Midwest utility-scale wind generators who stand to rake in enormous profit, and the big national environmental organization Pollyannas who think these lines will actually be used for renewables, want to broadly socialize the cost of building $300B worth of new transmission lines to export wind energy from the midwest to both coasts.  This uneconomic prospect is made possible by "public policy" renewable portfolio standards adopted by some individual states that would require them to purchase renewables at any price.  Every state that has adopted a RPS has different goals regarding what qualifies as "renewable" energy, different renewable percentage requirements, and the states even differ on whether the standard is voluntary or mandatory.  Some even include carve-outs reserved for in-state renewables only.

Because there is no national standard by which all states must abide, there's no way for federal regulators, regional transmission organizations, or environmental organizations, to force individual states to permit and pay for these new transmission lines.  But, that doesn't stop these entities from trying.

I came across an article in The Georgetown Law Journal the other day entitled It’s Electric, but FERC’s Cost–Causation Boogie-Woogie Fails To Justify Socialized Costs for Renewable Transmission that discusses why FERC's attempts to socialize the cost of individual state public policy projects ultimately must fail.

FERC, or a RTO, cannot force citizens of one state to pay for the public policy goals of another state in which these citizens have no legislative representation.

"Where a state has chosen not to adopt a renewable portfolio standard, or a standard as high as MISO’s tariff supports for a given resource, FERC has no “articulable and plausible reason” to approve a regional tariff that permits some states to impose their policy judgments upon states with divergent policy positions.  A contrary view raises commandeering and federalism questions.
FERC would be deciding what policies benefit a state and then forcing that state’s constituents to pay to support that policy. Although this situation differs from landmark cases, like New York v. United States and Printz v. United States, in that FERC would not be forcing state legislative action or commandeering a state administrative body, the situation raises similar political-accountability concerns.  As the Court noted in New York, when the federal government compels state action, “the accountability of both state and federal officials is diminished.” If state citizens wish to change state policy, they may elect state officials who share their view. That view can always be pre-empted under the Supremacy Clause if it is contrary to the national view, but in such a case it is the Federal Government that makes the decision in full view of the public, and it will be federal officials that suffer the consequences if the decision turns out to be detrimental or  unpopular."

FERC is on the fast track to a nasty federal court battle with states if they continue to coddle midwest wind developers in a misguided attempt to make utility scale renewables "affordable" for consumers thousands of miles away from the point of generation.

"It appears that the Commission is overextending its existing power without any supportive legislative augmentation. It is concerning that an independent agency lacking direct political accountability continues to push the envelope into controversial areas. Politically accountable federal legislators would be more appropriate arbiters of these issues in the first instance."

The article concludes with this warning:

"FERC should be mindful of approving cost-allocation methodologies over the objections of states within a
given region. While renewable power is critically  important to our country’s energy independence and the health of our environment, a one-size-fits-all socialized cost-allocation methodology might not be the  appropriate fit for every region."

But, read the entire article for yourself -- it's a great read!

Guess what Potomac Edison and Mon Power customers?  New parent company FirstEnergy wants to raise your electric rates again effective January 1, 2013!  That's right, those sky high bills you've been receiving because Potomac Edison and Mon Power are saving their money by not reading your electric meter are now going to be even more unreasonable!

According to a recent rate filing the companies made at the West Virginia Public Service Commission, your electric rates would actually decrease in 2013 due to lower power prices and the satisfaction of your old debt to the power companies.  However, FirstEnergy is proposing that the PSC leave rates at current levels to begin paying for one of their coal plants that they wish to sell to Mon Power, who supplies all Potomac Edison's electricity.

But leaving rates at current high levels is only the tip of the iceberg.  The price of the Harrison coal-fired generation plant that FirstEnergy's unregulated generation subsidiary wants to sell to their regulated WV subsidiary, Mon Power, is a cool $1.16 Billion.  Purchasing this plant will make Potomac Edison and Mon Power rates increase if the transaction is approved.

Other options to purchasing this plant do exist and include purchasing currently low-priced power from PJM's electricity market, building a new gas-fired generation plant, decreasing demand through spending on energy efficiency and demand management programs which reduces the need to acquire new generation.  However, FirstEnergy refuses to put out a request for proposals to supply needed generation through a bidding process.  FirstEnergy has done their own skewed evaluation that they claim shows purchasing this coal plant is the cheapest option.  It's hardly an unbiased and arm's length evaluation since parent company FirstEnergy stands make a substantial financial benefit from the transaction.

