Yesterday, I took another ride on PJM's Gaslight Express, also known as the Transmission Expansion Advisory Committee meeting.  There's just something exhausting about an 8 hour meeting where automatons read out loud from documents you've already read to yourself.  When followed by Q&A that one participant likened to "nailing jello to the wall," you can lose all will to live. Thank goodness that farce is over for the time being!

Yesterday's meeting began with a speech by someone named Susan.  Susan did not have a last name or a job title (although we are required to say our names and affiliations each time we speak during a meeting).  Susan must be quite famous, like Cher, or Prince, although I've never heard of her in the 15 years I've been doing transmission.  Susan said that poor PJM has a problem because too much coal/gas generation is closing down in Eastern PJM and solar is not replacing it "one for one."  In other words, shutting down an 800 MW coal-fired plant in Baltimore is NOT being replaced with solar (or wind or storage or any other renewable).  Therefore, the only thing PJM can do is build transmission.

When I "asked a question" and reframed what Susan said to apply to the entire PJM region, a different PJM guy jumped in to say that was wrong.  Why was it only wrong when I said it and not the famous Susan?  Is it me?  Is it you?  Or are we all going to sit here in the dark in 10 years and say, "We should have listened to Susan!"  I stated that PJM is building transmission to existing coal and gas plants in WV and PA in order to replace the generation that is shutting down in Baltimore.  This is a game of hot potato, because the generation in WV and PA will soon follow the generation in Baltimore as we head further down the "clean energy" path.  At some point, there will be NO generation left.  What happens then?

PJM changed its tune and, according to Loudoun Now,

Seiler said they were not replacing coal fire generation with coal fire generation from somewhere else.“It’s actually coming from the entire region that includes a mixture of fuel types including wind, solar, batteries, combined cycle gas units, and nuclear power plants as well,” he said.

Except there is not enough wind, solar and batteries in any of the places the new lines go to replace the coal fired generation, just like there wasn't enough of it to replace the generation that closed in Baltimore.  Here's PJM's current fuel mix:

As usual, PJM's load is sucking up the juice produced by coal, gas and nuclear, just the kind of resources that WV and PA are producing in excess.  Baltimore is only producing solar anymore.  So, don't tell me that Baltimore is replacing its coal with solar and wind from WV and PA.  It's just not believable and it doesn't even make sense.  It's nothing but gaslighting.

I asked the age of the 500 kV transmission line in my neighborhood that FirstEnergy is going to do some work on soon.  FirstEnergy will be replacing some old station equipment that doesn't function correctly anymore.  I wondered if the entire line, including the lines (conductor), maybe could use some updating to increase its capacity.  FirstEnergy has no idea of the age of one of its largest transmission assets.  Shut down that discussion, and turn up the gas.

I asked a series of questions about several of the PJM projects in this plan.  They were simple questions that deserved simple answers.  Instead, I got at least 10 minutes of double speak and still don't know the answers I was seeking.

First, I wanted to know how many high-voltage transmission lines currently exist in the Doubs-Goose Creek transmission line corridor in Frederick and Montgomery Counties, Maryland, and how many would be added by PJM's plan.  Existing now:  1- 500kV line and 2- 230kV lines.  After PJM's new plan:  2-500kV lines and 1- 230kV line.  Maybe.  I'm really not sure because the gas was turned up so high it was hard to find an answer in the toxic cloud.  I asked this question because PJM has insinuated that the greenfield 500kV line (Project 853) through Western Loudoun may have to be re-routed east onto Doubs-Goose Creek.  If that happens, the corridor would have 3- 500kV lines and one or 2- 230kV lines.  That's like over 2000kV of electricity in one corridor that may be 250 ft. wide at the most.  This corridor runs through private property, next to homes, schools, and other parts of the built community in Frederick and Montgomery Counties, MD.  The people who live there aren't going to like it anymore than the folks in Western Loudoun like a single 500kV line.  I asked why PJM thought moving the line from VA to MD because of opposition would somehow create a different result?  And that's when PJM really turned up the gas and I lost consciousness.

I asked what PJM was ALREADY building between Aspen and Golden due to the fact that it was not only in PJM's most recent package of projects, but also being actively opposed by residents of Lansdowne.  PJM started talking about Mars and Wishing Star and a different immediate need project already in the works, but said that project had nothing to do with Aspen to Golden.  That's good news for the NoTowerson7 folks I suppose... they are opposing a transmission project that doesn't exist!  I hope somebody lets Dominion know so they stop trying to build it.  Or maybe they also need some of PJM's gas?

And finally, I asked about the new 500kV transmission line across Jefferson County, WV.  As proposed by NextEra, it would expand the easement by 30 feet.  But since PJM has now awarded that project to FirstEnergy, is FirstEnergy held to that same amount of expansion, or can they expand the easement 50 feet, 100 feet, 500 feet?  I got a lot of nonsense in response that basically indicated that FirstEnergy can build whatever it wants, but PJM also said that FirstEnergy has promised them that it can do the rebuild WITHOUT EXPANDING THE EASEMENT AT ALL.  I guess FirstEnergy has their own supply of special gas because PJM acted like they believe that, even though I remember that we found out during PATH that the existing 138kV easement is only 75 feet.  I don't see a double-circuit 500/138kV on lattice towers fitting in there without easement expansion.  When FirstEnergy bid to install a new 500kV line on that corridor, they asked for a new 165 ft. easement.  But PJM chooses to believe whatever it wants to believe for now.

