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PJM's Board Approved New Transmission Projects - Now What?

12/12/2023

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Yesterday, PJM's Board of Managers quietly approved over $5B of new transmission designed to import electricity created by coal, gas, and nuclear to Virginia's data center alley and the Baltimore area, where thousands of megawatts of coal-fired power plants are set to close next year.  New industrial load and closure of dirty generators is being solved by importing dirty generation from other states to the DC-metro area, an area that likes to pretend it's embracing clean energy and lowering its carbon emissions.  Hardly.  Clean energy policy is all smoke and mirrors... literally.

First, let's look at PJM's announcement.
The proposed solution includes new substations, new transmission lines and improvements to existing facilities. A majority of the project components use existing facilities and rights of way (through either repurposing/rebuilding existing assets or paralleling existing rights of way, which can reduce costs and minimize impacts to local areas). There are sections that would be new construction on land without existing transmission lines, known as greenfield development.
Well, that's a complete and total lie.  Apparently I have found the weak spot.  Paralleling existing transmission lines with new transmission lines on greenfield ROWs does NOTHING to reduce costs.  How so, PJM?  A new greenfield project would cost the same no matter where it is sited.  In addition, wreck and rebuild projects that expand existing ROW have additional costs of tearing down the existing line before a new one can be built.  As far as "minimizing impacts" that is also a huge lie.  Transmission lines are not like Lay's Potato Chips where you can't just have one.  Continuing to expand existing transmission corridors is the antithesis of environmental justice.  Nobody who lives with one (or more) transmission line across their property wants another one.  Impacts can actually be GREATER when paralleling existing ROWs because ROW expansion further intrudes into the host's land and gobbles up things built outside the current ROW, such as fences, barns, playsets, swimming pools, and water wells and septic fields.  Loss of water and sewer makes a property uninhabitable.  Expansion of existing corridors is like living next to an active volcano... they slowly expand until they overtake you altogether.  Just remember, if a utility builds transmission through your property, you are subject to another, and another, and another.  Not fair for you, not fair for anyone else.
PJM does not site the facilities or transmission lines nor determine their routes. This is the next step in the process and will be completed by the developers designated by PJM to construct the projects.
That's right.  I've been saying this over and over, but here's one more for the road.  The next thing the transmission company assigned the project will do is a detailed routing study that attempts to avoid homes and other structures, parks, historic resources, public land and environmental constraints.  What comes out of that process is a collection of competing short route segments that can be pieced together to form the actual proposed route.  The transmission company expects you all to fight with each other over these route segments in order to push it out of your own backyard and into your neighbor's.  The company asks you to comment on individual segments with the hope of finding the ones with the least objections.  Tough luck for you if you live on one of them.  Once the proposed route is established, the transmission company will file an application with the jurisdictional state utility commission.  The company asks that the commission approve the route and issue a permit to build the project.  This is a long, court-like process in which impacted parties can participate, either with or without a lawyer.  It is recommended that you do participate, if nothing else simply to preserve your right to appeal a decision you don't agree with.
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And take a look at those cost allocation tables in the attachments to PJM's announcement (Page 55). The lion's share (44%)  of the more than $5B cost will be paid for by Dominion's customers.  However, more than 10% will be paid for by customers in PJM's APS region, which includes not only portions of northwestern Virginia, but also more than half of West Virginia and big chunks of Pennsylvania.  Why are struggling communities in rural areas paying for a giant chunk of transmission that benefits some of the richest corporations in the world, such as Amazon, Google and Facebook?  West Virginia and Pennsylvania are not getting any benefit whatsoever, except what little bit of "reliability" leaks out from keeping the data centers and plant closures from crashing the grid altogether.  Why do others have to pay to shore up something that someone else broke?  This is not like historic load growth that came in small and widely dispersed increments and therefore affected the region at large.  This is like plunking a large city down all at once and plugging it in.  We can (and PJM has) point right to the cause of the new transmission.  Least they can do is pick up their own costs.  It is no longer just and reasonable to expect everyone to pay for the damage done by the few.  And if you think that's bad, check out the regional load ratio share allocations -- a portion of the costs that is allocated across the entire PJM region.
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These are all the other utilities who have to pay a portion of the costs for new transmission to serve data centers.  You can locate these utility acronyms on this map.
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Check out the ComEd region, for instance.  This utility in northern Illinois will pay for 13.39% of the shared costs, a larger load-ratio share than Dominion (13.32%).  Imagine how they feel about paying for transmission that supports new data centers in Northern Virginia and closing coal plants in Baltimore.

