's meeting. It's because FirstEnergy owns the line that will be rebuilt. That's something I questioned at the last TEAC meeting where PJM insisted that NextEra would be doing the rebuild.

And speaking of FirstEnergy and the project in Jefferson County, I also asked whether the new solar "farms" in Jefferson that are being built adjacent to the existing line that will be rebuilt will lose service for an extended period of time while the rebuild is happening. These projects have waited years to interconnect to the existing line and now they may not have service after all until the project is completed. It could be many months because the existing line has to be shut off and torn down before the replacement is built. PJM's answer, if you can believe it, is that FirstEnergy did not come prepared to answer that question. In other words, we don't know or care. I thought PJM was a planner?

I asked what would happen if one of the segments of the West project was not approved by one of the 4 states that have siting authority. Would changes be made or would the project be cancelled? After all, if the little greenfield segment in Loudoun County is not approved, there's no need for the rest of it because it cannot connect to the data centers and we have no need for it here. PJM's answer is that would be up to the utilities building it. Another non-answer! It's up to the state regulators to condition any approval on the entire project being approved before any building starts.

PJM announced that the cost of all these projects would be more than $5 Billion. The cost would be added to the electric bills of every electric customer in the PJM region (that means you!). I asked if that cost included financial incentives granted by the Federal Energy Regulatory Commission, which can increase costs significantly. PJM said no. The utilities building these projects can apply with FERC to increase their profits with higher returns (interest) and other accounting treatments that allow them to start charging ratepayers right away for projects that may or may not be built until later. In addition, FERC can (and probably will) grant the abandonment incentive, which means ratepayers will pay for these projects WHETHER THEY ARE EVER CONSTRUCTED OR NOT. This "plan" is going to cost us a lot more than $5B.

PJM did agree to share the "constructabilty report" it created before selecting these projects. The report evaluates the risks and costs of each project, as well as the feasibility of actually constructing it when faced with opposition, and compares the projects to find the one with the greatest chance of success at the lowest price. Last month, I asked PJM to make this report public and it flat out refused. Now it says its report will be included in its recommendation paper to the Board of Managers. Baby steps...

Yesterday's TEAC lasted 6 hours and 49 minutes, according to the timer on my WebEx. It was a giant time suck that produced little new information, but we can't let them win because we don't show up.

PJM will recommend these awful transmission ideas to its Board of Managers on December 11. It is up to all of us to convince the Board to reject this ill-conceived plan and demand that TEAC come up with something better. How about something that will not place burden on communities that will receive no benefit?

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PJM Selects New Transmission Scenarios

10/15/2023

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On October 3, PJM Interconnection revealed its preferred scenarios for new transmission to connect coal-fired electric generation plants in West Virginia and southwestern Pennsylvania to the unabated build out of new data centers in Northern Virginia that are making our grid unreliable.

PJM narrowed the 72 proposals it received down to just 3 preferred scenarios shown in this presentation on pages 41-43. PJM says it included the proposal on page 41, identified as NextEra 175, because it was a non-incumbent solution. PJM went on to indicate that this proposal really doesn't have a snowball's chance in hell of being the final selection. PJM is favoring the 500 kV or 765 kV scenarios on pages 42-43. PJM said that it will select one of these two for an immediate recommendation for approval and build, and select the other as a long-term scenario. From what PJM said, and from browsing the submissions in PJM's next competitie proposal window, I surmise that the 500 kV scenario is the "right now" project and the 765 kV scenario is the long term solution it will recommend next. Therefore, we can expect that PJM will approve and assign BOTH of these proposals to be built within the next 5-7 years.

Let's concentrate on the 500kV scenario. PJM says that this scenario is part of proposal number 853 submitted by NextEra. NextEra is a competitive transmission developer based in Florida. It's not your local utility. NextEra 853 looks like this on PJM's map:

The portions of this proposal that affect Jefferson County, West Virginia and Loudoun County, Virginia look like this:

There are two connecting route segments in Jefferson County, West Virginia and Loudoun County, Virginia. The following is PJM's narrative description of where these routes will go. The brown text indicates portions where NextEra will wreck and rebuild the existing 138kV transmission line (wooden H-frame poles) as a double-circuit 500/138 kV line that will require at least an additional 30 feet of right-of-way. The green text indicates portions of the project that will be on new 165 ft. wide right-of-way. For the Loudoun County portion, the new 500 kV line will be routed in areas without existing transmission lines.

Segment 1
General route description: Route is approximately 22 miles long. Starting at a new dead end structure at the new Woodside substation, the line routes east along the existing Stonewall - Feagan's Mill 138kV transmission line ROW for 11 miles with the entire Stonewall - Feagan's Mill 138kV transmission line rebuilt under the new greenfield transmission line. The new line routes around the existing Feagan's Mill substation and then resumes using the existing 138kV transmission ROW between Feagan's Mill and Millville, for about 2 miles where the 138kV transmission ROW separates from the existing Bismark - Doubs500kV transmission ROW. The line routes adjacent to the existing 500kV transmission ROW for almost 4 miles before resumes using the existing Millville - Lovettsville 138kV transmission line. The line uses the Millville - Lovettsville 138kV transmission line ROW for approximately 4 miles to the east before deviating from the existing 138kV transmission ROW to create a new ROW. It is advantageous to rebuild the existing 138kV transmission circuits underneath the new 500kVtransmission line to minimize viewshed impacts, reduce ROW acquisition costs, reduce residential land infrastructure impacts, and reduce tree clearing requirements, especially for the furthest east section where the new line crosses the Appalachian Trail. This line component ends east of the Appalachian Trail, where a different line component begins to continue the route to new Gant substation.
The new right of way will be an expansion of an existing transmission line corridor for approximately 80% of the route length, where a 30 ft additional width will be required beyond the existing, assumed, ROW edge. For approximately 20% of the route length, the right of way will have its own corridor with a width of 115 ft (10%) and 165 ft (5%).
The majority, approximately 80%, of the proposed structures will be single circuit 500kV lattice towers with 138kV (TTVS-500-138) in a horizontal conductor configuration. The 138kV line to be underbuilt is an existing line. Approximately 20% of the structures will be single circuit 500kV lattice towers (TTVS-500) in a horizontal conductor configuration. Any proposed deadend structure will either be lattice tower or a 3-pole, one phase per pole structure type.