I also asked PJM when we would see the cost allocation table for these new projects.  PJM indicated that would either be part of the white paper for the Board, or issued shortly after the Board approves the projects.  Then, of course, I asked where we would find the white paper.  I think it may appear in the TEAC documents, but like all "answers" PJM issued yesterday, it was about as clear as mud.  The white paper will be written by the TEAC for the education of the Board of Managers before they make their decision on December 11.  In it, the TEAC makes its recommendation and summarizes the issues for the Board.  Do you think the Board is going to read all the other reports, and all the letters you have written, or just rely on the TEAC's summary to make its decision?  Pretend you're a busy Board member when you imagine this scenario.  The TEAC guys even gaslight their own Board of Managers to manipulate the decision they want.

That said, I hope everyone paid close attention to the nonsense Sami was spewing when "answering" my question about pushing the greenfield portion of 853 over onto the Doubs corridor.  I heard that such a re-routing is almost a given at this point... but maybe it was the gas.

I thought I was done asking questions, but I couldn't resist poking the guy giving detail about the 853 project in Jefferson County.  I explained the problem with expanding existing rights-of-way into the backyards of people who live along the existing line.  Expanding into their backyard is going to take their well, septic system, and anything else they have built in their own backyard because those things are not compatible with transmission easements.  But that was jumped on by the gaslighters, who pretended they did not understand the problem with calling new greenfield easements parallel to existing ones "brownfield."  I've brought this up endlessly!  The "answer" is that we cannot assume those things are going to happen, therefore they are not an issue.  Let's pretend they won't happen!  But they WILL happen.  I know at least one person for whom that is REAL right now.  But if PJM ignores it now, it would only surface later, when there's no chance to correct it.  That's what PJM prefers.  So there is going to be a long string of homes in Jefferson County without water or sewer, or both.  Essentially, these homes will no longer be suitable to live in.  What's the compensation for that and why would ratepayers have to pay for that routing error that could have been corrected from the beginning?

I could hear someone over the phone trying to ask a question who was being ignored.  Found out who it was and put her name in the webex queue.  She asked where the turning point for 853 from brownfield to greenfield was because she suspected it was in her front yard, based on the maps and narrative.  They turned up the gas for her, too, and pretended those details haven't been worked out.  If that's not worked out, how can any of these cost estimates be anywhere near accurate?  Good question!  FirstEnergy is building the brownfield part, and NextEra is building the greenfield part.  Where one stops and the other begins is a crucial fact for cost estimates.  She never did get an answer to her question.  She's just supposed to live in limbo until the utilities and PJM work this out sometime AFTER project approval by the Board of Managers.

Like trying to nail jello to the wall.  That's a perfect description for PJM's "stakeholder engagement."  They spew a bunch of nonsense but none of it is relevant or sensible.  And that summarizes the whole of yesterday's meeting.

PJM is not going to change its mind about these projects before sending them to the Board of Managers for approval.  I didn't expect any different.  My only reason for bothering with this meeting is to try to get some clarity on certain issues.  PJM couldn't even provide that.

Next up... the Board of Managers will make their decision on December 11.  The TEAC wants you to think that's all a done deal and that the Board will simply rubber stamp whatever TEAC asks for... because the lights will go out unless they do.  Is it really that simple?  Does the independent Board ever think for themselves?  Do they ever question the gaslit nonsense they are fed by the TEAC?  At least we'll get that question answered next week.

I am writing to express my strong opposition to PJM’s 2022 Window 3 RTEP “solution” that will put an enormous burden on PJM ratepayers in the Mid-Atlantic area. The expected $5.4 Billion dollar cost to be shouldered by ratepayers to support an industry that includes some of richest companies in the world is an abuse of PJM’s power.
At the September 5, 2023 TEAC meeting, I asked if PJM had engaged in conversations with Virginia state officials about their plans to advance dependable, dispatchable generation in Data Center Alley as an alternative to a transmission solution only approach. The negative, volatile reaction of your employees running the TEAC meeting was essentially to squash any and all ideas that PJM would ever have that type of conversation with state officials. Certainly, the Data Center Alley companies build of back-up generation on site in the form of diesel generators is apparently fine with Virginia officials. So again, please explain why PJM will not have that conversation? Your own Market Monitor has told PJM over and over again that a process to compare the building of generation vs. building transmission should already be in place.
The only two states in PJM’s Mid-Atlantic region that have excess generation capacity to send to Data Center Alley are Pennsylvania and West Virginia. What happens to PJM’s “solution” when the Biden Administration fulfills their promise to shut down all the coal-fired plants in the country? What happens when PA and WV are tapped out with their excess generation capacity? How close are we to that tipping point? Will this 2022 Window 3 solutions be for naught when there is no power to send?
Is PJM sure this time, that the transmission that you are ordering will be the last time that the same communities are asked to shoulder this burden? Wasn’t it just in 2017 and again in 2021, that the MD/PA border region in Harford County, MD and York County, PA experienced backbone transmission projects? What financial benefit does our area receive in tax revenues from Data Center Alley? NONE! If the State of Virginia wants to keep receiving the tax revenues from data center development, then they need to man up and build the necessary generation to support this type of development. The same communities should not be asked once again to shoulder this burden.
The reality is, that green energy cannot provide sufficient electricity to meet the needs of our Country at this time. States with ambitious green agendas are being disingenuous to their citizens. Shutting down reliable, dispatchable generation on the hope that wind, solar and battery storage can be effective in supplying electricity is a fool’s errand that will only increase electricity costs for ratepayers. ​

