I was going to just update my previous post, but you simply shouldn't miss reading CAKES's 2012 National Electric Transmission Congestion Study Comments.

'Nuff said.  Go.  Read.

Supplemental to the Order on Remand FERC issued last Friday, two of the Commissioners also issued statements explaining their decision.

Commissioner Norris's statement was a basic agreement with the Order and a hope that FERC's decision won't be used as a model for Order No. 1000 cost allocation methods.

However, Commissioner Moeller preferred to explain how western PJM will "benefit" from Project Mountaineer transmission lines that were intended to transport 5,000 MW of "cheap" coal-fired electricity from the Ohio Valley to eastern markets and lower high electricity prices on the east coast.

"Long-distance transmission lines are constructed because they greatly reduce the cost of electricity in comparison to the alternatives. Without long-distance transmission lines, energy consumers would need to construct enough local generating plants to ensure the availability of power. The cost of building smaller and local generating plants can be overwhelming in comparison to the cost of building a new transmission line. The cost can be especially high when local requirements make the construction of a generating plant effectively impossible."

That's only true when the cost of the transmission line is shared by the entire region, whereas the cost of local generation is paid by those who would benefit from it.

"In addition to the often overwhelming benefits of building a network of long-distance transmission lines, energy consumers at both ends of a transmission line often receive substantial benefits from the line. Even when a transmission line is directional, in the sense that power on the line tends to flow from regions where power is less costly to regions where power is more costly, energy consumers receive benefits on both ends of the transmission line. These benefits on both ends of the line derive generally from economies of scale and the efficiency of sharing the power that can be produced by generating plants. For example, the linkage of two cities by a transmission line can result in lower power prices in both cities due to the lower costs associated with the need to have fewer generating plants “spinning” as a reserve, but prices can also be reduced by building larger generating plants and by expanding the options for locating plants, so that plants can be located and sized at lowest cost. "

That's how it used to work, however, things have changed.  West Virginia exports something like 80% of the electricity produced in the state, and 99% of the electricity produced in West Virginia comes from burning coal.  Our rates used to be low because of the sale of exports, but a huge sea change is occurring.  Demand is decreasing in traditional export markets due to implementation of demand management, increased efficiency and the availability of local renewables.  West Virginia's former electric purchasers don't want our dirty, coal-fired power any longer and they aren't buying it.  In addition, the price of coal has skyrocketed, while the cost of natural gas has fallen, making the east coast's gas-fired plants a cheaper option for purchasing power.  As a result of this, West Virginians are being required to pick up the slack and make up for power sale losses through huge rate increases.  More transmission lines from West Virginia to the east coast are NOT needed!

"Even under an assumption that prices to some energy consumers will rise as a result of a new transmission line, the FERC, as a regulator concerned with interstate commerce, cannot favor prices in one state at the expense of the region. Plus, it is difficult to raise prices merely by increasing the ability of the power grid to transfer energy."

But that's exactly what you are doing in your order!  You are favoring the east coast with lower prices by building transmission lines intended to reduce economic "congestion" at the expense of the entire region.

"Using a simple example in a different market, strawberries are not more expensive in California because strawberries can also be shipped to New York. Rather, strawberry farmers will grow fewer strawberries if they cannot sell strawberries to New York. But even assuming that local power prices are higher when markets expand, lower power prices are not the only benefit associated with transmission. Arguably the most important benefit of the transmission network is not the access to markets, but the increase in the reliability of the entire network. As stated above, the benefits of avoiding one blackout can far exceed the entire cost of a transmission line.  While strawberries need to be consumed quickly or they become worthless, electricity differs in that it must be used instantly due to constraints imposed by physics. Also, while preparing land and acquiring water rights for strawberry farming can be capital intensive and requires advance planning, power plants involve substantial risk in that they require extensive capital investment long before revenues can be recovered."

Perhaps Commissioner Moeller is unfamiliar with West Virginia's "strawberry farm."  These are the "benefits" West Virginia reaps from it's production of "strawberries."

Environmental Effects of Coal Mining

Coal Impoundments

Political/Social Effects of Coal Mining

The Dirty Truth About Coal

And don't forget those transmission lines which transport all that sweet, juicy, "strawberry" goodness to Washington, D.C. and other markets, such as these transmission corridors through Jefferson County, West Virginia.