Segment 2
Route is approximately 25 miles long. The component begins as a continuation of the 500kV -138kV underbuild from the new Woodside substation. The line continues to follow the existing Doubs - Bismark 500kV transmission ROW for about 0.5 miles before turning south. The line maintains a predominately south-southeast direction for about 17 miles, with minor shifts in route direction to reduce impacts to existing structures, residences, and vegetation. The new line shifts east around Leesburg, Virginia, for about 5 miles, before reaching the Dulles Greenway. The line routes alongside the Dulles Greenway ROW for about a mile before turning north and terminating at the new Gant substation.
The new right of way will have its own corridor and will have a width of 165 ft.
The proposed structures will be single circuit 500kV lattice towers (TTVS-500) in a horizontal conductor configuration. Any proposed deadend structure will either be lattice tower or a 3-pole, one phase per pole structure type.

PJM has indicated that it will make its final selection on October 31. If you even think you may be affected by this proposal, you need to make PJM aware of your concerns now. You can send your comments on this proposal to PJM by emailing [email protected], [email protected] and [email protected].

If you do nothing, your next notice may be a postcard in the mail indicating that NextEra is routing the transmission line through your property and requires you to sign over a right-of-way across your property. Don't be a sitting duck!

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Spin Studies

9/17/2023

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Americans for a Clean Energy Grid is by far the king of spin studies. Even the name of this industry group is spin! "Americans"? It would be more aptly named "Corporations for Building Transmission From Which We Profit". CBTFWWP. Has a nice ring to it, doesn't it? Use of the word "Americans" is a tired, old front group tactic used by corporations to make you think that their front is actually made up of average people who love whatever is being sold. The only "Americans" here are corporations, and not all of them are actually American corporations!

ACEG is nothing but a transmission industry front group that writes numerous spin studies to promote their product, whether we need it or not. The studies aren't compiled for regular Americans like you... they are put together and promoted endlessly on Capitol Hill to convince your elected representatives that they should enact enabling legislation for more transmission, and more profits for their members. If you wrap your propaganda in a "study" it's supposed to have more clout. Another old propaganda trick!

So, here's the latest Spin Study being spun by CBTFWWP, and it includes a list of transmission projects we need right now to usher in a clean energy future.

The Spin Study names 36 transmission projects that it claims are "Ready to Go." It defines "Ready to Go" like this:

The determination of whether a project is ready-to-go relied on two criteria: 1) whether the project is at or near the finish line on the various federal and state permits they may need; and 2) whether the project is actively pursuing the cost recovery, allocation, and/ or subscriptions required for the developer to proceed. Inherently some judgment is re- quired. Based on these criteria we excluded over ten significant projects that are in earlier stages of development and not yet far enough along to be considered ready-to-go.

Has permits? Has cost recovery? Then what the hell is "Clean Line" doing on this list? The Oklahoma portion of the failed Plain & Eastern Clean Line isn't even a real project yet. What permits does it have? Who is paying for it? That's some "judgment"!

Clean Line – Originally proposed in 2009 by Clean Line Energy Partners to deliver renew- able energy from the Oklahoma Panhandle to Southeast markets, the Oklahoma portion of this DC merchant line was purchased and is now being developed by NextEra Energy.

The spinners justified their "judgment" for including this project with this article from 2017 that informs NextEra bought the remains of the Oklahoma portion. It doesn't say anything about permits or cost recovery. The only place "Clean Line" is ready to go is the trash can.

The spin gets even thicker on the projects that have failed since the first Spin Study.

Lake Erie Connector – DC line under Lake Erie, connecting Ontario with PJM, the grid operator in the Mid-Atlantic and Great Lakes region. The project had been under devel- opment for approximately 10 years, but ITC Holdings, which purchased the rights to the project in 2014, placed the project on hold citing economic conditions.

Oh? Economic conditions? How could that be so with all the government handouts to transmission in the IIJA and the IRA? Here's the "economic conditions" that have caused that project to be shelved... it's a merchant line that can't find customers.

“ITC made the decision to suspend the project after determining there is not a viable path to achieve successful negotiations and other requirements within the required project schedule. External conditions – including rising inflation, interest rates, and fluctuations in the U.S.-to-Canadian foreign exchange rate – would prevent the company from coming to a customer agreement that would sufficiently capture both the benefits and the costs of the project,” an ITC spokesperson said in a prepared media statement. “As a result, the company believes suspending the project is in the best interest of stakeholders.”

Lots of words in that salad when "can't find any customers at the price we need to build this thing" would do. It's a shame, too. That project was actually routed underwater so it didn't create any land impacts.

Speaking of word salad, the spinners claim that new transmission will be the key to reaching clean energy utopia.

Not only has investment in regional transmission lines been decreasing, but at the same time the need for regional transmission has been increasing due to a variety of factors. These include increasing demand growth, electrification of transportation and other sectors, higher natural gas prices due to European demand, a changing resource mix due to the economics of new renewable generation, increased customer demand for renewable resources, significant utility commitments for renewable energy expansion and decarbonization, and new public policies from local, state, and federal governments promoting carbon-free generation. The aggregation of these trends suggests a shift in the generation mix and significant load growth over the next few decades, both of which will require new transmission capacity.

But that's not even true. The spinners presume that all new transmission will be "for renewables." PJM Interconnection is the first to make a liar out of them by creating new transmission to feed Northern Virginia data centers from fossil fuel generation in the Ohio Valley.

Transmission capacity is also critical in helping shift national economic policy toward an increased focus on onshoring manufacturing to develop domestic supply chains. De- velopment of new domestic manufacturing along with growth in data centers, partially driven by AI, represents the potential for significant economic growth and job growth for the US.