PJM knows that and should make it clear to the States that doing so will result in widespread loss of electricity for its 65 million ratepayers. Certainly, the 11-30-2023 OPSI letter you received clearly outlines the grave concerns associated with the 2022 Window 3 solutions and the need for reliable and affordable electricity for PJM ratepayers.
The PJM BOM should reject the 2022 Window 3 solution and look to find ways with the State of Virginia to build generation within the data center development areas. In addition, PJM should also find ways to protect the operation of our reliable, dispatchable generators until other technology has the capability to take its place.
Sincerely,
Patti Hankins Maryland Ratepayer 

The PJM TEAC’s project recommendation to solve 2022 Window 3 issues does a disservice to all of PJM’s 65 million ratepayers and you should not approve it.

PJM’s plan is unlikely to be completed and will result in higher electric rates
PJM does not have a backup plan for the possibility that one or more segments of its plan cannot be built. Upon questioning, PJM staff said it would leave that problem on the doorstep of the designated entities. When certain segments are not approved, it makes other segments unnecessary. PJM staff is behaving like a Pollyanna, refusing to acknowledge the certainty that its plan cannot be fully constructed as proposed. This could lead to abandoned projects and increased rates for consumers, who will be forced to pay for project segments that never connect and are never built.
PJM staff has not shared any backup plan to maintain reliability and/or serve new load in the event that the recommended projects are not built by the targeted in-service dates. As more baseload generation retires prematurely but is not replaced with equivalent new generation, PJM is pushed closer and closer to grid failure. PJM would not be realistic, or even erring on the side of caution, to ensure continued reliability by relying solely on a massive new transmission build out that has an unlikely chance of success.
In addition, PJM staff’s assignment of hard to site greenfield projects to non-incumbents will only delay and complicate approvals. It is likely these projects cannot be built at all, and certainly not by entities unfamiliar with the impacted communities and state regulators involved. Like any transmission project on new easements, greenfield projects have a very low chance of approval and an almost certain chance of creating entrenched community and political opposition that leads to delay and abandonment.
The recommended plan is indisputably PJM’s biggest transmission endeavor to date. PJM’s recent track record of getting big projects approved and built is shockingly poor. Beginning with the PATH and MAPP project cancellations in 2012, several other large PJM projects have since been rejected and abandoned. There was the Monmouth County Reliability Project, rejected by the NJ BPU in 2018. There was the Transource Independence Energy Connection, rejected by the PA PUC in 2021. Community and political opposition drove all of these cancellations.
The shedding of over 11,000 MW of baseload generation combined with more than 7,500 MW of new data center load is a serious threat to not only the reliability of the grid, but to the pocketbooks of the 65 million consumers who depend on it. It’s the biggest threat PJM has ever faced. Such an enormous problem deserves a new approach. The new data centers in Northern Virginia provide benefit to some of the richest companies in the world, such as Amazon, Google and Facebook. The closing of baseload generators stems from the energy policies of certain states. But yet the entire region is being asked to fund a solution to this grid emergency created by the powerful few. It is unjust and unreasonable to place the costs and the impacts on portions of the region that will not benefit. If current planning and cost allocation rules require this travesty, then it’s time to change them because they have become unjust and unreasonable.
The Law of the Instrument is a cognitive bias that is often expressed with the phrase, "If the only tool you have is a hammer, every problem looks like a nail.” PJM’s transmission planning epitomizes the Law of the Instrument because it prioritizes transmission as the only possible solution. The PJM Market Monitor has been recommending for the past 10 years that PJM create “...a mechanism to permit a direct comparison, or competition, between transmission and generation alternatives, including which alternative is less costly and who bears the risks associated with each alternative.” (2023 Quarterly State of the Market Report for PJM: January through September, Pg. 719). PJM does not allow the market to work to drive the building of new generation in areas experiencing increased load or generation retirements. If PJM had adopted the Market Monitor’s recommendation in 2013, PJM wouldn’t be planning more than $5B worth of transmission as the only solution to solve generation retirements and data center load. PJM must now develop the recommended mechanism in order to allow for beneficial competition between transmission and generation to solve 2022 Window 3. The Board of Managers should reject the TEAC recommendation and order a new evaluation that compares new generation near load with new transmission to other states in the region in order to find the least cost, least impactful, solution for PJM’s ratepayers.