FirstEnergy is selling West Virginians a pig in a poke.  The plant is currently owned by FirstEnergy's unregulated generation subsidiary.  This means that the plant and its operating cost is paid for by the company in a competitive market.  In West Virginia's regulated, uncompetitive environment, the plant and its operating cost will be paid for by Mon Power and Potomac Edison customers.  FirstEnergy is shedding an expensive, uncompetitive liability into a regulated market where they are guaranteed full cost recovery plus a return, whether the asset is competitive or not.  If this plant was still competitive, FirstEnergy's unregulated generation subsidiary would keep it as a money maker, but because it's not, they want to unload it on you and abscond with over a billion dollars, which you'll be paying off for years to come.

In addition, this plant needs several environmental upgrades to comply with EPA regulations.  You'll pay for that too in the future, because it will be your plant by then and therefore your financial responsibility.

When FirstEnergy merged with Allegheny Energy in February of 2011, the Harrison plant had to be revalued at market value to please federal regulators.  This added $589M to the book value of the plant.  Now, less than 2 years later, FirstEnergy wants to sell the plant to you at full merger book value.  If you had bought the plant before the merger, it would have cost you that much less.  FirstEnergy's "merger synergies" have made this transaction even more expensive for Potomac Edison and Mon Power customers.

There's lots more detail to be found in the State Journal's news coverage:

FirstEnergy: Keep rates the same, use extra to buy coal plants

FirstEnergy wants to transfer coal-fired generation to Mon Power

How much is FirstEnergy's Harrison power station worth?

So, what can you do about it?  Tell the WV PSC that you do not support FirstEnergy's proposal and do not wish to pay higher rates to subsidize an out of state corporation's financial success by purchasing their unwanted, cast-off, uncompetitive coal plant liability at twice the pre-merger price.

Click here to submit your comment to the PSC online.  The case number is 12-1571-E-PC.

According to this article, energy efficiency programs in Ohio are too expensive for FirstEnergy's customers.

"The power giant says the programs they’ve implemented to incentive customers to reduce electricity use are getting too expensive.

Doug Colafella, is a spokesman for First Energy.

Colafella: “As these programs become more aggressive, as the goals become more difficult to achieve, the costs for these programs are undoubtedly going to increase.”

I'm not sure where our lil' CoalFella picked that winner from, but I think he may have his hand jammed in the wrong orifice.

After whining about how much energy efficiency is going to cost customers as justification for gutting Ohio energy efficiency mandates, FirstEnergy turns around today and announces the building of a new $45M "transmission control center" in Ohio.  Now who do you think is going to pay for Tony the Trickster's new underground lair?  You are!  Those poor, broke customers who can't "afford" energy efficiency investment that will lower their bills over the long term can afford to pay for a shiny, new office building for the company, according to FirstEnergy.

How much energy efficiency could Ohioans buy with $45M?

The perturbed parade of stakeholders who believe PJM and the Market Monitor were engaged in secret scheming to revise the MOPR to their detriment continues to grow.

There's a whole new crop of angry letters on PJM's website that generally urge PJM to toss out the current proposal and start again from scratch, this time including ALL stakeholders.

OPSI Resolution (Organization of PJM States)

Joint letter from MD-PSC and MD-OPC

U.S. Rep. Van Hollen letter (now you've gone and ticked off Congress with your secret scheming, PJM, tsk, tsk!)

PA-PUC letter opining that secret scheming isn't such a big deal (if you're from a state that has a bunch of expensive coal-fired generation that now has no market).

Ut-oh, PJM, Ut-oh!  Next thing you know, they're going to be labeling you a cartel.  Go figure.

One of PJM Interconnection's purposes is to provide reliable power at the lowest possible price.  As part of its attempt to accomplish this goal, PJM plans for transmission "enhancement" and administers an artificial market construct that is supposed to foster competitiveness that will ensure market prices for electricity are "the lowest possible."

