Legalectric

PJM’s Plan for Delaware

Sure hope so — they’ve got it coming.  Cost apportionment is a big issue, and for PJM, well, they’d taken their cost apportionment dream to FERC, got the FERC rubber stamp, but it seems they’ve not done a good job of it, according to the Federal Court — that’s old news:

Illinois Commerce Commission v. FERC August 6, 2009

Fast forward to today — turns out Delaware’s Gov. Markell is objecting to costs assessed to Delaware ratepayers, (though I’m not seeing any objection to the project itself coming out of Delaware).  DOH!  He’d better, this project does nothing for Delaware.

Here’s the PJM Planning doc that tells all:

PJM White Paper Artificial Island Project

Note on the first page the statement of need, of why this project is wanted — this is really important:

PJM specified that solution proposals must improve stability margins, reduce Artificial Island MVAR output requirements and address high voltage reliability issues.

So let me get this straight — they’re having stability and reliability issues and PSEG wants to reduce Artificial Island MVAR output requirements, and want to charge Delaware ratepayers for this?  PUH-LEEZE… This is a benefit to PSEG, not Delmarva…

And look what our big-coal friends at ODEC have to say:

ODEC letter regarding Artificial Island 7-29-2015

This project taps into the new line that was built not long ago:

Delaware has no regulation of transmission need or siting — so utilities can pretty much do whatever they want.  Further, it’s a FERC tariff, so the state doesn’t have anything to say about it going into the rates, and cost apportionment.  Great, just great.  So now Markell is objecting?  It’s a little late…

Delaware needs legislation — legislation like a “Power Plant Siting Act” and a legislative requirement of a need determination for whatever infrastructure they think they want.  They need legislation specifying that only Delaware utilities can own and operate transmission in Delaware (see House Bill 387 from the 2014 session).  Here’s what House Bill 387 would have done (It would have been an effective good start, protective of Delaware!), establish that a utility wanting to construct and operate transmission demonstrate NEED!  Here’s the wording, though it would require quite a bit more, and some solid rules, to be effective:

(5)Public utility electric transmission service providers must have a certificate of public convenience and necessity for the construction and operation of any new electric transmission lines operating at 100KV or greater and located in the State or offshore waters and integrated with the State electric transmission grid.In granting such certificate, the Commission shall consider:

a.the need for the proposed transmission line;

b.the impact on the reliability of the transmission grid

c.the long term viability of the public utility proposing the line;

d.the technical engineering and operating expertise of the public utility;

e.the technology and design proposed for the new transmission line; and

f.the economic and safety impact of the proposed transmission line.

Here’s the report about this PJM approval from Jeff Montgomery, News Journal:

Disputed cost-shares remain in plan for new power line

Note this snippet:

PJM officials said regional and federal rules and precedents obliged the organization to assign 99.99 percent of costs to Delmarva’s transmission zone, mostly in Delaware and Maryland.

The total includes the cost of a $146 million power line installation under the Delaware River and $68 million worth of transformer and substation work by Public Service Electric and Gas at the Artificial Island nuclear complex along the Delaware River southeast of Port Penn.

The Delaware Public Service Commission estimated that transmission costs would increase by about 25 percent in Delaware because of the plan.

“For the average residential consumer, monthly electric bills could increase by several dollars. For the average business, the increase may be more significant,” Markell said in his objection. “Some of our heaviest users could see increases of hundreds of thousands of dollars.”

And here’s the schedule for this project going forward from the PJM Board meeting yesterday:

Seems there’s an opportunity before the FERC ALJ.  But before then?  What is Delaware going to do?  Well, take a look at what Illinois did when it didn’t appreciate the FERC Cost Apportionment scheme — they sued FERC and won, based on the notion that if they weren’t benefitting, they shouldn’t be the ones paying:

Illinois Commerce Commission v. FERC August 6, 2009

The FERC Cost Apportionment scheme was remanded, and it’s in settlement negotiations right now.  What is Delaware doing in that docket?  To review the public postings, go HERE and search for FERC Docket EL05-121.  The next settlement conference is Thursday, August 6, 2015, starting at 10:15 a.m. in a hearing room at FERC HQ.  Delaware is represented in this, at least there are Delaware PSC staff listed on the service list, Janis Dillard, John Farber, and Robert Howatt.  So what are they doing about this cost apportionment scheme?  Seems this settlement conference is just the place for raising a stink about the PJM cost apportionment scheme, to raise issues of “benefits” and “cause cost, pay” arguments.  Are they showing up and speaking up for Delaware?