PJM’s Plan is Destructive to Clean Energy and Environmental Justice Progress
While governments and consumers are asking for cleaner power generation, PJM’s plan doubles down on fossil fuels by importing excess electricity from West Virginia and Pennsylvania. West Virginia and Pennsylvania still produce the majority of their electricity from coal and natural gas. Instead of cleaning up the environment in PJM states, increased dependence on fossil fuels actually increases pollution and regional haze. It makes no sense to close coal-fired plants in Maryland like Brandon Shores and Wagner, only to replace their supply with electricity from coal-fired plants in West Virginia. It’s just as dirty, except it’s in someone else’s back yard and requires $5B of new transmission that consumers will have to pay for.
By building new transmission to old coal plants, PJM ignores the questionable longevity of these existing generators under the EPA’s Clean Power Plan, or other state or federal clean energy legislation. The generators may retire before the new transmission line to the west is completed; creating a stranded asset that is not useful to the ratepayers who continue to pay for it. Certainly the expected life of the coal-fired generators is much shorter than the 40-year life of new transmission. New transmission to old power stations on the verge of retirement makes no sense.
PJM’s plan takes a huge step backwards for environmental justice and equity. While wealthy counties in the Washington, D.C. suburbs would increase their economic development, jobs and prosperity with new energy hog data centers, struggling communities in West Virginia face increased pollution from mining and burning coal to produce additional electricity to serve those data centers. West Virginians would also sacrifice their homes and working land to make way for new transmission lines to serve the data centers. As the final insult, West Virginia’s consumers would have to pay for PJM’s new transmission plan that hurts their own communities while benefitting politically connected communities elsewhere.
There has to be a better solution. This plan should be sent back to the TEAC with recommendations to develop a different plan that relies on new generation sources closer to load and produces less burden on communities that will not benefit, and therefore stands a much better chance of being approved and built in time to maintain reliability and serve new customers.
Any new transmission that cannot be constructed fully in existing rights-of-way must be buried within existing road, rail or other public rights-of-way. PJM must consider the use of buried HVDC along existing transportation corridors to transmit electricity from substations in the west, such as 502 Junction, to new substations in Loudoun County’s Data Center Alley. HVDC transmits more power with less line loss in situations where electricity is transmitted long distances without serving load along the way. Buried HVDC on existing rights-of-way reduces project risk from community opposition, delay, or cancellation. While buried HVDC may be more expensive up front, it produces considerable savings. Buried HVDC on existing easements does not require new land acquisition. It avoids public relations and state regulatory battles fueled by community opposition. Time is money and a project that can be built on time and on budget because there is no opposition creates an enormous savings. After buried HVDC is constructed on existing road and rail easements, it does not require perpetual vegetation management, and it is not subject to weather-related damage or sabotage. Outages are less frequent than with overhead transmission and the cost of just one outage caused by overhead line vulnerabilities can easily exceed the increased costs of constructing buried HVDC. Many transmission developers have found that the savings produced by buried HVDC obviates its higher up front cost.

PJM’s TEAC Process
PJM’s Transmission Expansion Advisory Committee has engaged in what I believe to be a deliberate campaign to misrepresent new transmission routes, while simultaneously attempting to thwart participation by non-member stakeholders. PJM’s maps of proposed projects continually misrepresented new greenfield transmission line proposals as brownfield. Maps were also inaccurate and did not match the written route narratives submitted by the proposing entities. PJM went through so many revisions to its maps that I have lost count. Is PJM’s mapping staff really that incompetent, or was the map debacle just a ruse to draw attention to the maps, instead of substantive comment?  I tried to discuss the issue of new easements adjacent to existing transmission lines at length with PJM staff because they insisted these new developments are “brownfield” developments. Brownfield developments are those that are entirely contained on existing easements. Anything that requires new easements, in whole or in part, is greenfield development. Adding additional transmission to existing corridors can actually be more destructive than greenfield routes in areas without existing transmission. The reason for this is that new communities have been built up along the edges of transmission easements that have existed for a number of years, even decades. The existing easements are hemmed in on both sides by new homes, schools, fire stations, churches, businesses, parks, and other developments. Creating a new transmission corridor on a new easement directly adjacent to the existing corridor will require the destruction of the existing community. This is not brownfield development. In contrast, a new line on a greenfield easement can be carefully sited to avoid homes, schools, fire stations, churches, parks and businesses. Brownfield can be, and often is, more destructive to host communities than greenfield.
After my provision of a written example of destructive brownfield siting (along with aerial photo), PJM staff said that they would be creating a new category for the maps to differentiate greenfield next to existing lines from brownfield. This appeared in one set of maps, but has since been eliminated, with PJM reverting back to painting all its new corridors as “brownfield or next to existing ROW.” Who is PJM trying to fool with this misrepresentation? Is it the communities who will host new lines? Or is it the Board of Managers, who may approve new transmission projects without full knowledge of the destruction they may cause to impacted communities because they have been incorrectly informed that the majority of the projects are brownfield? PJM staff is making an incorrect presumption that expanding existing corridors with new easements is preferable to greenfield lines, a view that is not shared by host communities. Since all opposition stems from community impact, PJM’s incorrect presumption does not serve to lessen opposition. It only serves to misinform the Board of Managers.
At the August TEAC meeting, I asked how impacted communities could share vital information about new or expanded easements that could be incorporated into the constructability reports to inform determination of risk. I was told that the public could comment verbally during PJM’s monthly TEAC meetings, a process that is not user friendly. Many people had difficulty signing up for TEAC meetings, and even when they managed to crack that nut, they were faced with sitting through many hours of the meeting waiting for an opportunity to comment, as the discussion of these new projects was always the last item on the agenda. I asked that PJM accept written comment from the public instead. PJM staff either did not answer my emails, or took weeks to do so. By the time PJM staff finally agreed to accept written comments, they told me we needed to hurry up and submit comments because the contractor was finalizing its constructability report. PJM staff managed to delay long enough to prevent all but the most determined commenters from weighing in. This is not an open and inclusive stakeholder process. In fact, it thwarts stakeholder participation.
Once the constructability studies were completed, PJM staff refused to share them, preferring to share only a table with risk determinations, and not the considerations that went into them. It appears that even that table has been manipulated to change the results presented from meeting to meeting, with risk determinations changing without notice or explanation. I believe that the constructability studies are just as manipulated as the rest of PJM’s process and urge the Board of Managers to review them carefully. PJM has recommended some of the riskiest projects for the Board’s approval. Someone needs to ask them why.