These new manufacturing facilities, along with new data centers, often require additional transmission to ensure the grid has the capacity to reliably interconnect significant new industrial loads. However, delays are already beginning to occur. Interconnection requests for data centers have dropped across the country and in Northern Virginia – a national hub for data centers – there is a scramble to meet the soaring power demand as current grid capacity is limited.

Some experts estimate that fully electrifying the US’s industrial load could more than double current US power demand. The current issues are arising even before manufacturing for microchips and additional electric vehicle production and battery manufacturing facilities fully ramp up, along with hydrogen production facilities. If sufficient transmission capacity is not available, these investments could be significantly delayed or even canceled.

That's right... when PJM was faced with new data center load, it did not propose transmission from renewable generators to meet need. That's because data centers use as much energy as large cities, and you can't reliably serve them solely with intermittent renewables. New data center load will INCREASE carbon emissions by ramping up the generation of fossil fuel electricity. This is what is going to happen when load increases... transmission connecting existing fossil fuel generators will be proposed. New data centers actually crash our clean energy policies.

The Spin Study has been produced for one purpose only... to pander to Congress to pass even more enabling legislation for transmission. Its recommendations to do just that are at the end of this "study." It recommends special tax credits for new transmission, federal transmission permitting and siting, federal eminent domain, and wider cost allocation.

There are also additional policy levers that Congress and FERC could pull to help facilitate faster and more effective buildout of new transmission. Americans for a Clean Energy Grid’s Legislative Principles outlines a number of these potential approaches.

I'd like to pull a couple levers... maybe the one that sends this Spin Study to the dumpster.

Enabling new transmission with legislation is the fast track to increasing carbon emissions.

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Is PJM's Competitive Transmission Process Rigged?

9/14/2023

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Something is sure starting to stink!

Since the old PATH days, PJM has been required to revise its transmission planning to put long-lead needs out for bid in a competitive process. This is supposed to ensure that PJM's 65 million electric consumers pay a lower cost to construct the transmission they need. It is supposed to give independent transmission companies an opportunity to build projects cheaper than the utility that serves the impacted service area, which PJM refers to as "incumbents." This is supposed to produce lower electric bills for the consumers.

Does this really work as regulators intended? Over the years I have read about various complaints made by some of the competitors in PJM's competitive "Open Window" transmission bidding process claiming that their project was not treated fairly. I can see how they might come to that conclusion. I'm seriously starting to develop the opinion that PJM's competitive process is nothing more than Kabuki theater performed to hide uncompetitive behavior that produces financial windfalls for its incumbents. PJM's thumb is on the scale... maybe its whole body! This process cannot be be called transparent and competitive by any stretch of the imagination.

PJM's bidding windows present a problem to be solved with transmission. Any qualified entity may submit a proposal. PJM publicly posts redacted versions of all the proposals it receives for a window here. Select 2022 Window 3 from the list, to see an example. Next, PJM creates maps for each proposal because a picture is worth 1,000 words. However, PJM's map-making skills leave much to be desired. A creative Kindergarten could do a better job making accurate maps with finger paints. Already for Window 3, we have seen at least 5 different versions of maps for the proposals. I'm pretty sure the actual number is much higher than 5, but I haven't been keeping track. PJM has been notified of numerous additional errors in its newest version of the maps, however PJM has not corrected any of the errors, nor even responded to emails pointing them out.

Errors in PJM maps include drawing greenfield transmission lines as brownfield and making inaccurate designations between greenfield and brownfield; creating substations that are not part of any proposal; mismarking the voltage of new substations; leaving components off certain maps... and I could go on because the list of errors is as long as my arm.

PJM chooses not to explain itself, nor why it is attempting to create maps when it does not posses the proper skill set. Why doesn't PJM simply require the bidder to include an accurate map of its project components using certain parameters? It would have saved loads of time and money so far for Window 3.

PJM's maps include a completely different legend for each map in the Window 3 series. In some legends, a 765-kV substation is pink, in others, it is red. In some maps, the colors in the legends do not match the colors on the maps (go ahead, PJM, find the map where a color not on the legend appears -- I double dare you!). It is impossibly confusing to flip between the different maps to compare different proposals because the maps are not equal. Some are definitely manipulated and do NOT follow the written proposal or provide an accurate comparison to other proposals. It's almost like PJM is using the maps as an influencing tool.

Who is PJM trying to influence with its maps? I have asked PJM repeatedly what it does with these maps, and it has refused to answer. I'm going to assume they CAN'T answer because the answer may point to the real reason for this map-making incompetence and, perhaps, purposeful manipulation.

Here's another uncompetitive process at PJM... I wanted PJM to accept public comment regarding the proposals in Window 3 to compile for its feasibility study. The feasibility study looks at things like routes, environmental considerations, permitting, supply chain, cost of the project and the possibility of delay relating to community opposition to the proposal. Since a number of the proposals in Window 3 are basic recycling of old projects that were opposed and abandoned, I think it's only fair that the feasibility study acknowledge how and why these projects failed the first time and what may have changed that would make them successful this time around. But, PJM just gave me the run around instead of being appreciative of more information for its feasibility study. PJM would only receive verbal public comments at its monthly TEAC meetings, which requires a complicated and frustrating sign up and registration process and then several hours of waiting for the appropriate time to comment. And even then, PJM was rude and argumentative with the few people that managed to jump all these hurdles in order to comment. PJM preferred to argue over meeting procedures than the substantive issues. You blew it, PJM! This is not what an open and inclusive stakeholder process looks like! PJM has flat out refused to respond to my many attempts to find a way to accept, compile, and include public comments in its feasibility studies.

PJM says that it has hired a third-party contractor to prepare feasibility reports for its preferred scenarios. Will the contractor use the maps for its evaluation? If so, it will be evaluating something that is not accurate. An evaluation of an inaccurate proposal results in an inaccurate study. What a waste of time and money! Will the contractor use information about routing, permitting, environmental issues, and the possibility of opposition for its evaluation of the feasibility of the preferred scenario? Signs point to "no" since PJM is trying so hard to make sure any public comment stays far, far away from its contractor. If the contractor does not know about obstacles, then it won't include any in its feasibility report... smooth sailing ahead (while the people on the ground are swearing vehement opposition).