And these are just the existing 50 year old (or older) transmission lines.  Project Mountaineer aims to add an additional, larger line (PATH) parallel to the existing corridor, expanding it another 200 feet, right on top of many of the homes shown in the photos.

Project Mountaineer's TrAIL project gave West Virginia a taste of "fresh strawberries," demonstrating what construction of new transmission lines will mean for the people and environment.

Maybe the people of West Virginia (not including paid-off politicians and the greedy, out-of-state corporations who own West Virginia generation and transmission) are tired of "farming strawberries" in exchange for "benefits" like those shown above.

Perhaps Commissioner Moeller should take a tour of The Mountain State, while we still have a few mountains left, and find out exactly how his "strawberries" are farmed and transported to market.

Two PATH opposition groups from Maryland and one from West Virginia have filed preliminary comments on DOE's 2012 National Electric Transmission Congestion Study.

Comments covered a variety topics, such as decreasing demand, rebuilds, offshore wind, the PJM cartel and environmental justice.

Sugarloaf Conservancy's comments can be viewed here.

StopPATH WV, Inc.'s comments can be viewed here.

Citizens Against Kemptown Electric Substation's (CAKES) comments haven't been posted yet, but I will update when the link finally shows up.

Now we'll see how nicely DOE plays when citizens intrude into their "stakeholder" playpen.

Check out what Bill Howley dug up over at The Power Line.  It seems that a WV landowner is annoyed at PATH and the developer he bought property from that, unbeknown to him, PATH was planning to plow right through it.  The developer claims that it was also unaware about PATH until after the sale.

PATH is represented by the odious and insufferable shysters from Jackson Kelly that were so much fun during the PATH CPCN case in West Virginia.  The sophomoric haranguing of opponents that floats Jackson Kelly schmuck Melick's boat comes through loud and clear.

Q.    Did -- did anybody at PATH try to force you to sell property to them at this time?
A.    No.
MR. BOWLES:    I'm going to object to the form of the question. What does "force" mean? It's not clear.
MR. MELICK:    That's an English word.
Q.    (By Mr. Melick) Did anybody -- if you don't understand the question, I'll -- I'll explain it to....

Honestly, what a dipstick.  But once you get over the vaudeville going on, reading PATH's feeble lies is interesting, in a train wreck sort of way.  For instance, the Melick-clown keeps trying to insist that had the developer properly recorded the subdivision with the county that PATH would have avoided crossing through a subdivision.  Hahahahahahahaaa!  I seem to remember PATH's original route marching through my own subdivision (properly recorded in 1981) with such severity that 16 out of 31 existing homes would have been gone.  And then there was PATH's arrogant assertion to the owners of  these homes, at their dog & pony show, that these homes in the way would simply be torn down and disposed of.  Way to go, fellas!  :-)

So what? Even if the developer didn't record the subdivision properly, it's not going to win PATH any brownie points.

If you're one of the thousands of landowners who still has PATH's "suspended" project looming over your property, this might be a case worth following.

FERC issued an Order on Remand last Friday.

Back in 2007, while gearing up for the billions of dollars that PJM's coal-fired Project Mountaineer transmission projects would cost, FERC issued Order No. 494, which socialized the cost of these exorbitantly expensive, unneeded projects over a larger customer base. Once authorized by FERC in the Order, PJM changed its cost allocation methods to adopt the “postage-stamp” method of allocating the cost of new transmission in its RTEP that operates at or above 500 kV.  Prior to Order No. 494, all new transmission was paid for through a “license plate” methodology whereby those who directly benefited from the project would shoulder the cost.

Under a license-plate (or zonal) rate design, a customer pays the embedded cost of transmission facilities that are located in the same zone as the customer. A customer does not pay for other transmission facilities outside of the zone, even if the customer engages in transactions that rely on those zones.

Under a region-wide, postage-stamp methodology, all transmission service customers in a region pay a uniform rate per unit-of-service, based on the aggregated costs of all covered transmission facilities in the region.

Due to these new postage stamp rates, a high percentage of regional load, and the  wide geographic reach of the PJM region, customers in Illinois suddenly found themselves being charged the second highest percentage of eastern PJM’s Project Mountaineer costs.