Local impacts
The West project in Jefferson County, WV was presented as a preferred solution submitted by NextEra Energy Transmission to wreck and rebuild an existing 138kV line underneath a new 500kV transmission project. As proposed, this project would expand the existing easement and construct new, larger lattice towers. It was stated that this project would deviate from the existing 138kV easement in certain areas and create a completely new easement for the new 500kV line. This proposal was never accurately represented on PJM’s maps, which characterized the entire project in Jefferson County as brownfield. At the Oct. 31 TEAC, PJM staff reassigned the project to FirstEnergy, without explanation. We in Jefferson County cannot determine how FirstEnergy will approach it, how much existing easements must be expanded, or where new easements are expected to go. FirstEnergy has been awarded a project it can create in the future to suit its needs, not one that has been properly evaluated and shared with the public.
The existing FirstEnergy 138kV transmission line running across Jefferson County from west to east has been in place for decades. In some areas, it parallels an existing 500kV line owned by Dominion that was rebuilt, completely within the existing easement, around 2012. Since the original construction of the lines on this combined right-of-way decades ago, new development has been built bordering it, limiting the ability to expand without causing considerable destruction of the built community. The landowners along the easement don’t consider this easement expansion and addition of larger structures to be brownfield development.
FirstEnergy’s Transmission Rights-of-Way Restrictions prohibit the following items in its easements: buildings, lighting fixtures, signs, billboards, swimming pools, decks, flag posts, sheds, barns, garages, playgrounds, fences or other structures. As well, septic systems, leach beds, and/ or wells are not permitted within a FirstEnergy transmission right-of-way. Expanded easements will undoubtedly run into these structures on adjoining property, requiring their removal. Depending on the size of the lot, it may not be possible to move or reconstruct them on the remainder. Expanding the existing easement will cause considerable damage to host properties.
Several new utility-scale solar generation facilities have been approved adjacent to the existing easement, along with an interconnection to the 138kV line. Some of these facilities are currently being developed, with panels constructed directly adjacent to the existing easement. Depending on the expansion of the easement, many brand new panels may have to be removed. In addition, the existing 138kV line will have to be taken out of service for extended periods of time to allow for the demolition and rebuild. When asked how these generators would be able to transmit the energy they produce while the transmission project is offline, PJM staff did not have an answer.
During its Oct. 3 TEAC, PJM staff indicated that they had failed to recommend certain proposed projects due to historic opposition to a previous transmission project in the same area (TrAILCo). However, PJM’s consideration of historic opposition was not applied equally to other areas that have successfully opposed new transmission in the past. Jefferson County formed vehement and entrenched opposition to the PATH project between 2008-2012. That opposition was a factor in the PATH’s project’s ultimate cancellation by PJM. The proposed PATH project used the exact same route through Jefferson County that is now being recommended for PJM’s new 500-kV project. A dozen years is not long enough for impacted communities to forget what happened last time. The only difference between the TrAILCo opposition in Virginia in 2007 and the PATH opposition in West Virginia in 2010 is the deep pockets and political connections of the opposing community. Is PJM afraid of engaging important, well-funded opposition in one state, and instead preferring to engage less politically connected and funded opposition in another? This is the epitome of environmental injustice, where disadvantaged communities are expected to accept damaging new infrastructure over and over again.
The proposed 500-kV project in Jefferson County is not on a direct route to the data centers in Northern Virginia that need a new power supply. Instead it is an unnecessary and destructive diversion that seems to capitalize on an existing transmission line crossing of the Appalachian Trail near the Virginia border. If not for that existing crossing, a more direct route for this project could be utilized. Jefferson County is being sacrificed to prevent a new crossing over the Trail even being proposed. Perhaps PJM believes that it will attract less opposition by destroying Jefferson County than it would for designated entities to ask the National Park Service to permit a less costly and less invasive new crossing further south. We in Jefferson County object to having this project cross our county at all.

​Conclusion
I ask that PJM’s Board of Managers short-circuit PJM staff’s double-time march toward approval of these new projects on December 11 and allow additional time for meaningful public consultation and comment carried out through a user-friendly process. In addition, I ask that PJM present true and correct information about these projects, and their intended routes and risks, to both the public and the Board of Managers before approval. Please do not approve the recommended 2022 Window 3 projects on December 11.

Constructability?  Is that a word?  My internet spelling police hates it, but constructability is defined as:

PJM loves its constructability analyses to select a project from a pool of many options.  PJM pretends it's all so scientific and dependable.  But, is it really?

