Transource IEC opposition groups in Pennsylvania and Maryland have been slowly building for the past year. Their building, until recently, has flown under the radar of PJM Interconnection. Although PJM should have been paying attention (at least since it was first called to explain itself to the community at a local meeting last year), PJM chose to dismiss the opposition and tune it out. PJM has been listening only to its "member" Transource about project progress, and perhaps its perceptions have become skewed.
The Transource IEC project is not proposed for "undeveloped land," as the PJM Board was told in a pre-approval whitepaper. The Transource IEC project is proposed for fully-developed farmland, the majority of which is conserved. Who does your constructibility reports, PJM? Do you hold a seance and consult with utility planers from 1930? It's been many years since farmland was "undeveloped land" that has no value of its own and is seeking linear infrastructure projects to increase its value to the community. In fact, that's probably never been entirely true, although in the last century farmers were a politically disenfranchised population whose cleared, relatively flat land looked good for cheap, linear infrastructure at 30,000 feet. That's no longer true, especially in the eastern portion of the PJM region, where dwindling farmland has become a highly-prized commodity worthy of protection from cluttered over-development.
In addition, time has not been kind to the IEC. Like a parasitic houseguest who drinks all your beer and leaves hair on your soap, IEC has not become more valuable over time. It's become less valuable. And the people can't wait until it leaves for good. Market efficiency projects have a very short shelf life, which PJM obviously realized when it inked its agreement with Transource to build the IEC project. Now it's time to re-evaluate and send IEC to the great dump heap of failed projects.
Opposition to IEC is entrenched and wide spread. Cancellation is the only option.
The opposition recently voiced its reasons for cancelling the project in a letter to the PJM Board of Managers. This opposition was bolstered by additional letters to PJM from Pennsylvania Representatives Kristin Phillips Hill and Stan Saylor. In addition, Pennsylvania Public Utility Commission administrative law judges evaluating the project have become increasingly critical of the project, with Judge Elizabeth Barnes stating that she'd be "hard pressed" to approve the currently proposed project. Things are not going well for this project in Pennsylvania.
What's happening in Maryland? Governor Larry Hogan recently sent his own letter to PJM requesting the project be stopped until it can be re-evaluated or develop a new route using existing rights of way. Things aren't going so swell in Maryland, either.
Face it, PJM, this is the kiss of death for the Transource IEC. It's time to cancel the project and go back to the drawing board, presuming any actual "need" to relieve congestion still exists. And PJM has stated that a re-evaluation is in process and will be revealed at PJM's September TEAC meeting. What PJM's magic math giveth, PJM's magic math can subsequently taketh away.
The number of abandoned PJM projects is steadily increasing, and with generous FERC incentives to reimburse project costs in the event of cancellation, costs to ratepayers stemming from PJM failure are well into the hundreds of millions of dollars. Hundreds of millions of dollars added to the electric bills of PJM consumers for badly planned projects that never even get off the drawing board! You've got a big, big problem, PJM! Your planning process isn't working and desperately needs revision.
I'd start with PJM's subjective "constructibility analysis." There's no uniformity here. PJM needs to add some reality to its engineering staff. Just because something looks good ("robust" in PJM parlance) from an engineering standpoint, does not mean it should be constructed. Engineering needs to intersect with the reality of politics, regulation, land use, and community relations. That's the point of a "constructibility analysis." But there are no standards. While I have seen "constructibility" analyses that factor in possible opposition, others don't even mention it. Environmental factors are not the only thing that makes a project unable to be constructed as planned. In fact, environmental factors are the ones most nimbly avoided. It's those other factors that kill projects. It's high time PJM add some uniform standards to its "constructibility" analyses and require each greenfield project to be evaluated according to set standards. A greenfield project that is technically superior to a rebuild isn't so superior when it can't be built. In that case, a lesser rebuild is the solution that best serves consumers because it is more likely to actually get built.
And PJM needs to come out of hiding and own its work. Transmission owners hide behind PJM by claiming they're only following orders. PJM in turn hides behind transmission owners by turning a blind eye to what is actually happening with the projects it orders, and instead receiving all its information about a project's progress from the transmission owner. In order for PJM to have any credibility, it needs to actively participate in tracking project progress. PJM has long been in desperate need of an effective public relations program. Why is it that 99.9% of the consumers PJM serves have never heard of PJM? Because PJM likes it that way. Only when PJM realizes it exists to serve consumers (not simply member utilities) and develops a relationship with its consumers will its credibility and purpose be recognized by the consumers. When will PJM recognize the usefulness of doing its own community consultation and not leaving that task up to increasingly patronizing and arrogant transmission owners whose only concern is the amount of money it can make from a project?