However, PJM also uses its feasibility reports and maps to inform its Board of Managers about the projects it is recommending for approval. Therefore, an inaccurate feasibility report gives an inaccurate picture of the recommended projects to the Board of Managers. How can the Board of Managers accurately evaluate recommended projects when the information they receive is inaccurate, or perhaps manipulated to influence their decision and lead them down the primrose path to making the decision to approve the recommended projects based on pure fiction?

I'm starting to believe PJM's "competitive" process is rigged through the manipulation of mapping and feasibility studies that drives PJM to select and approve a project unfairly.

Ball in your court, PJM.

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The Haves And The Have Nots

9/8/2023

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Data Centers in Northern Virginia need more power. They can't get it from local suppliers in Virginia, therefore regional grid operator PJM Interconnection has asked for new transmission proposals to import new electricity supply to serve the Northern Virginia data centers.

But why can't they build more renewables in Virginia to power the data centers, you ask? First of all, the data centers need as much electricity as a large city. Imagine taking New York City and plunking it down next to Dulles Airport and expecting to hook up to the existing electric system. The data centers use half as much as NYC! The load is just too great to solve with new renewable generators at load. This is a fact that seems to be escaping the elected officials in Virginia -- they don't realize how much electricity these data centers use.

Bates said he didn’t realize running a power line to a data center was considered a transmission line.

We all need to educate our local officials on the consequences of building energy sucking data centers in our communities. It's not just a distribution service line on small wooden poles like homes or businesses use. The power requirements are so great that data centers need big new high-voltage transmission lines and substations. They also need big new energy generators to produce the energy used.

Transmission opponent Patti Hankins from Harford County, Maryland, has put together an eye-opening presentation showing the energy supply profiles of several Mid-Atlantic states. Is your state an electricity importer or an electricity exporter? Nobody seems to be paying attention to this important fact these days, when everyone seems to be focused on increasing renewable generation and phasing out fossil fuels like coal, gas and oil. The media drones on incessantly about closing fossil fuel generators, and many people think that renewables like wind and solar supply a huge amount of our energy. What's really happening up the line when you turn on your light switch?

This presentation tells you everything you need to know.

comparison_of_pjm_state_installed_capacity_2022.pdf
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Did you know that Pennsylvania and West Virginia are the only two states in our region that export electricity to other states? Pennsylvania's electricity is mainly created from natural gas, with coal and nuclear making up the vast majority of the remainder. In West Virginia, the numbers are even more astounding, with 91% of the supply created by burning coal. Natural gas makes up the majority of the remainder. In both Pennsylvania and West Virginia, wind and solar provide so little energy that it's hard to even see their slice of the pie.

On the other hand, states like Virginia, Maryland, the District of Columbia (that imports 99% of the electricity it uses!), Delaware, New Jersey and Ohio are big energy importers. These states all have renewable energy goals and policies that have served to shut down a big majority of the fossil fuel electric generators that used to supply their energy. Additions of wind and solar have not kept up with the supply lost by closing fossil fuel generators. Even in these renewable loving states, wind and solar make up a very small percentage of the power that is used. The percentage is so small that it cannot support the state's electric load under any circumstances. So, where do these states get their electricity? From West Virginia and Pennsylvania via high-voltage transmission lines. Little do these states know that when they turn on the light switch, they are using good, old-fashioned coal and natural gas. And they stand ready to INCREASE their use of fossil fuels by building more energy hogs in their areas. This is the reason PJM is currently proposing a high-voltage transmission build out of epic proportions.

The thought of building the big baseload generators needed to power the new data centers near the data centers isn't even contemplated. It would never happen! However, why is it okay to increase the burning of fossil fuels in other states in order to power new data centers? Don't we all breathe the same air? Who's the NIMBY now?

We're not as far along on a renewable energy transition as people are being told by the media. Wind and solar is getting all the attention (and government handouts), but it's actually powering little. The corporations, utilities, and local governments lie about how "clean and green" they are. If they actually only used the renewable energy they produce, their lights would be out for a vast majority of the time. Without West Virginia and Pennsylvania burning fossil fuels, polluting their environments, and sacrificing to build gigantic new electric transmission line extension cords to the east coast cities, these areas would experience rolling blackouts worse than a third-world nation.

Another lie the media loves is that we need to build new high-voltage transmission to ship renewable energy around the country. After looking at these graphs and maps, you'll realize this just can't happen. We are currently stuck in a world of HAVES and HAVE NOTS. West Virginia and Pennsylvania HAVE the electricity and Virginia, Maryland, DC, Delaware and New Jersey HAVE NOT. What's really going to be on these new transmission lines is fossil fuel electricity from states with enough to export. So while the federal government comes up with new programs and taxpayer-funded giveaways to grease the skids for new transmission, they must acknowledge that the only thing they are actually doing is INCREASING emissions.

Elected officials considering new plans for data centers and other big energy hogs that they hope will bring new tax revenue, jobs, and economic development need to recognize that their state does not have enough electricity supply to support this new infrastructure. New transmission lines from states that burn fossil fuels is not the answer. The data center boom must be paused until the localities that will reap the financial rewards can build the clean infrastructure they will need to support it.

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What Will Be On New PJM Lines?

8/25/2023

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PJM Interconnection is the grid planner for the Mid-Atlantic region. PJM's job is to keep the grid reliable and the electricity markets competitive. When load increases in PJM's region without a corresponding increase in generation of electricity, reliability suffers. When reliability is threatened, PJM springs into action and plans new transmission to solve the impending crisis. If PJM did not act, we'd soon experience brown outs and black outs and the whole PJM system would crash. The most logical solution for PJM would be to order new generation near sources of increased load. However, PJM cannot order new generation, it can only order new transmission. Electric generation is a market-based, competitive endeavor. If demand increases prices in a certain load pocket, then the generation market receives a signal that it would be profitable for new generation to build for that load. It works, in theory, but sadly not in practice. PJM's reliability focused transmission planners never let the market work to spur new generation. When prices increase, or reliability issues crop up on the horizon, PJM orders new transmission to solve the problem before any new generators are even contemplated. PJM complains about the loss of baseload generation without replacement, but fails to acknowledge its own role in creating the problem.