Here's PJM's Constructability and Financial Analysis Report.  I didn't expect it to be anywhere near correct or accurate, and I wasn't disappointed.  It's completely illogical to the point of demonstrating bias.  Why is it that PJM has selected some of the most risky projects to recommend for approval by its Board of Managers?  Here's what I mean (see page 115 of the report for larger image):

Out of this "west" group, PJM has selected the riskiest project, Proposal 853.  853 has two "high" risks, two "medium-high" risks, and two "medium" risks.  It's the riskiest one in the table.  So, maybe it's about costs?  Proposal 853 costs $1,195,240.  It's still more than the cost of Proposal 904 at $1,122,400.  It can't be based on price.  Just what DID motivate PJM to select 853 instead of 904 or one of the other projects on the table?

What is proposal 904?  It's the building of a new 765kV transmission line through a section of central Virginia.  904 connects the data centers to a huge inventory of fossil fuel generators in the Ohio River Valley using AEP's 765kV transmission network.   Significantly, proposal 904 keeps all the transmission necessary to serve Virginia's new data center build in Virginia.  The other proposals inflict the burden of serving Virginia's data centers on other surrounding states.  Keep that in mind as we examine these two competing proposals as PJM did in its Constructability report.

Project 853

Project 853 has medium-high constructability risks, while 904 has medium constructability risks.  Gee, no help there either.  904 is cheaper and less risky, but PJM still selected 853.

And then there's this tidbit... did you catch it the first time you read it?  

PJM KNOWS this project isn't going to happen the way it was proposed and recommended for approval.  PJM is already anticipating so much opposition to the new greenfield segment in Loudoun County that it will have to abandon this plan and move the proposed new 500kV transmission line over to an existing corridor between Doubs and Goose Creek.  What is that corridor?

The 853 project in Loudoun is represented by that green line.  The Doubs corridor is represented by that roughly parallel yellow line to the east.  Sounds like a solution, you think?  Think again!  PJM has also recommending work on the Doubs-Goose Creek corridor to add another 500kV line to its existing 500kV and 230kV lines.  In order to squeeze another 500kV line in there, PJM proposes to rebuild the existing 230kV line as a double circuit 230/500 kV line, and then add a second 500kV line.  Moving the 853 project over to the Doubs corridor would add a THIRD 500kV line to that existing corridor.  Would that be a double circuit 500/500 kV, in addition to a 230/500 kV double circuit?  Or would there be one 230/500 kV double circuit, and two separate 500 kV lines?  Either way, it will require significant expansion of the current easement through a heavily developed area of Frederick and Montgomery Counties (Maryland) and construct an unimaginable amount of power in that corridor (three 500kV circuits + one 230kV circuit).  Chances of success on this idea rate right up there with the survival of a snowball in Hell.  Which area is capable of forming bigger opposition?  Loudoun County or Frederick/Montgomery Counties?  Personally, I think it's a tie.  Either one is going to kill this project dead.  Remember, it's not about fighting each other to push the project off onto someone else, it's about stopping the bad project altogether.  Nobody wants this anywhere!

So, what did we learn from PJM's constructability analysis?  Not much.  PJM did not examine the gray areas of opposition that I did.  PJM pretty much ignored the possibility of opposition derailing their plans.  Dismissed!

But, we're not going away.  In fact, we're only going to get stronger.  I predict that this project will NEVER get built.  Maybe PJM should go back to the drawing board and take another look at project 904?  Why did they dismiss that project anyhow?  PJM never actually says.  In fact, after reading all of PJM's excuses, err I mean analyses, I came away more convinced than ever that this whole thing is a farce.  Some of the excuses for not selecting a project were so ridiculous, such as -- we didn't select this project because we selected a different project.  That's not a REASON for making a project selection.  I also got the idea that PJM is absolutely terrified of rich people opposition in certain areas of Northern Virginia.  PJM has bowed down to the wealthy and privileged due to their bad experience trying to route the TrAIL project through those areas.  PJM thinks it's a better idea to route its projects through disadvantaged areas that can't fight back (or so they think).  That kind of thinking is outrageous in this day and age of environmental and energy justice reform.  Add in the fact that PJM's new transmission lines are nothing but extension cords importing dirty, delicious, coal-fired electricity out of West Virginia and Pennsylvania and you've got a project idea that is dead on arrival when asking for federal help.

Stupid, stupid, stupid, on top of dumb, dumb, dumb, PJM!  It's obvious PJM has another agenda at work here and it's not providing needed electric service at the lowest cost.  Let's hope the PJM Board of Managers examines this farce carefully before making its decision on December 11.

PJM Interconnection has never been good at interacting with the regular people its projects impact.  Part of the problem is that the place is chock full of engineers and socially inept geeks, and the other part is that they think they don't have to explain themselves to you or anyone else.  Back around 2008, during the PATH transmission line fight, some public relations guy from PJM named Kerry Stroup told a local reporter here that "PJM answers to no one."  But PJM is NOT an omnipotent dictator.  PJM answers to the Federal Energy Regulatory Commission.  All the power PJM possesses comes courtesy of FERC.  If PJM doesn't follow its own FERC-approved planning rules, anyone can file a complaint at FERC.

After decades of digging a moat around itself in order to keep regular people out of its planning process, PJM's efforts have failed and they are now positively terrified of the ruckus you're about to cause.