You could do so much better, PJM, on a lot of fronts. But, for now, it's time to fall gracefully on your sword once again and cancel the Transource IEC project.
The Transource IEC project is not proposed for "undeveloped land," as the PJM Board was told in a pre-approval whitepaper. The Transource IEC project is proposed for fully-developed farmland, the majority of which is conserved. Who does your constructibility reports, PJM? Do you hold a seance and consult with utility planers from 1930? It's been many years since farmland was "undeveloped land" that has no value of its own and is seeking linear infrastructure projects to increase its value to the community. In fact, that's probably never been entirely true, although in the last century farmers were a politically disenfranchised population whose cleared, relatively flat land looked good for cheap, linear infrastructure at 30,000 feet. That's no longer true, especially in the eastern portion of the PJM region, where dwindling farmland has become a highly-prized commodity worthy of protection from cluttered over-development.
In addition, time has not been kind to the IEC. Like a parasitic houseguest who drinks all your beer and leaves hair on your soap, IEC has not become more valuable over time. It's become less valuable. And the people can't wait until it leaves for good. Market efficiency projects have a very short shelf life, which PJM obviously realized when it inked its agreement with Transource to build the IEC project. Now it's time to re-evaluate and send IEC to the great dump heap of failed projects.
Opposition to IEC is entrenched and wide spread. Cancellation is the only option.
The opposition recently voiced its reasons for cancelling the project in a letter to the PJM Board of Managers. This opposition was bolstered by additional letters to PJM from Pennsylvania Representatives Kristin Phillips Hill and Stan Saylor. In addition, Pennsylvania Public Utility Commission administrative law judges evaluating the project have become increasingly critical of the project, with Judge Elizabeth Barnes stating that she'd be "hard pressed" to approve the currently proposed project. Things are not going well for this project in Pennsylvania.
What's happening in Maryland? Governor Larry Hogan recently sent his own letter to PJM requesting the project be stopped until it can be re-evaluated or develop a new route using existing rights of way. Things aren't going so swell in Maryland, either.
Face it, PJM, this is the kiss of death for the Transource IEC. It's time to cancel the project and go back to the drawing board, presuming any actual "need" to relieve congestion still exists. And PJM has stated that a re-evaluation is in process and will be revealed at PJM's September TEAC meeting. What PJM's magic math giveth, PJM's magic math can subsequently taketh away.
The number of abandoned PJM projects is steadily increasing, and with generous FERC incentives to reimburse project costs in the event of cancellation, costs to ratepayers stemming from PJM failure are well into the hundreds of millions of dollars. Hundreds of millions of dollars added to the electric bills of PJM consumers for badly planned projects that never even get off the drawing board! You've got a big, big problem, PJM! Your planning process isn't working and desperately needs revision.
I'd start with PJM's subjective "constructibility analysis." There's no uniformity here. PJM needs to add some reality to its engineering staff. Just because something looks good ("robust" in PJM parlance) from an engineering standpoint, does not mean it should be constructed. Engineering needs to intersect with the reality of politics, regulation, land use, and community relations. That's the point of a "constructibility analysis." But there are no standards. While I have seen "constructibility" analyses that factor in possible opposition, others don't even mention it. Environmental factors are not the only thing that makes a project unable to be constructed as planned. In fact, environmental factors are the ones most nimbly avoided. It's those other factors that kill projects. It's high time PJM add some uniform standards to its "constructibility" analyses and require each greenfield project to be evaluated according to set standards. A greenfield project that is technically superior to a rebuild isn't so superior when it can't be built. In that case, a lesser rebuild is the solution that best serves consumers because it is more likely to actually get built.
And PJM needs to come out of hiding and own its work. Transmission owners hide behind PJM by claiming they're only following orders. PJM in turn hides behind transmission owners by turning a blind eye to what is actually happening with the projects it orders, and instead receiving all its information about a project's progress from the transmission owner. In order for PJM to have any credibility, it needs to actively participate in tracking project progress. PJM has long been in desperate need of an effective public relations program. Why is it that 99.9% of the consumers PJM serves have never heard of PJM? Because PJM likes it that way. Only when PJM realizes it exists to serve consumers (not simply member utilities) and develops a relationship with its consumers will its credibility and purpose be recognized by the consumers. When will PJM recognize the usefulness of doing its own community consultation and not leaving that task up to increasingly patronizing and arrogant transmission owners whose only concern is the amount of money it can make from a project?
You could do so much better, PJM, on a lot of fronts. But, for now, it's time to fall gracefully on your sword once again and cancel the Transource IEC project.
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