Over the past decade or so, Northern Virginia has become the data center capital of the country. Data centers use a LOT of electricity. This recent article says that Amazon data centers in Northern Virginia use half as much electricity as New York City every day, and 35% more than the entire power grid of the company's hometown city of Seattle. That's a huge electric load currently being built out in Northern Virginia without a corresponding increase in electric generation. PJM says the data centers are creating a reliability issue and it has opened a request for proposals to solve it using transmission. The goal is to export a whole bunch of electricity to Northern Virginia, and PJM's utility members wasted no time in creating new transmission lines that would connect the generators they own to Northern Virginia.

One such proposal from FirstEnergy envisions two new 500kV lines from West Virginia to a substation in Frederick County, Maryland. Other utilities have proposed new lines from that substation to Northern Virginia, completing the new extension cords.

Extension cords are exactly what these new transmission lines are. They plug in at struggling FirstEnergy-owned electric generators in West Virginia and provide a pathway for additional electricity generated in West Virginia to power the data centers in Northern Virginia.

The map shows the northern line of this proposal beginning at Fort Martin, West Virginia. Fort Martin is the location of FirstEnergy's coal-fired Ft. Martin Power Station.

The plant uses more than 2.8 million tons of coal annually and at full capacity the plant’s generating units can produce more than 26 million kilowatt-hours of electricity daily. Read more here.

Of course, nobody wants coal-fired electricity any more and FirstEnergy has been toying with closing or selling some of these plants. And then the PJM serendipity fairy arrived! PJM needs transmission to bring a new supply of power to No. Va., and FirstEnergy can bolster the future economic success of its failing generators by connecting it to data center load. And FirstEnergy's proposal was born.

The southern line of FirstEnergy's proposal is shown on the map as beginning at Pruntytown, WV. Pruntytown is a gigantic substation where many electric generators in the area connect to the grid. One such plant is FirstEnergy's Harrison Power Station in Haywood, West Virginia.

Harrison uses more than five million tons of coal annually and at full capacity the plant’s generating units can produce over 47 million kilowatt-hours of electricity daily. Read more about Harrison here. FirstEnergy's bottom line wins again with this proposal!

But did anyone ask Northern Virginia if they wanted to import dirty coal-fired electricity from West Virginia to power their data centers? PJM? FirstEnergy? Dominion? These entities are going to have a really hard time selling this to a community with clean energy goals and aspirations. The D.C. metro area is so worried about climate change that they have closed many fossil fuel generators in their own neighborhoods. Why would these people just look the other way and shrug about increasing their carbon footprint every time they turn on the light switch? Would local governments in Northern Virginia keep approving new data centers that need power if they knew they were increasing regional air pollution? Where's the tipping point here?

In addition to the burning of more coal to produce more electricity in West Virginia, FirstEnergy's proposals also plan on hundreds of miles of new transmission rights of way across private property between West Virginia and Northern Virginia. None of these affected landowners need this new electric supply. It's simply passing through on its way to corporate users in D.C.'s growing urban sprawl.

Of course, FirstEnergy's proposal is only one of 72 that PJM received. Other utilities have proposed connecting their nuclear and gas fired power stations in south eastern Pennsylvania to the data center load via new transmission lines. Numerous proposals begin at the Peach Bottom Atomic Power Station in Delta, PA and the gas-fired York Energy Center in the same town. Still other proposals want to connect the data center load to American Electric Power's massive 765kV transmission system in the Ohio Valley, where numerous fossil fuel plants are struggling to survive. See the 765 lines on this map:

The endpoint of AEP's 765kV system in Virginia is at a substation called Joshua Falls. New lines beginning at Joshua Falls connect to the data center load as shown on this proposal map submitted to PJM by AEP subsidiary Transource.

Northern Virginia communities need to go into this new power supply for their data centers with their eyes wide open. Are all the "benefits" they are receiving from the massive data center build out worth increasing their carbon footprint? Why are other communities in rural areas hundreds of miles from the data centers being forced to sacrifice their land and in some instances, the very air they breathe, so that Northern Virginia counties can increase their tax revenue and their sprawl? If these counties are receiving all the benefits from the data center buildout, shouldn't they also step up and shoulder the negative impacts by building new coal, gas, and nuclear power stations in their own communities?

There has to be a better solution than this!

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PJM's Implausible Deniability

8/18/2023

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Regional grid planner/operator PJM Interconnection says that it selects proposed projects based, in part, on their "constructibility." Other factors PJM considers are cost, and whether or not the proposal solves all the grid issues in the RFP (which PJM calls an "Open Window').

PJM's credibility goes right out the window, though, when it ignores "constructibility" issues and pretends the projects it selects are "constructible."

What is "constructibility"? It's the likelihood of permitting problems, the ease of getting equipment and supplies, and OPPOSITION. Let me say that again... the likelihood of opposition to a transmission proposal developing makes it less likely that the project will actually ever be built. That's why utilities should never site new projects on old routes from abandoned projects that developed opposition. If a transmission project was opposed at that location in the past, there's a 100% chance that opposition will develop there again.

If PJM really cared about "constructibility" it would conduct public outreach before selecting new transmission projects. But what if PJM is simply erecting a smoke screen of "plausible deniability" so it can pretend unconstructible projects that it favors are actually viable?

And if PJM was constructing a "plausible deniability" constructibility scenario, it would rely on the most implausible claims of the utilities that have proposed the projects.

Here are some actual claims made by project proponents in their proposals to PJM.

A large scale set of projects that solve the growing congestion issues in the southern Pennsylvania/northern Virginia/Maryland/West Virginia area. The project involves strategic rebuilds, substation upgrades, and greenfield transmission lines that primarily follow existing corridor. This strategic use of existing corridor greatly reduces the risk of projects being delayed due to opposition.