“However, the cost shifts that would be incurred by switching from the DFAX methodology to the postage-stamp methodology are significant, resulting in western zones paying between 1,260 percent and 22,500 percent more for these facilities.”

The Illinois Commerce Commission objected to this inordinate cost, compared to “benefits” received, and the issue ended up before the 7th Circuit Court of Appeals.  In October of 2009, the Court remanded the rate methodology back to FERC, finding that the Commission had not provided sufficient record evidence to justify its findings that the existing allocation practice for new facilities at and above 500 kV was unjust and unreasonable, and the Commission had not adequately supported its conclusion that the postage-stamp methodology was just and reasonable. The court found that the Commission’s reliance on the difficulty of measuring benefits for above 500 kV facilities, and the resulting likelihood of litigation, failed to justify the Commission’s decision. The court stated that the Commission had failed to show “the absence of any indication that the difficulty exceeds that of measuring benefits to particular utilities of a smaller-capacity transmission line.” The court further found that the Commission failed to justify requiring PJM to adopt a region-wide, postage-stamp cost allocation methodology for new transmission facilities that operate at or above 500 kV.

However, the court also recognized that, in comparing costs and benefits, the Commission “does not have to calculate benefits to the last penny, or for that matter to the last million or ten million or perhaps hundred million dollars.”  FERC seems to have taken this to heart in their Order on Remand, issued on Friday.  To summarize, the Order determined that allocating costs of transmission enhancements that operate at or above 500 kV to utility zones using a postage-stamp cost allocation methodology is a just, reasonable and not unduly discriminatory method of allocating the costs of these new facilities.

In order to get there, FERC provided what it feels is the justification the court found missing in Order No. 494.

“In summary, ComEd, along with the other western utilities, will receive significant benefits from the new 500 kV and above projects that prevent the degradation of the PJM transmission system and maintain the capability to continue to produce up to $2.2 billion in estimated system-wide savings each year, as indicated by the ISO/RTO metrics report, along with additional estimated annual savings associated with decreased service interruptions and power quality disturbances, reduced line losses, and reduced congestion. These estimated annual, system-wide savings totaling approximately $2.2 billion compare favorably to the annual, system wide costs of approximately $1.3 billion for the facilities at issue here. In total, PJM’s transmission system provides ComEd’s customers with access to savings of approximately $320 million to $468 million each year.  While we recognize that there is imprecision in valuing the benefits of new 500 kV and above facilities, these estimated savings identified herein provide sufficient justification for allocating approximately $198 million per year in costs to ComEd under the postage stamp methodology for new transmission facilities necessary to maintain the integrity and reliability of the existing system so that customers will continue to have access to savings and to provide for future needs.”

I suppose it shouldn't come as any real surprise, since the "fix" has been in on the sale of three national parks since last fall, so let's call it outrageous, disgusting and contemptible.  The Obama Administration, Secretary of the Interior Ken Salazar, and the upper echelon of the National Park Service sold something that belongs to YOU to two huge energy corporations today.  And guess what?  YOU will pay for the energy corporations' bribe!

After recommending the "no action" alternative for the Susquehanna-Roseland Transmission Line last fall, the NPS reversed themselves today and selected the power companies' preferred Alternative 2, the most damaging route across the Delaware Water Gap National Recreation Area, the middle Delaware National Scenic River, and the Appalachian Trail.

“In identifying the preferred alternative, we closely examined the existing easements owned by the utilities, the impacts of the proposed transmission line, alternatives to the proposal, and mitigation measures to avoid and minimize adverse impacts to park resources,” said Dennis Reidenback, the Park Service's Northeast regional director.

Oh, and those "mitigation measures?"  That is the $40M land-bribe that the power companies are offering to the NPS in exchange for license to ruin three parks that belong to the citizens of the United States.  And, under federal electric ratemaking schemes, the power companies won't be paying that $40M.  They are permitted to recover the full amount from ratepayers in 13 states and the District of Columbia over the next 50 years.  Under the same ratemaking scheme, the power companies will also make a profit on this $40M through the 12.9% interest they will earn on the unpaid balance of the $40M bribe each and every one of the next 50 years.  The Obama Administration and the National Park Service has sold YOUR parks to corporations and is making you pay for the bribe they received in return for agreeing to the sale of YOUR assets!  