Although PJM can order new transmission to artificially adjust electricity markets, they cannot order new generation to shape the market.  This unbalanced "market" is what set up the investor owned incumbent utility transmission feeding frenzy we've had to put up with over the past few years.  Instead of ordering new economic generation near load, PJM orders expensive new transmission lines that source from existing generation farther from load.  PJM believes that "the market" (that is the REAL economic market, not PJM's artificially constructed and controlled market) will stimulate new generation without interference.  However, PJM will not rely on "the market" to drive transmission expansion.  If they did, would the lights go out while we wait for "the market" to catch up?  PJM thinks so.

Because PJM cannot order new generation, the states of New Jersey and Maryland took matters into their own hands and ordered new generation in their own states.  This upset PJM, the Market Monitor, and the incumbent generators, who have been scheming to actually prevent new generation.  So much for allowing "the market" to encourage new generation.

PJM "ordered" four new high capacity long distance transmission lines between 2006 and 2008 in order to increase the use of coal-fired resources.  These lines were supposed to bring lower cost electricity to the east coast, instead of waiting for "the market" to encourage new east coast generation.

The lines were economic projects, designed to decrease the "congestion" on existing lines that prevented the import of additional coal fired generation to the east coast during peak load.  However, PJM also floated these projects as reliability projects, insisting that eastern load would continue to attempt to draw cheap coal fired power from the west over congested lines until the lines simply overheated and failed, pitching the entire region into the dark.  That would never have happened because the east coast had plenty of their own generation, albeit more expensive (at the time) gas fired generation, that would increase prices when relied on to support peak load.

In order to decrease prices on the east coast through the building of these new lines, the cost of the lines is shared by all consumers in the entire PJM region.  The east coast only paid a fraction of the cost of the lines that lowered their prices.  And, in fact, the lowering of prices on the east coast by building new transmission actually increased prices in the western region by providing new markets for previously constrained generation.  Eliminating "congestion" serves to levelize prices between different markets.

But, something amazing happened between 2006 and 2012.  Demand for electricity on the east coast tanked due to increased energy efficiency and demand side management.  By shaving peak load, the east coast made great strides to solving the "problem" of not having access to cheaper, western coal fired generation.  Something else happened during that time as well.  Shale gas flooded the market, opening up a cheap, plentiful, new supply of natural gas that lowered the cost of previously expensive gas fired generation on the east coast and motivated new gas fired generation builds near east coast load.

The combination of decreased load and more economic east coast generation completely obviated PJM's "need" for the four new transmission lines.  Unfortunately, TrAIL had already been built at enormous cost and personal sacrifice by the people of West Virginia.  However, two other projects, PATH and MAPP, have finally been abandoned by PJM and won't be built.  But, the PJM consumers will still pay for these abandoned projects they never wanted and no longer need.  PJM's transmission planning has failed on a massively expensive scale.

But I've only accounted for three of the four projects thus far.  The last one is PSEG & PPL's struggling Susquehanna Roseland project in Pennsylvania and New Jersey.  Although there is no economic or reliability need for this project anymore either, the project owners and PJM continue to insist on constructing it at enormous cost to consumers, landowners and the citizens who own the Delaware Water Gap National Recreation Area.

PSEG & PPL read the economic writing on the wall over the past few years and stepped up their efforts to ramrod their project into reality by making it "too big to fail" even though the economic justification for it had evaporated.  The companies still claim that S-R "will save consumers $200M per year in congestion costs," therefore it is urgently needed and justifies enormous cost that will raise electric prices, take land from property owners, force those living in close proximity to risk their health being bathed in the line's continuous EMF soup, and destroy a priceless and irreplaceable national park.

In order to do so, PSEG & PPL bribed towns and landowners with "mitigation" payments and began a lobbying program that reached all the way to the White House with the goal of obtaining the approval of the National Park Service.  The cost of all this, of course, will be borne by all consumers in PJM.

Last week, I watched FERC Commissioner Moeller extoll the virtues of new transmission while disparaging the efforts to hinder Susquehanna Roseland, a project that "would save consumers $200M a year in congestion costs," according to Commissioner Moeller.

So, where did that congestion figure come from?  PJM and the project owners floated it at the time the project was approved, many years ago.  Does that figure still bear any resemblance to reality?  No. The "congestion" driving S-R has evaporated.  The building of S-R will actually cost consumers more than any subset of consumers will ever save on their electric bills.  Whether or not there is a "reliability" need for this project I really can't say, but if there is one, a simple rebuild of the existing line may suffice to fill that void.  S-R as planned is overkill.

