Project title:  Mid-Atlantic Power Pathway (MAPP)

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

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

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

The four representatives nodded glumly.

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

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

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

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

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

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

Component title:  Meadow Brook - Doubs 500 kV Line

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

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

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

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

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

Black Oak - Doubs Greenfield 500kV Transmission Line

The project starts at Black Oak and heads east, paralleling the existing Black Oak - Bedington corridor, for ~6 miles. The line continues east for approximately 10 miles but strays away from the existing corridor due to infrastructure build up that has occurred around the corridor in this area. The line then heads southeast where it parallels the existing Hampshire to Ridgeley 138kV corridor for
approximately 16 miles. At this point the rebuild of the existing Hampshire to Stonewall 138kV line begins. The line will be upgraded to 500/138kV double circuit. The route follows this corridor until it meets up with the Stonewall Substation. At this point the route follows the existing Stonewall to Millville 138kV line. This line will be rebuilt to 500/138kV for its entire length. After the Millville substation the route follows the Millville to Doubs 138kV transmission line. This line is rebuilt to 500/138kV until a few spans outside of the Doubs substation. The 500kV circuit diverges from the 138kV centerline and connects into the 500kV Doubs substation. 

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.

The project will feature a right of way width of 175 feet for the green field portion of the project. The ROW will parallel existing corridor for the first ~31 miles (the greenfield portion). For the rebuild portion, the transmission line should fit in the existing corridor, however the transmission operator may decide to expand the right-of-way.

The proposed line will cross over the Black Oak to Bedington 500kV transmission line., The proposed line will cross over the Black Oak to Junction 138kV transmission line in two locations., The proposed line will cross over the Double Tollgate to Millville 138kV transmission line., The proposed line will cross over the Hampshire to Ridgeley 138kV transmission line in three locations., The proposed line will cross over the Mt Storm to Doubs 500kV transmission line in three locations.

The preliminary design for the single circuit transmission line utilizes tubular steel monopole structures with davit arms and v-string insulators in a delta configuration. The 500kV transmission line will utilize triangular spaced triple-bundle 1272 kcmil "Bittern" ACSS/TW MA3 conductor and two optical groundwires. The preliminary design for the double circuit 500/138kV transmission line utilizes tubular steel monopole structures with davit arms and v-string insulators in a delta configuration for the 500kV circuit and davit arms and I-string insulators in a horizontal configuration for the 138kV circuit. The 500kV transmission line will utilize triangular spaced triple-bundle 1272
kcmil "Bittern" ACSS/TW MA3 conductor and the 138kV transmission line will utilize a single 1272 kcmil "Bittern" ACSS/TW MA3. The structure will contain two optical groundwires.

45F1 - New Bartholow Substation - 12 terminal

AC Air Insulated Substation (AIS): New proposed 500 - 230 kV Substation. New Breaker and a Half (BAAH) 500 kV switchyard with three (3) bays, six (6) line terminals, twelve (12) 500kV, 5000A, 63kAIC Breakers, two (2) shunt 150 MVAR capacitor banks, one (1) -300 to +500 MVAR Static VAR Compensator (SVC), two (2) 500 - 230 kV transformer banks. New BAAH 230 kV switchyard with three (3) bays, six (6) line terminals, eleven (11) 230 kV, 5000A, 80 kAIC breakers.


Environmental constraints identified are manageable through implementation of an environmental avoidance, minimization, and mitigation strategy incorporated at the beginning of the routing/siting process. Co-location with existing utilities and other infrastructure was prioritized to the greatest extent practicable to minimize the environmental impact on the landscape. The proposed site crosses no national wetland inventory (NWI) wetlands or waterbodies. Fatal flaws have not been identified for proposed site. A cultural resource professional assisted with the siting process to identify and minimize impacts to known areas with historic sensitivities. An investigation to further identify and evaluate historic properties will be conducted to determine the presence of archaeologically or historically significant resources. Federally listed species have been identified with potential to occur in the area including listed bats, but no critical habitat was identified in the area of the substation site. If suitable habitat is identified or regulations change, agency coordination and species-specific surveys will occur. The project intends to adhere to tree removal seasonal restriction windows to avoid and minimize impacts to protected birds and bats, such as the northern long-eared bat, bald eagle, and other common raptors. Erosion control best management practices and setbacks will be engineered and utilized to prevent sedimentation from leaving the site for the protection of aquatic species and to avoid water quality impacts. There are no unique or sensitive environmental concerns or impacts with the proposed substation site that cannot be addressed.