Public relations has never been PJM's strong suit.  In fact, PJM's public relations effort has been almost non-existent.  PJM depends on the utilities it orders to build the projects to interact with the torches and pitchforks crowd later on, after there's no chance to influence the plan.  But now, because impacted people have found out about PJM's plans before the projects have been awarded, PJM has made a feeble attempt to inform you about its "role" in ordering the new transmission projects that concern you.

Here's PJM's recently released Role in Regional Planning/2022 RTEP Window 3 document.  You are supposed to read it and accept it, even though you may not agree, and even though PJM may have left out some important things.  Here's PJM again telling people that it answers to no one and that PJM must build these things ASAP or your lights are going to go out.  It's going to say the same things to your state utility commission when it appears as a witness for the utility that is assigned to build the project.

Think about that... PJM says it cannot deny service to a new customer (data centers) but if new transmission to serve these customers isn't built on PJM's timeline, then "load has to be dropped."  In other words, PJM will shut off service to certain customers.  You can bet it won't be the data centers.  So what PJM is really saying is that it is going to serve the new load and drop the old load.... unless you gladly welcome new transmission across your property, you selfish NIMBY.  Kind of makes your head hurt, right?  Remember, I said that PJM lacks public relations skill.

Here's the real answer that PJM isn't telling you... when a new customer asks the local utility for new service, the utility could certainly build new generators to produce the electricity for the new customers.  Building new generation is something that the state could require the utility to do.  Let's use Dominion as an example here because Dominion is the utility that serves the data centers.  Dominion could decide to build a new generator (or generators) near the data centers and ask the Virginia State Corporation Commission to approve it and assign costs to Dominion's customers.  But, with Virginia's "clean energy" goals enshrined into law, the chances that the VA SCC would approve a big, new baseload generator that could satisfy the data center's insatiable thirst for electricity are slim.  Nobody wants a new electric power plant in their neighborhood and solar, wind and other renewables can't supply the kind of on demand 24/7 power needed for data centers.  So Dominion and the Commonwealth of Virginia simply shrugged and passed the buck to PJM to find a solution to the reliability problem the new data centers have caused.  And this is the result.  You probably didn't envision this when Virginia passed its clean energy laws, but this is what happened because Virginia passed environmental goals that were NOT achievable when combined with the building of new energy-intensive data centers.  This is Virginia's problem and it's about time they own it, don't you think?

PJM handled the hot potato it received according to its existing rules.  PJM did not acknowledge that this is a new problem caused by state clean energy laws and out-of-control building.  PJM pretended that it was a transmission problem, not a generation problem.  Therefore, PJM sought out any usable generation in its region to solve Virginia's lack of power and designed new transmission line extension cords to plug it into the data center load.  PJM cannot order new generation to be built, it can only order transmission.  Therefore, when the only tool you have is a hammer, every problem looks like a nail.  Virginia could order new generation, but it chooses not to because new generation could make it impossible to achieve its clean energy goals.  Even the Federal Energy Regulatory Commission recently questioned whether new infrastructure caused by energy policies of certain states should be fully paid for by those states.  If Virginia had to pay for the entire $5B cost of this new transmission, perhaps building generation might be a cheaper alternative.  But Virginia thinks it can do it cheaper by choosing transmission that is cost allocated to other states that will not benefit from the data centers or clean energy laws.  

Ten years ago, PJM's independent Market Monitor suggested to PJM that it create a process by which new transmission is forced to compete with new generation to evaluate who would pay the costs and accept the risks of each alternative.  If PJM had only listened to the advice of its own expert, we'd be having a very different conversation right now.  It wouldn't sound like PJM's "Role" paper, it would sound more like this blog.

So, what can you do to change PJM's preferred plan?  The document gives you several options in the last couple of paragraphs.  The first is to participate in PJM's Transmission Expansion Advisory Committee meetings.  Been there, done that.  It's frustrating and exhausting.  At every turn, you are faced with the virtual moat PJM has constructed around its processes designed to keep regular people out.  PJM wants to make it really hard on you to participate.  If you do manage to get in, share your thoughts, and not give a damn what PJM thinks about you, prepare to be thwarted at every turn.  This is what many of us have experienced since August of this year.  The TEAC process for these projects is done.  PJM has made its recommendations despite everything that was said in its meetings.  Let's move along.

PJM's second suggestion is to send your comments to its Customer Service and Planning Departments.  Don't waste your time here, either.  PJM says it will "compile" these comments for the Board of Managers' perusal.  In other words, PJM will sanitize your comments so that they support its recommendations.  PJM only wants you to communicate with its Board of Managers through a filter it controls.  You might as well not even bother.

The third option is the one you should use.

Write directly to the Board.  Don't let PJM's TEAC filter your comments.  All that nonsense about "ex parte" communications is meant to scare you away from this option, but it doesn't mean anything.  So what if your comments are made public and posted on PJM's website?  SO WHAT?  Complete instructions for composing your letter to the Board of Managers can be found here.  Remember, you are writing to the Board -- Dave Anders is just the mailman.  Do not address your comments to Anders.

Deadline for comments to PJM's Board of Managers is Monday, December 4 (one week before the Board meets to consider approval of the projects on December 11).  PJM "forgot" to tell you about that in its "Role" paper.  Another Freudian slip that can derail your efforts.  It seems that PJM is more about trying to keep people out of its processes than it is about inclusion.  PJM doesn't care what you think and is going to do what it wants despite your best efforts.  If PJM is trying to steer you away from a letter to the Board of Managers, then you can bet that's your best option.  Maybe PJM is a little transparent after all... but not in a good way.