Every quarter PJM's Market Monitor publishes a "State of the Market" report.  The one for the third quarter of 2012 was released the other day.  The report has a section about "congestion."  If S-R was still going to save consumers "$200M per year" that information would show up in the report.  It does not.

The SOM report says, "The AP South interface was the largest contributor to congestion costs in the first nine months of 2012. With $50.9 million in total congestion costs, it accounted for 12.0 percent of the total PJM congestion costs in the first nine months of 2012.
The top five constraints in terms of congestion costs together contributed $112.5 million, or 26.5 percent, of the total PJM congestion costs in the first nine months of 2012. The top five constraints were the AP South interface, Graceton – Raphael Road transmission line, Woodstock flowgate, Belvidere – Woodstock line and Clover transformer."

None of these congestion contributors is located anywhere near the Susquehanna Roseland project area.  And the biggest contributor to congestion costs is $50.9M per year, not $200M.

The SOM report also provides a nifty map on page 221 that shows congestion points.  There's no congestion showing up in the geographic area where S-R is being constructed.

Need and justification for Susquehanna-Roseland have completely evaporated.  If the project is abandoned now, or reconfigured to more closely align with any actual need, the cost to consumers will be dramatically lowered.  Stop constructing this project now.  Just stop.  Consumers can't afford PJM's artificial markets and planning failures any longer.  Stop it.

Yesterday, FERC issued a Policy Statement intended to further refine their policy for awarding financial incentives to transmission projects.  The Policy Statement was the Commission's response to the extensive, 42-page, 74-question Notice of Inquiry it issued in May of 2011.

The financial feeding frenzy has been scaled back for now and transmission owners have had their bag limits on consumer wallets reduced.

If you want the quick and dirty summary, here's FERC's press release.

If you want to know exactly what was in the Policy Statement, read on.

"In particular, the Commission: reframes its nexus test to focus more directly on the requirements of Order No. 679; expects applicants to take all reasonable steps to
mitigate the risks of a project, including requesting those incentives designed to reduce the risk of a project, before seeking an incentive return on equity (ROE) based on a project’s risks and challenges; provides general guidance that may inform applications for an incentive ROE based on a project’s risks and challenges; and promotes additional transparency with respect to the impacts of the Commission’s incentives policies."

1.  "The Commission will no longer rely on the routine/non-routine analysis adopted in BG&E as
a proxy for the nexus test."

What this means:  The nexus test requires an applicant for incentives to demonstrate a connection between the incentive(s) requested and the risks and challenges that a project faces.  Previously, once an applicant demonstrated that a project was not routine, the nexus test was satisfied and the project was deemed to face risks and challenges that merit incentives.  In the refined policy, FERC tosses out the routine/non-routine analysis and will require project applicants seeking incentives to demonstrate how the total package of incentives requested is tailored to address  demonstrable risks and challenges and must provide sufficient explanation and support to allow the  Commission to evaluate each element of the package and the interrelationship of all elements of the package. If some of the incentives would reduce the risks of the project, that fact will be taken into account in any
request for an enhanced ROE.  In short, applicants will have to do more to demonstrate risks and challenges that merit incentives.

2.  "The Commission expects incentives applicants to seek to reduce the risk of transmission investment not otherwise accounted for in its base ROE by using risk-reducing incentives before seeking an incentive ROE based on a project’s risks and challenges."

What this means:  A transmission's base ROE (the interest a project earns on its investment) is already set to account for the riskiness of transmission investment.  However, when a transmission project is riskier than a "normal" transmission project, it can be granted additional incentives to compensate for additional risk.  However, a project must request and utilize risk-reducing incentives before requesting an incentive ROE (extra interest) on a particular project.  A project owner must show how their project is riskier than "normal" and then how certain risk-reducing incentives will compensate for or reduce risk.  If the project is still so risky that risk has not adequately been reduced through the base ROE and risk reducing incentives, it may also request further risk compensation in the form of an enhanced ROE (extra interest).  The Commission is getting tougher judging risk and the need for a full spectrum of every available incentive.  No more using the same risk as the basis for every incentive.  Each incentive granted will reduce risk and a company would have to prove further risk that has not already been compensated for with other incentives in order to be awarded an incentive ROE.