Although the power companies and the Obama Administration are pretending that the Susquehanna-Roseland line will "save you money" by alleviating made-up "congestion," it's all a bunch of phony invention.  Susquehanna-Roseland is going to do nothing but make my electric rates go up.  Hmm... wouldn't this make a delicious formal complaint?  

Check out the comments of New Jersey Sierra Club Director Jeff Tittel, who isn't afraid to call a spade a spade.

"Today the Obama administration sold out our National Parks.  Lands that are supposed to be protected for future generations, they turned over to power companies. This is a shameful day in the long history of our parks and may set precedent for more gas and power lines through our parks.  This decision is an insult to the more than 5 million people that visit the Water Gap every year," said Jeff Tittel, Director, NJ Sierra Club.

"We will continue fighting this project, even in the Courts if necessary.  We will stand up for the integrity of our National Parks, even if the Department of Interior will not."

"This is all about the power of money, whether it is coal companies and utilities pushing a power line that will cut through a national park, or people standing in line to get mitigation money so that they can profit on the destruction of a National Park's resources."

Perhaps worst of all, the environmental destruction could cause a severe infestation of bolt weevils in the Parks!!

In the wake of Judge Dwyer's affirmation of Frederick County, Maryland's, Board of Zoning Appeals denial of a special exception for PATH's  gigantic substation last month, PATH had 30 days to file further appeals.  The deadline quietly passed at the end of last week, with no further whiny filings from PATH.  They've finally shut up about it, at long last!  Break out the ale!

Is this another indication that PATH is precariously perched on the precipice of abandonment?  C'mon, let's get on with it!  No time like the present.

March 28 addendum:  We now have "official" quotes from PATH stating that it will not file further appeals.

Although PATH's talking head claims that PATH's "rationale" (when has PATH ever made a rational decision?) for the decision is "confidential," it's more than obvious.  Contentious federal abandonment hearings, where PATH will have to prove the prudence of its expenditures, are starting to become more of a certain reality to the companies.  

One of the incentives that the PATH Project was granted by FERC way back in 2008 was a guarantee for recovery of 100% of prudently incurred investment in the event the project is abandoned.  PATH hopes to recover their approximately $140M investment in the project from ratepayers in 13 states over an as yet undetermined number of years (for their TrAILCo project, they suggested 49).

When PJM put the PATH Project "in abeyance" last February 28, continued costly appeals on the substation decision were no longer prudent.
"As we've discussed on numerous occasions, the proposed PATH Project, including the proposed Kemptown Substation, remains in suspension at the direction of PJM. Potomac Edison will consider its options for constructing the Kemptown Substation if the PATH Project should be re-activated by PJM," Meyers wrote.
If continued legal appeals are no longer prudent, PATH's first appeal to Circuit Court was not prudent either, since it occurred after the "suspension."

PATH has been spending your money willy-nilly on whatever they thought would foster the influence they would need to ram this project through state approvals.  They never thought they would be challenged on their expenditures, or that their project could fail.  Now they're left "holding the bucket" and this particular bucket is not full of water, electricity or money.  It's chock full of something rather pungent...

That old adage, "what goes around comes around" never fails.  While we may have been mentally and financially tormented by AEP's PATH subsidiary for the past (nearly) 4 years, AEP is getting plenty of torment of their own in return lately.  And, it couldn't happen to a nicer bunch of *insert inappropriate word here*!  So, pull up a chair and let's get started.

We've been following AEP's pummeling at the hands of fed up customers in Ohio.  Earlier this week, AEP-Ohio had a serendipitous changing of the guard when the President (who got them into this mess) left for another job with a gas company.  "Curiouser and curiouser," cried Alice... 

Today, AEP-Ohio held what they called a public forum at the PUCO, although PUCO denied official responsibility for the process as being a part of any active case.  Over a hundred angry customers from all classes, such as small business, large business, residential, schools, non-profits, etc., showed up to return a little of their misery to AEP. 

The mayor of Hillsboro had this to say, "AEP lit a prairie fire with its destructive actions and brought itself intractable and vocal critics, including myself and the people I represent." 