If you're totally confused by PJM's cost allocation system, just wait... there's bound to be some fireworks when PJM asks for FERC approval to allocate the cost this way.  More about that when it happens.  For now it's enough to know that PJM's historic cost allocation system does NOT work for these projects and therefore must be changed in order to remain just and reasonable.

PJM's White Paper (that they managed to hide until AFTER the Board meeting) pretends that your participation mattered.  Look what it said:
Project needs and recommended solutions as discussed in this report were reviewed with stakeholders during 2023, most recently at the October 31, 2023, and December 5, 2023, TEAC meetings. Written comments were requested to be submitted to PJM to communicate any concerns with project recommendations. All correspondence addressed to the PJM Board are available at the Board communications page.
All your letters to the Board got filtered through the TEAC and summarized.  The Board didn't read any of them.  I'm thinking that muzzling of stakeholders is NOT in PJM's beloved Manual of procedures.  Therefore, it most likely violates the rules it is supposed to follow that have been approved by FERC.  Anyone can file a complaint about that.

So, despite our best efforts, the PJM Board has approved the Window 3 projects.  Now what?

The real battle is just beginning.  Buckle up... it's likely to last for years.  Delay is our friend.  The enemy of our enemy is also our friend.  All of this will become crystal clear in due time.

But what should you do right now?  Reach out to your neighbor, ask them to reach out to their neighbor.  Form neighborhood groups that coalesce into town groups that coalesce into county groups that coalesce into state groups that coalesce into multi-state groups.  We're all family now.  Gather your people.  

And then circle the wagons.  Transmission opposition is as much a strategy battle as any other.  Keep your strategy discussions private.  The transmission companies will be desperate to know what you're planning so they can try to beat you to the punch.  They will infiltrate your groups and stalk you online in the creepiest way possible.  But don't be so paranoid that you aren't accessible to new folks.  There are layers to transmission opposition information dissemination.  After you meet a few of the utility wonks at transmission company public meetings you may be able to recognize them for what they are when they manage to infiltrate meetings.  I think after 15 years, I can practically SMELL them when they sneak into the room.  Once, I was guest speaking at a public meeting for a group when I noticed a guy way in the back row that positively screamed "utility guy" to me.  It wasn't so much his look as it was his behavior.  After I was done speaking, I pointed him out to the host leader and she told me he did work for a utility, but that he was secretly on their side.  Lesson:  not all utility nerds are bad guys, but there are plenty that are going to frustrate you and try your patience.  Take a deep breath.  Find the humor in the situation.  It helps.

When you've got your group together, feel free to ask me, "What's next?"  However, let's keep that out of public social media groups and out of public blogs.  I'm always available to answer questions or provide advice.

WE CAN DO THIS!

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    About the Author

    Keryn Newman blogs here at StopPATH WV about energy issues, transmission policy, misguided regulation, our greedy energy companies and their corporate spin.
    In 2008, AEP & Allegheny Energy's PATH joint venture used their transmission line routing etch-a-sketch to draw a 765kV line across the street from her house. Oooops! And the rest is history.

    About
    StopPATH Blog

    StopPATH Blog began as a forum for information and opinion about the PATH transmission project.  The PATH project was abandoned in 2012, however, this blog was not.

    StopPATH Blog continues to bring you energy policy news and opinion from a consumer's point of view.  If it's sometimes snarky and oftentimes irreverent, just remember that the truth isn't pretty.  People come here because they want the truth, instead of the usual dreadful lies this industry continues to tell itself.  If you keep reading, I'll keep writing.


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