Colocating the line with the existing transmission line helps mitigate viewshed issues and permitting risk.

No. It does not. Cutting a new corridor next to an existing one does not prevent opposition. Those folks with existing corridors on their property don't want another, and they don't want to lose more land to an electric line that provides no benefit to them. You can't expect the same people to make the same sacrifice over and over again for the benefit of others who never make any sacrifice.

A cultural resource professional assisted with the routing process to identify and minimize impacts to known areas with historic sensitivities.

The utility hired the right contractor who didn't find what he was paid not to find. Why should anyone believe a paid utility consultant? This contractor's idea of "historic" is probably not the same as yours. If it's not on the Historic Register or preserved in some way, it is likely to be destroyed. Opposition doesn't care about some contractor's opinion. Opposition forms and acts based on it's own opinion. Hiring a contractor does not increase constructibility.

There are no unique or sensitive environmental concerns or impacts with the proposed transmission line that cannot be addressed.

But you didn't ask the landowners who live there what they think and they are the ones who control opposition. What does "addressed" mean? It means the utility blows a lot of smoke and nonsense and plows ahead according to its own plan. Then the utility can say it "addressed" your concerns... by telling you your concerns are stupid.

The combination of these three elements provides a comprehensive solution for the current requirements in the area. Four documents are attached to show the progress already made on this...

Except you forgot to mention that the PA PUC already denied your application for this project the first time it was ordered by PJM. Ordering it a second time does not change the PA PUC's mind. And it certainly does not change the minds of the impacted landowners who created massive opposition.

But, but, but....

The Rice-Ringgold 230kV Route is the result of a robust siting and outreach process which included input from landowners, local officials, and key stakeholders on a multitude of study segments. The proposed route will be 130 feet in width, parallels existing rights-of-way including interstates, roads,railroads, and existing transmission lines for 42% of its length, and best minimizes potential impacts to the natural and human environments. The extensive Siting Study is available for review under PA PUC docket A-2017-2640200. In addition, the Proposing Entity has been able to obtain 70% of the required ROW, via option agreements or easements, for the Rice-Ringgold 230kV line route.

Oh, you mean the PA PUC docket where they denied your first permit application? The landowners refused to go along with the transmission plan. What good is their "input" when it consisted of a firm "no." And speaking of "robust" how many of those landowners have you consulted about bringing this project back from the dead? I'm going to bet it is ZERO. They will oppose this project again. Guaranteed.

But, but, but...

The project will use steel, monopole structures with foundations. The use of steel monopoles was determined during the siting of the Proposed Solution due to significant landowner opposition to lattice towers, particularly in agricultural areas.

That flat out never happened. Landowners objected to the project itself, not just the tower structures. The utility simply made up a landowner preference for monopoles. It's sort of like asking... would you rather be shot or stabbed?

As the Proposed Solution continues to move forward, representatives will continue to be available throughout construction to answer questions from landowners.

And that stops opposition how? Landowners have long ago stopped believing any of the lies the utility tells them.

The Peach Bottom - Doubs Route is mostly in rural areas. Northern portion of the route is located in southern Pennsylvania with rural and farmed properties and then the route heads to the west. The route is to the north and west of Westminster and then heads in a south-westerly direction to Doubs.

Rural people hate transmission at least as much (or more) than suburban/urban people. This is because those rural farm folk depend on their land to make a living. When portions of the land are removed from production and devoted to new transmission lines, it reduces the farm's income. Just think... what if a transmission line in your back yard took part of your paycheck away from you every pay day? Rural siting does not make a project more constructible.

PSE&G will coordinate all outreach, real estate-related requests, and efforts to identify environmental and non-environmental conditions affecting the properties along the proposed Project route. Working collaboratively with our internal Outreach Team, PSE&G will coordinate stakeholder engagement and public outreach with land acquisition planning. This level of collaboration will help to ensure proactive and cohesive stakeholder communications in order to better serve landowners and impacted individuals and entities. PSE&G contemplates the need for access roads and areas, as part of any lands to be acquired

PSEG has identified several properties that are suitable for this proposed solution. The Project Team has initiated contact with the property owners and will continue to work to acquire site control in the event of award. The Project Team will work with impacted stakeholders, municipalities, and local authorities to obtain the necessary property rights to construct and maintain its facilities. While this solution is located outside of PSE&G territory, PSE&G is committed to a transparent, timely, and efficient land rights acquisition process for any site control required. PSE&G intends to utilize the same land acquisition professionals from start to finish, ensuring landowners have the same team assigned to their negotiations throughout the process.

You get the same annoying land agent showing up unannounced at your home, and maybe your job, and calling you incessantly. Maybe they'll even contact other family members, neighbors or friends and ask them why you're resisting. Land agents are aggressive jerks. Having the same one bothering you is not a benefit.

Outreach is just another word for outrageous lies and one-way information. Any suggestions you make will be ignored. You will be promised all sorts of stuff (but never in writing). Reality is going to be very different.

It doesn't matter how much "information" you spew, landowners still don't want your project and will form a wave of opposition.

The greenfield transmission line between North Delta station and Northeast station will require an ROW with a width of 85 feet in residential areas and 100 feet farmland.

But it's the same project in both places! Why take more land if it's a farm? Do you think farmers have more to spare? Inequitable treatment fuels opposition.

ROW will be acquired to widen the existing transmission line corridor from 150 feet to 200 feet. Approximately 102 acres of additional ROW will be acquired, which is all privately owned. Negotiations with private landowners will be based on fair market values determined by a third-party appraiser. Negotiations with private landowners will be conducted by PPL ROW Agents and PPL contracted ROW agents.

That third-party appraiser? He's just another hired utility contractor paid to find what the utility wants him to find. He likely lives in another state and has never even set foot in your county. His job is to research land sale prices in your county and find the lowest ones he can so the utility can offer you rock bottom and tell you it is "fair market value." The utility only pays you for the value of the land in the easement. It does not pay damages to the remainder. It does not pay for decreased property value. It does not pay for permanent loss of income. This is nothing more than standard procedure for ROW acquisition. There's nothing special about it that makes it more likely the project can be constructed without opposition.