Customers also told AEP they're tired of the incomprehensible gibberish that goes on in rate cases and in the bills they receive.  AEP pretended to take a lesson and incorporate the customers' concerns in their new rate filing expected next week.  Somehow, I don't believe that AEP hasn't started putting together their rate filing yet.  I would bet it's already done and the most the public's concerns will do is slightly modify things here and there.  If AEP really cared what the consumers think, they would have been paying attention all along, instead of ignoring consumer pain and crowing about their earnings every quarter.  These consumers aren't going away, and AEP is unlikely to truly change their behavior.  This story will continue...

Meanwhile, in Virginia, Attorney General Ken Cuccinelli, who desperately wants to be elected Governor next year has been holding town hall meetings to grandstand as "the people's lawyer" and pretend to explain electric rate increases to the voters.  He vigorously defended AEP's Appalachian Power subsidiary's recent rate increases and said they were caused by anything but the truth -- AEP's out-of-control coal addiction.  The only problem here is that ol' Kook doesn't know what the heck he's talking about.  He said previous rate increases in Virginia are the fault of the EPA (for regulations that haven't even been effected yet). 

He must have served some really potent Koolaid, as one Stepford wife said on her way out the door, “The EPA regulations are having a negative effect on the rates for people.” 

But where was Kooky Ken when Appalachian Power was granted recovery of 50% of their charitable contributions from ratepayers last year?  He forgot to mention that!  I guess "the people's lawyer" is looking for some of "the power company's campaign contributions."

Also this week, AEP officially notified PJM and SPP of anticipated plant closures.  It ended up being over 1,000 MW less than AEP has been bellyaching over since June, due to some creative math that suddenly made it more economical to install a scrubber on Big Sandy than to repower one of the units with natural gas (not that anyone believes them).  The Little Drummer Boy's canned quote shows how much denial of fact still predominates at AEP. 

"Our retiring units were required to run to meet peak demand last summer, and little new generation is scheduled to come on line prior to the retirement dates to replace this lost generating capacity." 

He continues to ignore the fact that previous "peak" is being vigorously hacked down to size by booming demand side management and energy efficiency.  Oh, cry me a river!

Closer to home in West Virginia, Appalachian Power is salivating at the thought of Century Aluminum reopening.  Century has been offered a $20M "tax break" to pay for electricity supplied by APCo.  And whose pocket do taxes come from?  Yours!  Be sure to thank your legislator for that one! 

Also, APCo has polished up its "economic development efforts" by re-hiring some guy they laid off years ago.  Good luck with that, I'm sure businesses just can't wait to relocate to West Virginia, where they will be paying off old coal debt for power that was consumed by other ratepayers in 2008.  What an incentive!

What will AEP do for an encore next week?

CleanTechnica, who prides itself on being "the most-visited clean energy or cleantech news site in the world" that "share[s], and inspire[s] others to share, correct information on cleantech and its dirty competitors (there’s a lot of misinformation out there)," got ironically fished in by one of the biggest energy industry scams in Washington.  Yesterday, they published an analysis of PJM's 2011 State of the Market Report, to show gains in renewables and demand side management, and a drop in coal-fired resources.  While that part of the article could certainly be fairly argued with (and is, by many flat earth cavemen), CleanTechnica loses all credibility when it finishes up by quoting The COMPETE Coalition as a "group of 622 U.S. electricity industry stakeholders advocat[ing] for competitive electricity markets," and refers to one of COMPETE's PR spin opinion pieces as a "report."  So much for "correct information."

The COMPETE scam isn't even that hard to figure out.  The truth is readily available for any reporter who wants to spend a few minutes doing something more than copying & pasting text from a website.

Here's what the COMPETE Coalition is really all about:  It is a corporate-funded lobbying group intended to protect its Board of Director's generation revenue monopolies, including revenue derived from Reliability Must Run (old, dirty, generation) contracts and new coal-by-wire transmission projects.  I'm sure it's perfectly legal to pretend the coalition is a 501(c)6 trade association with a membership that pays "dues," and not an organization whose sole purpose is lobbying for their own financial interests.  The coalition accomplishes this under the guise of supporting competition in electricity markets, which is the exact opposite of their true goal.  While the APPA article linked below has more general information about COMPETE's overall scam, a recent example of coalition chicanery would be COMPETE's deployment of shills to interfere in New Jersey's LCAPP hearings.  COMPETE claims that RMR contracts and transmission lines produce cheaper electric rates than building new, competitive generation in high-priced markets, like New Jersey's.  This isn't true at all.  In the case of new transmission lines, for instance, the cost of the project is subsidized by ratepayers in 13 other states, making New Jersey's cost of new transmission to satisfy load deceptively "cheaper" only through creative accounting.