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.

40AB1 - New two single circuit 230kV transmission lines from new Bartholow substation to new Grisham substation

General route description
The route is approximately 35 miles long. The component is two single circuit 230kV transmission lines to satisfy contingency requirements with utilizing a shared tower, however the towers can be designed in such a way that they are staggered and offset as to utilize the same ROW width as a double circuit 230kV transmission line. This provides the reliability of two single circuits and the permitting and constructability requirements similar to a single double circuit tower installation. Starting at a new dead-end structure at the new Bartholow substation, the route follows the existing Doubs - Brighton 500kV transmission ROW west - southwest for almost 8 miles, expanding the existing ROW. Minor adjustments may be needed for reducing impacts to buildings and residences. The route turns south where Bennet Creek intersects with the existing Doubs - Brighton 500kV transmission ROW and then routes on the eastern side of Sugarloaf Mountain for about 12 miles before then co-locating with the existing Doubs - Goose Creek 500KV transmission ROW. The route follows the existing transmission ROW on the eastern side, expanding the existing ROW, with slight deviation at the Leesburg Water Treatment Plant to avoid impact to operations at the facility. The route shifts underground on the north side of the Potomac River at the Leesburg Water Treatment Plant to reduce viewshed issues with crossing the river and spatial constraints on the south side of the river. The lines remain underground along the Doubs - Goose Creek 500kV ROW corridor until returning to overhead construction around the southeast corner of Crosstrail Blvd and Harry Byrd Hwy. The lines follow the Harry Byrd Hwy until turning south on the east side of Loudoun County Pkwy. The lines shift to the west side of Loudoun County Pkwy near the intersection with the Washington and Old Dominion trail to avoid conflicts with the 1757 Golf Club. The lines then share a common double circuit transmission tower for remaining duration of the route as it is less than 1 mile and is advantageous to utilize a double circuit tower for cost effectiveness.

The Project is located in the valley south of the Potomac River in Loudon County, traversing north through Montgomery and Frederick Counties in Maryland. A former agricultural region, Loudon County is now densely developed with commercial buildings and planned residential communities within commuting distance to Washington, D.C. Some industrial facilities are located to the south of the project area. Slopes are gentle, approximately 4%. The project terminates on the north side of the Potomac River in Frederick, Maryland where the topography is generally rolling. Elevations range from a low of near sea level along the Potomac River to about 875 feet. The river valley’s topography includes little steep terrain, but some steep gradients do exist adjacent to the river. These land elevations and the degree of slope have influenced land use in the watershed. The region’s relatively flat topography has made it easily accessible for development and agriculture in some areas next to the river and its tributaries.
The new right of way will have its own corridor for approximately 60% of the route length. The right of way will be an expansion of an existing transmission line corridor for approximately 35% of the route length. The right of way width will be 60 feet and it will accommodate 2-230kV lines. Approximately 5% of the route will be underground in narrower and congested areas where overhead construction was considered not feasible. Where underground transmission line segments are not sited by permits issued by the Authority Having Jurisdiction, a 40 ft wide right of way would be required for construction.

The proposed structures for each of the two proposed lines will be single circuit 230kV steel monopoles (TVVS-230) in a vertical conductor configuration. Any proposed dead-end structure will be a steel monopole. The portion of the route proposed to be underground will utilize duct bank construction with 3-cables per phase and splicing vaults at regular intervals.