PPL Electric is committed to open communications and transparency throughout the project lifecycle. As such, PPL Electric develops a project-specific Community and Outreach Plan based on the unique conditions associated with each project. To communicate clearly and transparently, PPL Electric utilizes a wide variety of strategies including, in-person meetings with local municipalities and regulators, direct mail, project websites, fact sheets, frequently asked questions, and public open houses. For example, during previous projects, PPL Electric has developed a strategic public outreach program that served as the cornerstone of project success. The program included soliciting input from, and providing timely updates to, external stakeholders from the onset of the project through to completion. This was achieved using face to face meetings, direct mailings, multiple rounds of open houses, fact sheets, press releases and an interactive website.

Sounds just like every other transmission "outreach plan." It's a flurry of secret gladhanding meetings with public officials, a lot of lies, and a complete lack of compromise. Landowners aren't fooled by this. Opposition will develop. There was never a "success." Landowners were harmed and they hate you.

Most high-voltage transmission projects will require a state siting approval. To begin the siting approval process, Proposer plans to hold pre-application meetings with the regulatory agency to introduce Proposer and the Project, as well as confirm its understanding of the process. Shortly thereafter, Proposer will simultaneously begin collecting siting data and start its outreach efforts so that public siting input is incorporated at the earliest stages of the Project. Once the Proposer identifies a preferred site/route and at least one viable alternative site/route, Proposer will carry out environmental and detailed engineering work in order to establish a highly- detailed Project plan to support the siting applications.

Oh yes, secret meetings with their friends at the regulatory commission before they file an application and before the landowner or the public knows about it. "The earliest stages of the project" has long passed by the time the public finds out about it and starts making suggestions for alternatives. That's the one thing that scares these clowns the most... you finding out about their plans before they want you to know... and trying to change the project in publicly beneficial ways. There are many ways to build transmission (or not), but the utility wants to do it THEIR way on YOUR property and they doesn't want to hear any suggestions from you.

And finally, here's the ultimate word salad about "robust public outreach" that only begins after all the important decisions have been made and the only role left for impacted landowners and the public is to comply. This is how opposition forms. Landowners matter!

The Company is committed to working with all interested stakeholders through a robust public outreach program to address/respond to community concerns and inform the public about the project to the greatest extent practicable. The Company believes a well-designed public outreach program can have numerous benefits, including fostering a cooperative relationship with landowners and other stakeholders, expediting the regulatory permitting process, and assisting with project development. In general, the purpose of the community outreach plan is to gain community support for the project. In the affected communities, the Company’s public outreach plan will educate the public and relevant stakeholders on specific project details to enable timely regulatory approvals and construction activities. Elements of the public outreach plan will include the following:1) Identify potential issues at an early stage by engagement with key community stakeholders at the outset; 2) Broaden the community engagement process to identify potential and relevant community benefits that can facilitate community support for the proposed project; 3) Develop a broad base of community support for the proposed project before the regulatory agencies; and 4) Develop a comprehensive administrative record documenting the community outreach process that can be presented to the regulatory agency or, in the event of a legal challenge, to the appropriate court. The outreach plan proposes to dedicate considerable time and resources in engaging the community, and specifically the affected community during the planning process to identify highly sensitive areas that have the least amount of cultural, environmental, and social impacts on the community. The plans will reflect avoidance of impacts rather than mitigation. However, in some cases, if avoidance is not possible, then the Company will involve the community in providing appropriate and practical mitigation measures. The Company will commence its public outreach activities following project award.

Landowners will NEVER cooperate or support the transmission project. This old public relations schtick has been tried over and over again and it is always a miserable failure that starts a wildfire of opposition that makes a transmission project unconstructible.

"Community benefits"? What's that? It's rewarding the larger community unaffected by the transmission project with trinkets and gifts for their cooperation. The "community" loses nothing and makes no sacrifice. It's all gain and no pain. The landowner, however, takes one for the team and is not comforted at all by the new library across town. "Community benefits" attempts to split your community into sacrificial lambs and greedy pigs. Landowners must be compensated by law because they are losing something tangible. "The Community" isn't compensated because it's not losing anything. There's a reason for that. Not all communities can be bribed to throw their neighbors under the bus. In fact, it may actually increase opposition.

This is the reality that PJM does not want to hear. It prefers to live in the land of lies created by the transmission companies where it can claim plausible deniability because the transmission companies filled their proposals with lies about constructibility.

Isn't it time you gave them a little reality so that they have to evaluate these projects honestly?

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New FirstEnergy Transmission Proposal at PJM Interconnection

8/15/2023

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Here it is... all in one place.

2023_firstenergy_transmission_plan.pdf
File Size:	264 kb
File Type:	pdf

Download File

If you've been looking for more information about FirstEnergy's proposal for TWO new 500kV transmission lines from northwestern West Virginia to suburban Maryland, this is all the information currently available.

Spread the word!

PJM is currently evaluating 72 transmission proposals to find the ones it thinks will work best to bring more electricity to power more data centers in Northern Virginia. FirstEnergy's proposals oh so conveniently supply coal-fired electricity from their Ft. Martin and Harrison power stations in northern West Virginia.

PJM is expected to finish its evaluation in September and has promised to hold a special Transmission Expansion Advisory Committee Meeting in October to reveal its choices and discuss before it recommends approval from the PJM Board of Managers. Lots of PJM activity coming up for your participation. Keep checking back for more instructions!

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Game on, PJM!

8/9/2023

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I just sent the following to PJM TEAC facilitators Sami Abdulsalam and David Souder.

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).

As you might have guessed, I participated in yesterday's TEAC by telephone. It has been many years since I attended a PJM meeting or raided its free M&M dispensers (plain or peanut?). But PJM is now at the beginning of a new initiative that makes yesterday's Project Mountaineer look like child's play. PJM wants to import insane amounts of power from the east and the west to power new data centers in the DC-metro area. PJM received more than 70 proposals from greedy transmission developers to make this happen. Many of them simply recycled old projects (or parts of them) that were cancelled years ago, such as the old PATH project in Virginia, Maryland and the West Virginia eastern panhandle. Take a quick browse through these maps to get an idea of the magnitude.

