Grassroots group Residents Against Giant Electric (RAGE) continues its outstanding work against FirstEnergy's Monmouth County Reliability Project (MCRP) in urban New Jersey.
In a recent article (and video) former NJ Transit vice-chairman Bruce Meisel vehemently opposed the MCRP, calling it "... a money grab project that puts the interests of JCP&L over the residents and ratepayers of Monmouth County.”
The significance of Meisel's opposition stems from MCRP's proposal to use New Jersey Transit's right of way for its project. Without the approval of the NJT board, this project isn't happening.
The article says Meisel was most affected by the number of signs and the people opposing the project across the area when he took a tour of the area late last year. That's directly attributable to the work of RAGE, who have been very effective winning the hearts and minds of the community and local governments.
If FirstEnergy thinks it can shout down this kind of opposition with a few well-paid business or labor advocates, its got another think coming. There's nothing FirstEnergy can do to stem the tide of opposition to its project. It's over. MCRP lost. Projects with this kind of political opposition never get approved. Time for Plan B.
In recent press, FirstEnergy has been turning with increased frequency to what it may feel is its most powerful weapon... PJM Interconnection.
The significance of Meisel's opposition stems from MCRP's proposal to use New Jersey Transit's right of way for its project. Without the approval of the NJT board, this project isn't happening.
The article says Meisel was most affected by the number of signs and the people opposing the project across the area when he took a tour of the area late last year. That's directly attributable to the work of RAGE, who have been very effective winning the hearts and minds of the community and local governments.
If FirstEnergy thinks it can shout down this kind of opposition with a few well-paid business or labor advocates, its got another think coming. There's nothing FirstEnergy can do to stem the tide of opposition to its project. It's over. MCRP lost. Projects with this kind of political opposition never get approved. Time for Plan B.
In recent press, FirstEnergy has been turning with increased frequency to what it may feel is its most powerful weapon... PJM Interconnection.
JCP&L has been consistent on the project’s need, which stems from a decision made by PJM Interconnection, a regional grid operator that oversees 13 states and the District of Columbia – New Jersey being one of those 13. PJM has stated that a 2011 review found that Monmouth County’s electrical system violates reliability criteria.
FirstEnergy has quickly gotten to the bottom of its bag of tricks and pulled out what it may feel is its trump card. PJM says it's needed and therefore there is nothing anyone can do about it. FirstEnergy wants its opposition to believe that PJM's approval of the project is the final word and that there are no alternatives. FirstEnergy wants its opposition to believe PJM is an omnipotent authority whose word can never be questioned.
Most people have never heard of PJM. PJM is a mystery to the average electric consumer, and after years of watching the PJM dance, I'd have to conclude that PJM likes it this way. PJM has never seen any value in making itself understandable and accessible to the consumers it serves. While touting itself as "transparent" and open to any "stakeholders," PJM is a hopelessly bureaucratic and technical maze that electric consumers aren't supposed to figure out. Sort of like this guy:
Most people have never heard of PJM. PJM is a mystery to the average electric consumer, and after years of watching the PJM dance, I'd have to conclude that PJM likes it this way. PJM has never seen any value in making itself understandable and accessible to the consumers it serves. While touting itself as "transparent" and open to any "stakeholders," PJM is a hopelessly bureaucratic and technical maze that electric consumers aren't supposed to figure out. Sort of like this guy:
PJM Interconnection is a regional transmission organization (RTO) that coordinates the movement of wholesale electricity in all or parts of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of Columbia.
Acting as a neutral, independent party, PJM operates a competitive wholesale electricity market and manages the high-voltage electricity grid to ensure reliability for more than 65 million people.
PJM’s long-term regional planning process provides a broad, interstate perspective that identifies the most effective and cost-efficient improvements to the grid to ensure reliability and economic benefits on a system wide basis.
An independent Board oversees PJM’s activities. Effective governance and a collaborative stakeholder process help PJM achieve its vision: “To be the electric industry leader – today and tomorrow – in reliable operations, efficient wholesale markets, and infrastructure development.”
PJM's planning process uses NERC criteria to define reliability violations that must be remedied. Who is NERC?
The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to assure the reliability and security of the bulk power system in North America. NERC develops and enforces Reliability Standards; annually assesses seasonal and long‐term reliability; monitors the bulk power system through system awareness; and educates, trains, and certifies industry personnel. NERC’s area of responsibility spans the continental United States, Canada, and the northern portion of Baja California, Mexico. NERC is the electric reliability organization for North America, subject to oversight by the Federal Energy Regulatory Commission and governmental authorities in Canada. NERC’s jurisdiction includes users, owners, and operators of the bulk power system, which serves more than 334 million people.
Had enough acronyms yet? This industry loves acronyms, it's their own special language that you aren't supposed to understand!