3.   "Investments in the following types of transmission projects may face the types of risks and challenges that may warrant an incentive ROE based on the project’s risks and challenges that are not either already  accounted for in the applicant’s base ROE or could be addressed through risk-reducing incentives:

1. projects to relieve chronic or severe grid congestion that has had demonstrated cost impacts to consumers;
2. projects that unlock location constrained generation resources that previously had limited or no access to the wholesale electricity markets;
3. projects that apply new technologies to facilitate more efficient and reliable usage and operation of existing or new facilities."

What this means:  I think it's pretty self-explanatory.

4.  "The Commission will no longer consider requests under Order No. 679 for a stand-alone incentive ROE based on an applicant’s utilization of an advanced technology."

What this means:  No more incentive ROEs based solely on advanced technology, this will be considered as part of a project's risks and challenges (see 3 above).

5.    "Risks may be reduced through the risk-reducing incentives described in section II.B, or through mitigating costs by implementing best practices in their project management and procurement procedures. Applicants should consider taking measures tailored to mitigate the various risks associated with their transmission projects and to identify such measures
in their applications."

What this means:  Transmission Owners need to stop creating risks through poor management or bad choices and then asking to be compensated for it.

6.   "The Commission expects applicants for an incentive ROE based on a project’s risks and challenges to demonstrate that alternatives to the project have been, or will be, considered in either a relevant transmission planning process or another appropriate
forum. Such a showing should help identify the  demonstrable consumer benefits of the proposed project and its role in promoting a more efficient, reliable and cost-effective transmission system."

What this means:  No more PATHetic projects!  An applicant must demonstrate to the Commission how its project was compared to alternatives and found to be the most cost-effective solution.  Of course, a showing could be that an RTO/ISO has made this determination.  And since RTO/ISOs are nothing but industry cartels that will choose the projects of their favored incumbents and then make up a justification to support their choice afterward, this really doesn't solve the problem.  However, the transmission owner now has to convince the Commission that it was done properly.

7.   "The Commission expects applicants for an incentive ROE based on a project’s risks and challenges to commit to limiting the application of the incentive ROE based on a project’s risks and challenges to a cost estimate."

What this means:  Any incentive ROE will only be applied to a project cost amount that was used to determine the project's cost effectiveness as evaluated by an RTO/ISO.  So, say a project is found to be superior to other alternatives at a certain price when evaluated by an RTO/ISO, and then is awarded an incentive ROE by FERC.  The project can no longer apply the incentive to amounts that go over budget.  Historically, projects have floated bogus cost estimates at RTOs in order to get projects approved, and then spent a lot more actually building the project, and collected extra interest on the overspend.  This situation perpetuated the "the more you spend, the more you make" scenario that has plagued transmission projects and is breaking consumers while unjustly enriching transmission owners and contractors.  The Commission also gives a nod to SPP's cost containment proposal submitted in comments as a reasonable example.

While these are generally positive changes, they don't go nearly far enough and completely fail to tackle the underlying problems with FERC's transmission incentives policy.  FERC has merely set the stage for another long, slow decline toward lazy rubber stamp approval of ridiculous incentive packages that cause consumer concern.  The PATH project was the impetus for the NOI and the refinement handed down yesterday.  How long before another PATH happens?

I'm not sure what happened between FERC's rather auspicious and ambitious beginning in issuing such a great NOI, and this Policy Statement that feels like a punt.  It could be that there was too much controversy among the Commissioners.  It could be that there was too much political pushback from a greedy industry.  And don't forget those personal visits to the Commissioners from transmission owning CEOs.  Whatever happened, it looks like the Commission lost their nerve and took what they feel is the easy way out.

See statements of Commissioners Norris and LaFleur here.  It's interesting that they didn't publish a statement from Commissioner Moeller, since he had plenty to say yesterday.  Maybe he's part of the problem.  Wellinghoff didn't have much to say about it, and Clark was not participating.

It seems like the Commission was afraid if they came down too hard on transmission incentives that they would stifle investment.  However, they have quite effectively managed to do just that with their Policy Statement.  Which transmission owner do you think is going to be brave enough to step into the void and be the first to apply for incentives under the refinement (which was effective yesterday, btw)?  Not a one of them.  They're all going to hang back and wait for someone else to poke the first stick into the lion's cage so they can begin the process of finding ways to work around well-intended changes in order to continue to unjustly enrich themselves building unnecessary transmission.