43e - New 230kV transmission line from new Bartholow substation to existing Mt. Airy substation

The route is approximately 5 miles long. Starting a new deadend structure at the new Bartholow substation, the line routes northeast along the northside of the existing Conastone to Brighton 500kV transmission ROW. The line follows the existing ROW for about 4.25 miles before turning north, routing to the Mt Airy substation and then terminating at the substation.

The project is located in the Piedmont Upland portion of Maryland’s Frederick County. The Frederick Valley, through which the Monocacy flows, is nestled between the Catoctin Mountains to the west, and the lower Parrs Ridge to the east. The river valley’s topography includes little steep terrain, but some steep gradients do exist adjacent to the river. These land elevations and the degree of slope have influenced land use in the watershed. This section is underlain by metamorphic, igneous, and sedimentary materials, related to volcanic activity that occurred in Precambrian time. The region is comprised of rolling upland with herringbone texture and underlain with siltstones and quartzites.

The new right of way will be an expansion of an existing transmission line corridor for approximately 90% of the route length. The right of way will have its own corridor for approximately 10% of the route length. For approximately 1 mile, the right of way width will be 45 ft, for approximately 3.3 miles, the right of way will be 60 ft and will accommodate a portion of component 47ad within it. For approximately 0.5 miles the right of way will be 40 ft wide.
The majority, approximately 80% of the proposed structures will be single circuit 230kV steel monopoles (TVVS-230) in a vertical conductor configuration. Approximately 20% of the structures will be double circuit 230kV steel monopoles (TVVS-230DC) in a vertical conductor configuration. Any proposed dead-end structure will be a steel monopole.

47abc - New 500kV transmission line from new Goram substation to new Bartholow substation

The route is approximately 61 miles long. Starting a new dead end structure at the new Bartholow substation, the line routes northeast along the north side of the existing Brighton to Conastone 500kV transmission ROW. The line follows the existing ROW for about 49 miles and then turns north where the Otter Creek to Conastone 230kV transmission ROW coincides with the Conastone to Brighton 500kV transmission ROW. The line then follows along the west side of the Conastone to Otter Creek 230kV transmission ROW until it reaches the new Goram substation where it terminates.

The project is located in Maryland’s Frederick, Carroll and Baltimroe counties east of the Monocacy River. The Frederick Valley, through which the Monocacy flows, is nestled between the Catoctin Mountains to the west, and the lower Parrs Ridge to the east. The river valley’s topography includes little steep terrain, but some steep gradients do exist adjacent to the river. These land elevations and the degree of slope have influenced land use in the watershed. The region’s relatively flat topography has made it easily accessible for development and agriculture in some areas next to the river and its tributaries. The project continues north into the Piedmone Upland area of York County, Pennsylvania, characterized by rolling hills and valleys, generally with gentle to moderately steep slopes. However, steeper slopes with narrow valley bottoms dominate near the Susquehanna River. Many higher ridges are underlain by more resistant bedrock such as quartzite. This Section was formed by fluvial erosion and some peri-glacial wasting and averages about 600-700 feet in elevation. The drainage pattern of the area is considered to be dendritic. Slopes in the range of 0-8% are common throughout York County.

The proposed structures will be single circuit 500kV steel monopoles (TVVS-500) in a vertical delta configuration. Any proposed deadend structure will either be a 3-pole, one phase per pole configuration.

For the first time in recent history, PJM could face decreasing reserve margins should these trends – high load growth, increasing rates of generator retirements, and slower entry of new resources – continue. The amount of generation retirements appears to be more certain than the timely arrival of replacement generation resources, given that the quantity of retirements is codified in various policy objectives, while the impacts to the pace of new entry of the Inflation Reduction Act, post-pandemic supply chain issues, and other externalities are still not fully understood.