PJM Interconnection's solution to 2022 Window 3 transmission needs is comprised of a collection of new and upgraded 500kV transmission lines, along with a number of 230kV new lines and upgrades.  Why does this matter?  It's all about who pays.

PJM will assign project costs to different subregions of its territory according to its existing FERC-approved cost allocation rules.  As noted in a recent FERC Order, these rules are:

500kV lines are "Regional Facilities".  It is likely that the 230kV improvements will be "Necessary Lower Voltage Facilities."  Therefore, 50% of the cost of these new lines, estimated at $5.4B, will be allocated to ALL customers in the PJM region based on their load-ratio share.  The load-ratio share, in layman's terms, is the amount of PJM's total load used by each sub-region. Everyone who pays an electric bill in PJM will pay for their share of $2.7B of new transmission that is only necessary because of the building of new data centers in Northern Virginia and the closing of fossil fuel generation made necessary by the clean energy laws of certain states.  Although the reason for the lines is caused by only a portion of the region, everyone pays.

The other 50%, or $2.7B, of the costs will be allocated using the DFAX method which, in layman's terms, would be the specific sub-regions who use the new facilities.

This is set in stone and it cannot be changed unless PJM petitions FERC to change its cost allocation rules, or FERC takes the initiative to begin a proceeding to investigate electric rates that have become unjust and unreasonable. 

This cost allocation for PJM's new projects is not fair.  However, there is nothing you can do about it.

In a recent case, PJM filed a cost allocation document for recently approved projects intended to solve the closing of the Brandon Shores coal-fired plant in Baltimore.  Most of the cost was allocated to the sub-region around Baltimore that would use the new facilities, with some smaller portions assigned to other sub-regions.  Maryland regulators didn't like this.  They thought PJM should have found other solutions to the generator closing instead of a quickly approved transmission plan that cost nearly a billion dollars.  The Maryland regulators filed a protest in PJM's cost assignment FERC docket.  FERC said that since the cost allocation PJM made was in accord with PJM's existing, FERC-approved cost allocation rules, there was nothing they could do but approve it.

However, something interesting happened there.  Commissioner Mark Christie, a champion for electric ratepayers, said it wasn't fair, although he was obligated to approve it.  You should read his Concurrence because it may be a harbinger of things to come.

Although perhaps he did not find the cost allocation fair, Commissioner Christie chose to approve it because of the extreme risk of blackouts if the projects were delayed by a FERC investigation into the justness and reasonableness of PJM's cost allocation policies.

We are hobbled by PJM's bad policies and poor planning practices into a future that never allocates project costs fairly.  Will people complain about the upcoming cost allocation of PJM's 2022 Window 3 projects?  Absolutely.  But will FERC open an investigation, or will it be forced into another Hobson's choice?

Commissioner Christie shared his thoughts on how PJM's cost allocation rules have been rendered unjust and unreasonable by recent events.

A very relevant question that can also be applied to the current problem with PJM's 2022 Window 3.  Is the closing of more generation in certain states due to their climate laws, and the out-of-control building of new data centers that will only benefit one or two counties in Virginia, more of a public policy issue that should be paid for by the states/localities involved?  After all, it is their choice to put pressure on the amount of generation available in PJM.  Before passing laws that mandate the closing of existing generators, or before approving the building of new facilities that require extreme amounts of new electric supply, the states or localities responsible need to make sure that they still have adequate generation available to serve their load.  It is within their power to include a provision in their law that the closing of generators must be balanced with the building of new generators.  It is also within these state powers to make sure there is an adequate supply of generation in the state/locality to serve big, new electric customers like data centers, before approving them.  Instead, the states/localities are making these choices and leaving the consequences on the doorstep of others who have no vote on that state's policy choices.  This is not just and reasonable.  It's irresponsible.  It's selfish.  It pushes the consequences of a state's policy choices off on residents of other states.  In this same vein, do the voluntary policy choices of one state that requires new transmission also compel other states to use their eminent domain authority to take property from their state's residents to create easements for new transmission that serves the state making the selfish policy?  Why would I be asked to give up my property to build transmission that is caused by the building of data centers in Northern Virginia?

The "New Jersey" approach Commissioner Christie refers to is what's known as the "state agreement" approach to cost allocation.  It is a more recent construct that allows a state with a new public policy to voluntarily agree to shoulder all the costs of new transmission made necessary by their state policies.  This construct would prevent the unjust and unreasonable allocation of costs to states that did not cause the need for new transmission.  It's exactly where we find ourselves now.  The question is, would FERC open an investigation to correct PJM's current cost allocation for Window 3 to order it be allocated according to the public policy "state agreement" cost allocation approach?

Amen, Commissioner Christie!  Perhaps if they did, they'd stop prematurely shutting down fossil fuel generators before replacement generation is available.  And perhaps they'd stop approving new data centers without any viable means of powering them.  Instead, it's been left on the doorstep of all the other states in the PJM region to pay for, and house, transmission only made necessary by the thoughtless politics of certain states and localities.  This is not just and reasonable.

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?

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:

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!

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:

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"!

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.

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.

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.

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.

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.

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.

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.