So, NERC sets reliability standards, and PJM uses NERC's standards in its planning process. PJM and NERC are membership organizations. Who are their members? Companies with an interest in the work of the organization. The industry sort of regulates itself within these organizations. If the organizations are controlled by their members, and their members are the industry, then PJM and NERC are controlled by the companies they regulate. PJM didn't use NERC violations to design the MCRP. FirstEnergy proposed the MCRP to resolve NERC violations that showed up in PJM's 2011 planning process. PJM simply rubber stamped the incumbent utility's solution to the problem, and nobody proposed any alternatives or spoke against it, therefore it was "ordered" by PJM's Board of Managers.
In its application to the NJ BPU, FirstEnergy says MCRP was the remedy for NERC N-1-1 (or Category C) violations. If you stack up the different types of violations, N-1-1 comes at the bottom of the stack. N-1-1 relies on a reliability comedy of errors to occur -- that one component of the system fails, and then a bunch of other components that were supposed to act as back up for that component also fail. FirstEnergy describes the necessity for MCRP like this:
So, NERC sets reliability standards, and PJM uses NERC's standards in its planning process. PJM and NERC are membership organizations. Who are their members? Companies with an interest in the work of the organization. The industry sort of regulates itself within these organizations. If the organizations are controlled by their members, and their members are the industry, then PJM and NERC are controlled by the companies they regulate. PJM didn't use NERC violations to design the MCRP. FirstEnergy proposed the MCRP to resolve NERC violations that showed up in PJM's 2011 planning process. PJM simply rubber stamped the incumbent utility's solution to the problem, and nobody proposed any alternatives or spoke against it, therefore it was "ordered" by PJM's Board of Managers.
In its application to the NJ BPU, FirstEnergy says MCRP was the remedy for NERC N-1-1 (or Category C) violations. If you stack up the different types of violations, N-1-1 comes at the bottom of the stack. N-1-1 relies on a reliability comedy of errors to occur -- that one component of the system fails, and then a bunch of other components that were supposed to act as back up for that component also fail. FirstEnergy describes the necessity for MCRP like this:
In the 2011 RTEP, PJM identified reliability criteria violations of NERC Category P7 (previously NERC Category C) contingencies for the outage of the Atlantic-Red Bank (S1033) 230 kV line and the No. 2, 230-34.5 kV transformer with the loss of the Atlantic-Red Bank (T2020) 230 kV line and the No. 8, 230- 34.5 kV transformer due to failure of a common structure containing both circuits. JCP&L confirmed this contingency may result in more than 700 MW of load loss, well above the 300 MW loss of load criterion limit, which violates the JCP&L Planning Criteria as well as PJM planning criteria. The JCP&L-proposed Project was confirmed by PJM that it adequately addresses the reliability criteria violation.
So, one transmission line is out, and then a transformer fails, and then another transmission line goes out, and then another transformer fails.... and then you need the MCRP to provide service. That's 2 transmission lines and 2 transformers, all out of service at the exact same moment. Chances of that happening? Not likely, but it could happen, in theory. However, it's not likely that failure to build the MCRP as proposed is going to make the lights in New Jersey go off in the near future. Because if we want to play the "what-if" game, what if the MCRP also fails after the other 2 transmission lines and the other 2 transformers fail? But NERC doesn't go that far out in its "what if" game, because it starts to get a little ridiculous.... and expensive.
A NERC violation was identified by PJM, FirstEnergy's JCP&L came up with a "back of the envelope" solution, PJM's Board of Managers approved the solution and assigned construction to JCP&L with a June 1, 2016 in-service date. And then JCP&L began trying to implement their proposed solution. The next year, JCP&L notified PJM that they couldn't get it done in time and proposed an extension of the in-service date to June 1, 2017. And then JCP&L notified PJM a second time that the projected in-service date is now June 1, 2019. In its application, FirstEnergy shares
A NERC violation was identified by PJM, FirstEnergy's JCP&L came up with a "back of the envelope" solution, PJM's Board of Managers approved the solution and assigned construction to JCP&L with a June 1, 2016 in-service date. And then JCP&L began trying to implement their proposed solution. The next year, JCP&L notified PJM that they couldn't get it done in time and proposed an extension of the in-service date to June 1, 2017. And then JCP&L notified PJM a second time that the projected in-service date is now June 1, 2019. In its application, FirstEnergy shares
PJM has not changed their required date for the project, but has listed the projected in-service date as June 1, 2019 in the RTEP Transmission Construction Status database... Note the PJM Required Date is the date the violation is initially identified to occur.
Apparently the violation keeps slipping out in time to keep pace with JCP&L's failure to get its proposed project accomplished. How convenient! I guess this "violation" isn't as urgent as FirstEnergy claims. If the two transmission lines and two transformers fail tomorrow, PJM will still be able to keep the lights on using other components of the system. But if the failure happens on June 1, 2017 (or 2019?), the lights will go out unless MCRP is there to pick up the slack. Seems pretty improbable, doesn't it?
Nevertheless, as a member of PJM, FirstEnergy's JCP&L was assigned construction responsibility for the MCRP. Membership comes with responsibilities. Members pledge to follow PJM's operating rules, such as constructing projects which they are assigned. The PJM Operating Agreement obligates the member to build, but it also gives the member an "out" if things go wrong with the project, such as a failure to secure required state or local permits.