Maintaining an adequate level of generation resources, with the right operational and physical characteristics, is essential for PJM’s ability to serve electrical demand through the energy transition.
Our research highlights four trends below that we believe, in combination, present increasing reliability risks during the transition, due to a potential timing mismatch between resource retirements, load growth and the pace of new generation entry under a possible “low new entry” scenario:

The growth rate of electricity demand is likely to continue to increase from electrification coupled with the proliferation of high-demand data centers in the region.

Thermal generators are retiring at a rapid pace due to government and private sector policies as well as economics.

Retirements are at risk of outpacing the construction of new resources, due to a combination of industry forces, including siting and supply chain, whose long-term impacts are not fully known.

PJM’s interconnection queue is composed primarily of intermittent and limited-duration resources. Given the operating characteristics of these resources, we need multiple megawatts of these resources to replace 1 MW of thermal generation.

New Jersey officials hope to engage in “horse trading” with other PJM states over the cost allocation of transmission needed to meet their climate goals, a key state regulator said last week.

“The other clean energy states and PJM are looking at billions of dollars of transmission upgrades if we do it the way we’re doing it now, when we can meet all the needs of the entire PJM region at approximately the same price,” he said. “So there’s a lot of room for horse trading, if we can get the parties to the table.”

The SAA leaves New Jersey “almost in a hostage situation at the moment,” Silverman said. “The transmission projects that we are planning benefit many states in PJM; they will see lower production costs as a result of these upgrades. But because of the way the system works, we are solely responsible for the cost. That needs to change.”

This Proposed Solution is a resubmittal of the modified Independence Energy Connection (IEC) Project. The Proposed Solution consists of: (1) the IEC West Portion, which is comprised of approximately 29 miles of new double-circuit 230 kV AC overhead transmission line between the existing Potomac Edison Ringgold Substation in Washington County, Maryland to a new Rice Substation in Franklin County, Pennsylvania; and (2) the reconfigured IEC East Portion, which is primarily comprised of adding 230 kV AC overhead transmission lines between a new Furnace Run Substation in York County, Pennsylvania, and the existing BGE Conastone (via Baltimore County) and Graceton Substations in Harford County, Maryland.

Violations are small in magnitude and operating steps for a short term duration can mitigate issues pending further review in 2022 RTEP.

On the supply side in PJM, "we're seeing dramatic retirements" of coal-fired generation, with PJM retiring about 15 GW of coal in the next two years that it is not being replaced on a one-to-one basis, Thomas said.
The Midcontinent System Operator is experiencing a similar trend, with incremental generation resources being added that do not have the same reliability attributes as those being retired. "They are adding megawatts that are less valuable than the megawatts being retired, meaning they need to add significant multiples to replace what's being retired," he said.
In MISO, the accredited capacity being added goes down out to 2041, while the future load scenarios continue to go up.

"This is kind of a fascinating trend, and arguably not a sustainable trend, because what all these other regions are counting on is importing power from other areas of the country to make up the difference and that's a house of cards waiting to fall," Thomas said.
PJM is not one of the areas identified by the North American Electricity Reliability Corporation, an international regulatory authority, as having reliability concerns, but "they're coming in a big way," he said.
The PJM interconnection queue of resources planning to connect to the grid is 95%, if not more, wind and solar power resources, which is where the economic signals are right now.
"There is going to be very little to no new natural gas coming into the system and coal is going to continue to retire" with the nuclear power resources remaining because they are subsidized at the state and federal level, Thomas said.

One of the core tenets of the PJM capacity market is that in order to have capacity it must be deliverable. A megawatt of power on the system only has value if it can be delivered at peak demand periods, Thomas said.
PJM has been giving capacity accreditation to intermittent resources above their approved capacity injection rights levels, so these resources were selling capacity that was not deliverable, and that is a problem, he said.

The problematic aspect is consumers have been paying for capacity that has no value at peak, and suppliers "are getting boxed out of the market by these undeliverable megawatts," Thomas said.