I guess if Congress really wants transmission incentive policy reform, they're going to have to do it themselves through amendments to the Energy Policy Act.  I can only wish them luck.

Wow, talk about your scare tactic headlines... 

"Thousands Seen Dying If Terrorists Attack U.S. Power Grid" was the headline Bloomberg used on an article about cyber security and the electric grid yesterday.

Too much drama?  Maybe not.  Read the article and find a new worry to keep you up at night.

"Cyber attackers “could magnify the damage of a physical attack” by disabling computerized security systems or blocking signals to grid operators, the report said.

Other threats to the grid may include terrorist groups, disgruntled or bored individuals, or energy companies seeking to thwart competitors, it said. A 2011 report from the Electric Power Research Institute said that about $3.7 billion in investment is needed to protect the grid from cyber attacks."

So, while FERC tries not to be so helpless about cyber attacks, who's minding the store?

Is it NERC, who is supposed to enforce grid reliability standards?  NERC, whose standards are drafted and approved by the industry they are supposed to regulate, is a tool of the industry. 

NERC recently fined three related subsidiaries of some anonymous electric utility $725,000 for for failing to have a good cyber security protection system in place.  $725,000 is a big deal fine for NERC, but what if this was your electric service provider, and their entire system had been taken out by "disgruntled or bored individuals" before NERC got around to collecting such a paltry fine and instituting a compliance program?  I guess that's a gamble anonymous electric utility is willing to take with your life (according to Bloomberg).

Don't sit around waiting for the government entities, or worse yet the utilities themselves, to save you if some pimply teenage hacker brings their anarchy dream to fruition. 

Don't listen to these same entities telling you that we need to build a bigger, cleaner, stronger grid.

Don't listen to these same entities telling you that you are and always will be a stupid animal feeding at the corporate energy trough to survive.

How many Sandys do we need to demonstrate that the traditional electric delivery system is broken and can't be fixed?

So, what's the solution?  Self-reliance.  Smaller systems that can be isolated.  Power generation located closer to where the power is used.  Distributed generation.  The Power Line brings us two stories of microgrids in New York that survived a direct hit by Sandy, while all the traditional utilities shrugged their shoulders at massive failure.  Read the stories here and here.

I hope we don't have to wait for pimply teen to grow out of his anarchy phase before our grid "authorities" wake up.

PATH never could resist having the last word in any argument, even if doing so burned PATH like a moth circling too close to an enticing flame.

PATH didn't disappoint today and filed a second "response" to the answer of one of the other parties to PATH's answer to protests of its abandonment filing at FERC.

Old Dominion Electric Cooperative filed an answer to PATH's answer last week pointing out that PATH was only remaining a "member" of PJM in order to collect an extra half a percentage point of interest over the amortization period.  Since PATH does not plan to own any transmission that would receive benefit from a PJM membership, the extra interest to be derived from this "membership" is just another way to gouge consumers without any corresponding benefit.  ODEC also pointed to PATH's ridiculous contention that its parent companies' memberships in PJM entitled PATH to receive this benefit.

What is it that PATH fails to understand here?  Sec. 219 of the Energy Policy Act directs FERC to "provide for incentives to each transmission utility or electric utility that joins a Transmission Organization."  Now that PATH's project is abandoned and PATH has no plans to own any other transmission, ever, PATH is no longer a "transmission utility or electric utility."  Therefore, PATH is no longer eligible to retain this incentive.  Does someone need to draw PATH a picture?  Any further answers or responses should include artwork, preferably in crayon.

In their "response" today, PATH rambles on accusing ODEC of conflating and confusing PATH's answer.  Fail!  Considering that I read the same thing in PATH's answer that ODEC did, chances are that the Commission will also read it that way, despite PATH's suicidal attempt today to rehabilitate its own bleary legal work.  And speaking of bleary legal work... who is the "Virginia Service Corporation Commission" that PATH mentioned in their "response" today?  Any parties here by that name?  Didn't think so.  Thanks for the laugh, PATH!  Watch out for that fire, it's hot!