The COMPETE Coalition fairy tale was deconstructed in the publicly-filed Formal Challenge to Potomac-Appalachian Transmission Highline's 2010 Transmission Revenue Requirement.  The Challenge (complaint), which was filed by two concerned ratepayers with the Federal Energy Regulatory Commission in December 2011, had this to say about COMPETE:

Click here to read more and see full, linkable content

There's plenty of new reading waiting for you over on the citizens' Coalition blog!

Just when you had puzzed and puzzed until your puzzler was sore trying to interpret PJM's 5-book RTEP set, concisely edited by Leo Tolstoy, PJM has issued another voluminous report.  The 2011 State of the Market Report is like the world's biggest fortune cookie, with your hidden fortune cleverly translated into Ancient Sanskrit.  I wish PJM would get more efficient and issue Magic 8 Balls instead.  I mean, how easy it could be to give it a shake and say, "Oh, PJM Magic 8 Ball, will the PATH Project be coming back?"  The PJM Magic 8 Ball would give you an immediate answer like, "Don't count on it!"  Instead all we get are these encyclopedic mystery novels with "Reply hazy, try again!" stamped on the front cover.

Here's PJM's CliffsNotes version press release summarizing the report.  This is about as concise as it gets:

"The report noted that gas prices fell and coal prices rose in 2011. Gas prices decreased on average by 10 percent and coal prices increased on average by 19 percent in 2011. PJM LMPs were lower. The load-weighted average LMP was five percent lower in 2011. PJM capacity prices were lower. PJM average capacity prices were 18 percent lower in 2011. Operating reserve charges increased by 1.0 percent in 2011. Congestion costs decreased in PJM by 29.9 percent in 2011."

Inside the big report, there's a section entitled, "Generation and Transmission Planning" (Volume 2, Sec. 11!)  The report's mention of PATH seems to be missing one crucial fact -- that this project is supposedly "suspended."  The report prattles on like PATH hasn't skipped a beat, but throws you a tiny little bone at the end saying that PJM is "considering new information."  What is that supposed to mean, PJM Magic 8 Ball?  "Outlook not so good."  I hope Magic 8 Ball was speaking from PATH's perspective...

The Potomac - Appalachian Transmission Highline (PATH) project is required to resolve reliability criteria violations. The PATH project consists of a 765 kV transmission line extending approximately 275 miles from the Amos Substation, which is located in southwestern West Virginia, to the proposed Kemptown (765/500 kV) Substation, located in central Virginia. The project also includes a new Welton Spring (765/500 kV) Substation.
Currently, right-of-way issues are being discussed in West Virginia, Virginia and Maryland. The property for the Welton Spring and Kemptown substations has been acquired. The preliminary engineering design work, as well as the preliminary procurement activities, is in progress. Construction will be scheduled to begin following receipt of state commission approvals to construct. The required in-service date for the PATH line is June 1, 2015.
PJM is in the process of considering new information, including fuel cost estimates, emissions costs, future generation scenarios, load forecast updates and demand response projections.

Further down in the report, the MMU goes and gets all cranky about transmission projects dropping out of the RTEP messing up his little markets and makes this recommendation:

"The MMU recommends that PJM propose modifications to the transmission planning process that would limit significant changes in the status of major transmission projects after they have been approved, and thus limit the uncertainty imposed on markets by the use of evaluation criteria that are very sensitive to changes in forecasts of economic variables."

Way to send us all to the poor house, MMU!

This little transmission project went to market,
This little transmission project stayed in the RTEP,
This little transmission project is "in abeyance,"
And this little transmission project is not,
But this little transmission project cried, "Wah, Wah, Wah" all the way to abandonment.

Don't you just love the new "stakeholder friendly" PJM?