As you read above, I asked where PJM might consult with the public about some of these projects while evaluating them to see how feasible they are before we waste another 10 years and hundreds of millions trying to build something impossible like PATH or MAPP or IEC. I was pretty much blown off and told that PJM does its own constructibility evaluations. In other words, comments from impacted communities are not part of the process. Because I continued to push, I was told to send a follow up email. This is the result.

Currently, anyone concerned about a PJM proposal is welcome to make comment at PJM TEAC meetings. You get unlimited time to speak over the phone at a PJM meeting, where you have a captive audience for your thoughts and ideas. What a great opportunity! All you have to do is sign up for a PJM account and register for the meeting of your choice. Call the phone number, and when the question part arrives, push a button. Instant audience. Of course, hearing unlimited public comment from hundreds of concerned people at each PJM TEAC is going to make the meetings just a bit longer. Soon, it's just going to be one long, continuous meeting where the commenters never stop making comments and the party never ends.

Or, PJM can find a constructive way to welcome and make use of public comment.

Next TEAC is September 5. Are you in?

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Fits of Fantasy

7/19/2023

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I think the phrase is actually flights of fantasy, but... well, you'll see.

Data centers. Have you ever really thought about them when you're poking around online and the world is at your fingertips? Probably not, but we have to have a place to store all our big data that we just can't seem to part with. We're full-blown digital hoarders.

Data centers use a huge amount of electricity, and they must have a steady supply 24/7, 365. Data centers depend on enormous backup generators (that run of fossil fuels) in the event of a power outage. Data centers require on demand, reliable power.

But this industry fit of fantasy proclaims that we can run data centers on 100% renewable power. No, we can't. We don't have the technology to produce on-demand supplies of electricity from 100% renewable generators. Wind and solar only run part of the time, when their fuel is made available by Mother Nature. A data center that relies 100% on wind and solar will 100% use its backup generators for at least 50% of the time. And doesn't that defeat the purpose of "clean energy" in the first place?

The fit of fantasy examines several data center clusters in the U.S., including the nation's largest data center market in Northern Virginia. Northern Virginia data centers operate on 94% fossil fuel electricity. 94%!!!! That's the type of power needed to power a 24/7 365 power hog like data centers.

But, never fear, this fit of fantasy thinks the problem can be solved by building new transmission. I'm going to guess the author hasn't bothered to examine PJM's recent competitive solicitation for new transmission projects to solve the issue of powering Northern Virginia's data center power suck. It looks like this.

One proposed solution simply imports more fossil fuel electricity from the Ohio Valley. That's sure to speed the "transition" (to 100% fossil fuel power). Other solutions pump fossil fuel electricity in from Pennsylvania. It's all about importing more fossil fuel electricity instead of building reliable renewable generators near the load. That's because, first of all, PJM can only order transmission, not generation, and second wind and solar cannot supply reliable power that will run a data center 24/7 365.

Where's the disconnect?

The superficial examination of how easy it will be to build new transmission is where this fantasy starts having fits.

Plans to transition U.S. data centers to renewable energy power sources are impeded by current utility transmission infrastructure. The main problems are outdated power lines, delays in planning and permitting for new transmission and distribution projects and supply chain bottlenecks. Upgrading existing transmission lines can take as long as three years, according to the Lawrence Berkeley National Laboratory, due to time-consuming regulatory hurdles, resulting in multi-million-dollar costs.

An electric line is just an empty extension cord, not plugged in to anything. Unplugged extension cords do not produce electricity. What you need is another plug -- a reliable generator on site. Having extra extension cords won't produce power if there's no place to plug them in. Not having enough extension cords is not the problem. "Time consuming regulatory hurdles" is something this author doesn't know anything about. There are no hurdles for simple rebuilds on existing rights-of-way. More extension cords are not the answer.

Upgrading power transmission infrastructure to accommodate renewable energy sources is a top priority for utility companies. Recently adopted federal legislation provides $2.5 billion in public funding for this effort. Additionally, the Federal Energy Regulatory Commission (FERC) plans to study and address these ongoing issues. Utility companies are cooperating with regulators, city officials, operators and developers throughout the U.S. to improve connectivity.

Do you have any idea how much "power transmission infrastructure" costs? A good sized transmission project that connects renewable energy resources easily costs MORE THAN $2.5 billion. Qu'est-ce que "public funding"? There's no such thing. What they meant to say is TAXPAYER FUNDING by people like you. This legislation won't do anything but complicate things. How many times has the federal government run to the rescue with handfuls of cash and solved a problem efficiently and cheaply? FERC plans to study and address them? How? Do tell! I'm betting you don't even have a ghost of an idea.

This report highlights select regional data center markets that are working to advance renewable energy power availability and solve transmission and distribution issues. These markets all depend on local renewable energy sources and are at the forefront of a transition necessary for the data center industry to grow on a sustainable basis.

WTH? These markets depend on local renewable energy sources? Where are they going to put millions of acres of solar panels and wind turbines in crowded Northern Virginia when every square inch of available real estate is covered with data centers, warehouses, and urban sprawl? What you're depending on is faked "plans" by utilities checking the politically correct boxes while raking in a huge pile of money. Dominion doesn't give a fig about the environment, or your data center. It only loves money. Dominion will say or do anything, even if it knows what it is saying is impossible, as long as foolish data center companies enable bigger profits for Dominion.

The data center industry cannot grow on a sustainable basis unless they starting building nuclear plants inside the data centers.

Fits of fantasy. No matter how much fiction you write, you cannot force it into being.

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PJM's Altered Reality

PJM Selects New Transmission Scenarios

Spin Studies

Is PJM's Competitive Transmission Process Rigged?

The Haves And The Have Nots

What Will Be On New PJM Lines?

PJM's Implausible Deniability

New FirstEnergy Transmission Proposal at PJM Interconnection

Game on, PJM!

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