Because we conclude that the Commission’s decision denying the Siting Applications and rescinding Transource’s provisional CPC was in accordance with Pennsylvania law, including Sections 1501 and 2805(a) of the Code, and Section 57.76(a) of the Regulations, and is supported by substantial, credited evidence
of record, we affirm.

As for Transource’s arguments that PJM’s determination of need would be binding due to this matter involving issues of interstate regional transmission subject to FERC oversight,the ALJ held that the Commission was obligated to make an independent determination based on Pennsylvania law. (Id.at 82, 86, 99-102.)The ALJ further observed that while FERC has exclusive jurisdiction over the interstate transmission of electric energy and wholesale electric process, that jurisdiction was limited to matters that are not subject to state regulation. (Id.at 85 (citing Section 824(a) of the Federal Power Act, 16 U.S.C. § 824(a)).) According to the ALJ, FERC recognized this limitation by stating that there is “longstanding state authority over certain matters that are relevant to transmission planning and expansion, such as matters relevant to siting, permitting, and construction” and that the FERC was in noway invoking “an exercise of authority over those specific substantive matters traditionally reserved to the states . . . .”(Id.(quoting Transmission Planning and Cost Allocation by Transmission Owning & Operating Pub.Utils., 76 Fed. Reg. ¶¶49,842, 49,861 (Aug. 11, 2011) (FERC Order No. 1000)).) This means, according to the ALJ, that FERC Order No. 1000 was “not intended to dictate substantive outcomes” or to allow FERC to “determine what needs to be built, where it needs to be built, and who needs to build it.” (Id.at 85 n.13 (quoting S.C. Pub. Serv. Auth. v. Fed. Energy Reg. Comm’n, 762 F.3d 41, 57-58 (D.C. Cir. 2014) (internal quotation marks and citation omitted)).)

As for the resolution of congestion in the APSRI, it does not appear that we have ever held that congestion, which is an economic consideration, is sufficient on its own to support need or necessity under Pennsylvania law.

It was not just OCA’s witness who criticized PJM’s cost-benefit analysis, but PJM’s own Independent Market Monitor who suggested that its market efficiency process, which includes the cost-benefit analysis, be reevaluated and that the actual costs and benefits of a project should be considered and not ignored in determining whether a market efficiency project is needed.

Although the Federal Power Act assigns
authority over regional transmission projects and interstate transmission needs to
FERC, it preserves state authority over siting and construction issues related to those
projects. See New York, 535 U.S. at 18-22 (explaining that 16 U.S.C. § 824 contains a
“‘clear and specific grant of jurisdiction’ to FERC” over interstate transmission service
and rates but “reserve[s] state powers” over other matters); S.C. Pub. Serv. Auth., 762
F.3d at 62

Transource brought its exceptions to the Recommended Decision before the full PAPUC, explaining in detail how the Recommended Decision misinterpreted FERC’s Order No. 1000, the meaning and weight of the PJM regional transmission planning process and decision on Project 9A, and the remaining role left for the PAPUC under state law in this context.

Pennsylvania made the choice to allow its utilities to join PJM, and it has reaped the benefits of being part of an integrated regional market. A consequence, however, is that the state has chosen to subordinate its police power interests in determining the need for new transmission projects to PJM’s determination of regional needs.

Under Pennsylvania law, the PAPUC’s order had immediate effect and is in force today, see 66 Pa. Cons. Stat. § 316, meaning that Transource is no longer a Pennsylvania-authorized public utility. Thus, Transource is no longer authorized to access lands for project assessment or to conduct appraisals.

Transource PA faces the prospect of imminent and irreparable harm as a result of the PAPUC’s order. Under its Designated Entity Agreement, Transource PA is required to acquire all state permits by September 30, 2021. A failure to meet that milestone date constitutes a breach of the agreement, which could result in the elimination of Project 9A from the Regional Transmission Expansion Plan and the termination of the agreement.

Transource PA requests such other and further relief as the Court may deem just and proper, including attorneys’ fees pursuant to 42 U.S.C.
§ 1988.