Nevertheless, as a member of PJM, FirstEnergy's JCP&L was assigned construction responsibility for the MCRP. Membership comes with responsibilities. Members pledge to follow PJM's operating rules, such as constructing projects which they are assigned. The PJM Operating Agreement obligates the member to build, but it also gives the member an "out" if things go wrong with the project, such as a failure to secure required state or local permits.
1.7 Obligation to Build.
(a) Subject to the requirements of applicable law, government regulations and approvals, including, without limitation, requirements to obtain any necessary state or local siting, construction and operating permits, to the availability of required financing, to the ability to acquire necessary right-of-way, and to the right to recover, pursuant to appropriate financial arrangements and tariffs or contracts, all reasonably incurred costs, plus a reasonable return on investment, Transmission Owners or Designated Entities designated as the appropriate entities to construct, own and/or finance enhancements or expansions specified in the Regional Transmission Expansion Plan shall construct, own and/or finance such facilities or enter into appropriate contracts to fulfill such obligations.
PJM monitors the project's progress to meet certain milestones.
1.5.8 (j) Acceptance of Designation. Within 30 days of receiving notification of its designation as a Designated Entity, the existing Transmission Owner or Nonincumbent Developer shall notify the Office of the Interconnection of its acceptance of such designation and submit to the Office of the Interconnection a development schedule, which shall include, but not be limited to, milestones necessary to develop and construct the project to achieve the required in-service date, including milestone dates for obtaining all necessary authorizations and approvals, including but not limited to, state approvals.
1.5.8 (k) Failure of Designated Entity to Meet Milestones. In the event the Designated Entity fails to comply with one or more of the requirements of Section 1.5.8(j); or fails to meet a milestone in the development schedule set forth in the Designated Entity Agreement that causes a delay of the project’s in-service date, the Office of the Interconnection shall re-evaluate the need for the Short-term Project or Long-lead Project, and based on that re-evaluation may: (i) retain the Short-term Project or Long-lead Project in the Regional Transmission Expansion Plan; (ii) remove the Short-term Project or Long-lead Project from the Regional Transmission Expansion Plan; or (iii) include an alternative solution in the Regional Transmission Expansion Plan.
PJM isn't so much wedded to a certain project as it is compelled to find a solution to impending violations. A project that fails to be permitted goes back to the drawing board, and PJM works with the utility to find an alternative solution that can be permitted. Ill-conceived projects that draw staunch, sustained and wide-spread opposition rarely get permitted. Who's monitoring JCP&L's "milestones" on the MCRP project? Is PJM actively and independently monitoring MCRP's milestones, or are they simply taking FirstEnergy's word for it that its MCRP is on schedule and meeting milestones? JCP&L's poor execution of this project has already cost the consumers three years of reduced reliability. At what point will PJM "re-evaluate" the MCRP instead of simply shifting the milestones JCP&L fails to meet into the future?
While it is true that PJM has identified MCRP as the solution to future violations, that's only part of the story. PJM can act to re-evaluate a failing project to come up with a better solution to prevent reliability violations. PJM's mission is reliability, not adhering to rigid project concepts proposed by its members. In fact, PJM transmission projects are suspended, canceled, or re-evaluated frequently. PJM's approval of a certain project does not set its completion in stone. PJM is subject to the outside forces of state regulators, who hold the ultimate authority to permit a certain project. And state regulators are subject to the outside forces of state citizens who may support or oppose certain projects that are proposed. The NJ BPU must weigh the benefits of the project against its detriments and find that the benefits outweigh the detriments. If it does not find the MCRP beneficial, the NJ BPU may deny the project a permit. And then it would be kicked back to PJM to come up with an alternative solution. This sounds like a very long and expensive road, and ultimately it could cost JCP&L customers their reliable electric service.
When will it be time for PJM to pull the plug on the MCRP? Now, while there's still time to find an alternative solution to looming reliability violations? Or later, when the lights go out?
While it is true that PJM has identified MCRP as the solution to future violations, that's only part of the story. PJM can act to re-evaluate a failing project to come up with a better solution to prevent reliability violations. PJM's mission is reliability, not adhering to rigid project concepts proposed by its members. In fact, PJM transmission projects are suspended, canceled, or re-evaluated frequently. PJM's approval of a certain project does not set its completion in stone. PJM is subject to the outside forces of state regulators, who hold the ultimate authority to permit a certain project. And state regulators are subject to the outside forces of state citizens who may support or oppose certain projects that are proposed. The NJ BPU must weigh the benefits of the project against its detriments and find that the benefits outweigh the detriments. If it does not find the MCRP beneficial, the NJ BPU may deny the project a permit. And then it would be kicked back to PJM to come up with an alternative solution. This sounds like a very long and expensive road, and ultimately it could cost JCP&L customers their reliable electric service.
When will it be time for PJM to pull the plug on the MCRP? Now, while there's still time to find an alternative solution to looming reliability violations? Or later, when the lights go out?
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