That's the three foot tall slogan emblazoned on a bunch of new billboard ads in Ohio.

Sierra Club's Beyond Coal Campaign has initiated the advertising campaign to make Ohio's FirstEnergy customers aware of how FirstEnergy is ripping them off by failing to pass on energy efficiency benefits and to generate consumer comments at the Public Utilities Commission.  Check out the campaign's website here.  The very observant may even get a deja vu feeling while reading ;-)

Read an article about the billboards where our lil' Coalfella whines about how unfair the campaign is.  Really?  FirstEnergy wants to whine about unfair right about now?  Ha ha ha ha.  Karma's a real bitch, boys!  Now sit back and watch how generating comments at PUCO is done.  You might want to take notes to use during your next little public tiff with AEP.

Ooops!  PJM's Terry Boston let the wind industry's scheming out of the bag yesterday at some "event" on fostering transmission investment and clean energy resources in the Southeast.

"The Bipartisan Policy Center is working with power industry representatives and plans to send recommendations early next year to President Barack Obama on transmission and electricity policy, the head of PJM Interconnection said Wednesday."

Say what?

According to this article in Platts, Boston said, "FERC's current rule on cost allocation of new transmission lines is to assign costs to those who benefit from the lines, but for interstate projects to move renewable resources through several states, some states may feel left out and that is a big challenge for the industry to address."

Left out?  Is that how the industry that stands to profit from long-distance transmission lines "for midwest wind" is going to color those states being used as a pass-through for these lines?  You're darn right we're going to feel "left out" when other states' renewable portfolio standards require us to give up our land for new rights-of-way and pay for construction of a transmission line that only benefits citizens of another state.  It's not going to happen, even if the lobbyists do whisper sweet nothings in Obama's ear while writing campaign contribution checks.  Bi-partisan, my eye!

Let's take a look at the people involved here.  While they may be politically bi-partisan, there's an even scarier partisanship going on here than anything the Democrats or Republicans could dream up.  It's all about the money, boys!  It's big business vs. the consumers they plan to rob blind.

John Jimison, a former US House of Representatives staffer and current managing director of Americans for a Clean Energy Grid:  Americans for a Clean Energy Grid is nothing but a front group for industry that stands to rake in the cash by turning the midwest into "the Saudi Arabia of wind" and shipping it to both coasts via $300B of new high-voltage transmission lines that we don't need, can't afford, and that will only serve to render the grid more fragile and vulnerable.  This front group is a transmission owner's dream$come$true because they've reined in the big environmental organizations to act as their lackeys to promote transmission development for "clean energy."  The environmental fantasy these patsys see fails to recognize that once this "green" grid is built (with consumer funds, remember that) it's going to transport fossil fueled energy because the grid is open access and "wind" won't be able to compete on a price basis.  Only through government subsidies and state mandates will costly "wind" power be viable.  This front group has been busy holding real old fashioned kool aid socials around the country.  In fact, we may have infiltrated one earlier this year ;-)  Just remember, there ain't no such thing as a free lunch, check out the "sponsors" of these propaganda fests.

Former Congressman Rich Boucher:  Now employed as the "head" of energy lobbying firm Sidley Austin's "government strategies group."  Lobbyist.  Not "bi-partisan" but protecting the interests of his well-heeled energy company clients.

Former Federal Energy Regulatory Commission Chairman Curt Hebert:  Currently the Chief Executive Officer of Lexicon Strategy Group, LLC.  Lexicon Strategy Group " specializes in risk assessment and developing appropriate business strategies to mitigate the impact of adverse legislative and regulatory policies. Our legal team provides regulatory expertise to electric and gas clients for issues including exploration/production, generation, transmission, distribution and securities."  How do they do that?  "Coalition Building, Third Party Advocacy, Constituent Recruitment, Governmental Management (Federal and State), Federal and State Energy Policy Development,
Advocacy Campaigns."  You know, all the best front group propaganda techniques.

And, of course, the partisanship to the energy companies that own him of our dear friend Terry Boston from the PJM Cartel is already legendary.

Well, guess what, lobbyist friends?  The consumers who make up the 99% aren't on board with your money making schemes, and the states who currently control transmission siting approvals aren't on board with your attempts to usurp their authority, and guess what?  There's more of us than there are of you.  See you at the White House!