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.
Since the old PATH days, PJM has been required to revise its transmission planning to put long-lead needs out for bid in a competitive process. This is supposed to ensure that PJM's 65 million electric consumers pay a lower cost to construct the transmission they need. It is supposed to give independent transmission companies an opportunity to build projects cheaper than the utility that serves the impacted service area, which PJM refers to as "incumbents." This is supposed to produce lower electric bills for the consumers.
Does this really work as regulators intended? Over the years I have read about various complaints made by some of the competitors in PJM's competitive "Open Window" transmission bidding process claiming that their project was not treated fairly. I can see how they might come to that conclusion. I'm seriously starting to develop the opinion that PJM's competitive process is nothing more than Kabuki theater performed to hide uncompetitive behavior that produces financial windfalls for its incumbents. PJM's thumb is on the scale... maybe its whole body! This process cannot be be called transparent and competitive by any stretch of the imagination.
PJM's bidding windows present a problem to be solved with transmission. Any qualified entity may submit a proposal. PJM publicly posts redacted versions of all the proposals it receives for a window here. Select 2022 Window 3 from the list, to see an example. Next, PJM creates maps for each proposal because a picture is worth 1,000 words. However, PJM's map-making skills leave much to be desired. A creative Kindergarten could do a better job making accurate maps with finger paints. Already for Window 3, we have seen at least 5 different versions of maps for the proposals. I'm pretty sure the actual number is much higher than 5, but I haven't been keeping track. PJM has been notified of numerous additional errors in its newest version of the maps, however PJM has not corrected any of the errors, nor even responded to emails pointing them out.
Errors in PJM maps include drawing greenfield transmission lines as brownfield and making inaccurate designations between greenfield and brownfield; creating substations that are not part of any proposal; mismarking the voltage of new substations; leaving components off certain maps... and I could go on because the list of errors is as long as my arm.
PJM chooses not to explain itself, nor why it is attempting to create maps when it does not posses the proper skill set. Why doesn't PJM simply require the bidder to include an accurate map of its project components using certain parameters? It would have saved loads of time and money so far for Window 3.
PJM's maps include a completely different legend for each map in the Window 3 series. In some legends, a 765-kV substation is pink, in others, it is red. In some maps, the colors in the legends do not match the colors on the maps (go ahead, PJM, find the map where a color not on the legend appears -- I double dare you!). It is impossibly confusing to flip between the different maps to compare different proposals because the maps are not equal. Some are definitely manipulated and do NOT follow the written proposal or provide an accurate comparison to other proposals. It's almost like PJM is using the maps as an influencing tool.
Who is PJM trying to influence with its maps? I have asked PJM repeatedly what it does with these maps, and it has refused to answer. I'm going to assume they CAN'T answer because the answer may point to the real reason for this map-making incompetence and, perhaps, purposeful manipulation.
Here's another uncompetitive process at PJM... I wanted PJM to accept public comment regarding the proposals in Window 3 to compile for its feasibility study. The feasibility study looks at things like routes, environmental considerations, permitting, supply chain, cost of the project and the possibility of delay relating to community opposition to the proposal. Since a number of the proposals in Window 3 are basic recycling of old projects that were opposed and abandoned, I think it's only fair that the feasibility study acknowledge how and why these projects failed the first time and what may have changed that would make them successful this time around. But, PJM just gave me the run around instead of being appreciative of more information for its feasibility study. PJM would only receive verbal public comments at its monthly TEAC meetings, which requires a complicated and frustrating sign up and registration process and then several hours of waiting for the appropriate time to comment. And even then, PJM was rude and argumentative with the few people that managed to jump all these hurdles in order to comment. PJM preferred to argue over meeting procedures than the substantive issues. You blew it, PJM! This is not what an open and inclusive stakeholder process looks like! PJM has flat out refused to respond to my many attempts to find a way to accept, compile, and include public comments in its feasibility studies.
PJM says that it has hired a third-party contractor to prepare feasibility reports for its preferred scenarios. Will the contractor use the maps for its evaluation? If so, it will be evaluating something that is not accurate. An evaluation of an inaccurate proposal results in an inaccurate study. What a waste of time and money! Will the contractor use information about routing, permitting, environmental issues, and the possibility of opposition for its evaluation of the feasibility of the preferred scenario? Signs point to "no" since PJM is trying so hard to make sure any public comment stays far, far away from its contractor. If the contractor does not know about obstacles, then it won't include any in its feasibility report... smooth sailing ahead (while the people on the ground are swearing vehement opposition).
However, PJM also uses its feasibility reports and maps to inform its Board of Managers about the projects it is recommending for approval. Therefore, an inaccurate feasibility report gives an inaccurate picture of the recommended projects to the Board of Managers. How can the Board of Managers accurately evaluate recommended projects when the information they receive is inaccurate, or perhaps manipulated to influence their decision and lead them down the primrose path to making the decision to approve the recommended projects based on pure fiction?
I'm starting to believe PJM's "competitive" process is rigged through the manipulation of mapping and feasibility studies that drives PJM to select and approve a project unfairly.
Ball in your court, PJM.
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