My world has turned black and white… here’s the view out the door, the tent for the airplane buckled this morning.  We had to go out and get fuel oil for the boiler and gas for the tractor and the roads haven’t been plowed from last weekend’s storm, and here we are now smack dab in the midst of another.  The governor has shut down the state, again… and meanwhile, tomorrow at 2 p.m. the New Jersey Board of Public Utilities is making its decision on the Susquehanna-Roseland, delayed from today because of the storm.  Well, it’s gonna be storming all day, so I don’t think that this one day will make a difference, other than those of us coming from a distance will probably have a harder time because they’ll be another foot and a half of snow.

Our little tent roof wasn’t the only one collapsing.  It could be a lot worse.   Schools, big boxes all over Delaware, and even the Townsend Fire Company roofs have collapsed:

Fair Use from The News Journal/ESTEBAN PARRA

Houses too:

And then there’s the Smithsonian warehouse:

… and more view out the window back door — those crab pots aren’t going anywhere anytime soon.  Just so that tree doesn’t come down on the van:

By standing up for offshore transmission for wind, Delaware’s Gov. Jack Markell stands up to Midwest coal!

The Mid-Atlantic states have been standing up and opposing transmission from the Midwest.  They’ve gone on record in a number of venues, and in their opposition are citing Midwest transmission promoters’ disregard for eastern renewable efforts, that xmsn may well not be an economical way to get power to the east, and that THEY KNOW THAT MIDWEST TRANSMISSION PLANS INHERENTLY ARE ABOUT COAL. The plan they’re referring to is a massive transmission buildout known as JCSP, and it also applies to the big PJM buildout that includes the PA-NJ Susquehanna-Roseland transmission line that was the subject of a hearing last month.

Here’s JCSP (Joint Coordinated System Plan) note their site now talks about wind — but look where the transmission starts, DUH! The coal fields of the Dakotas:

Gotta give them, Delaware, Maryland and Virginia, a lot of credit for recognizing and stating what Midwest states have been unwilling to admit.

That said, here’s what Mid-Atlantic states are doing — they’re banding together to propose offshore transmission.  If it’s underwater offshore transmission, that’s an idea that’s hard not to like.  But I’ll bet it throws PJM for a loop, what with all their “backbone” transmission schemes, a la Project Mountaineer, that are in the works:

The FERC birth of Project Mountaineer:

Exhibit STL D-6a (PSEG Discovery Response)

Exhibit STL D-6B (PSEG Discovery Response)

And you can see that those lines in play now, PJM’s “backbone” transmission projects like Susquehanna-Roseland (NE part of Project Mountaineer Line 1) and MAPP (NE part of Project Mountaineer Line 4) are part of the plan… the big transmission plan that does not work for the east coast.

Here’s the Memorandum of Understanding between Delaware, Maryland and Virginia:

DE, MD & VA Wind Infrastructure MOU

And recently, Gov. Jack Markell addressed these issues before American Wind Energy Association’s offshore windfest — but given the PJM big-transmission-projects-from-hell are referred to as “backbone” projects, I wish they’d find another term:

Delaware energy: ‘Backbone’ power line pushed for wind farms

By AARON NATHANS
The News Journal

BOSTON — If the Eastern Seaboard is to one day be dotted with thousands of wind turbines, they may as well work in harmony.

That’s the message 10 eastern governors are sending to the federal government as they advocate for a major underwater power line parallel to the East Coast.

U.S. offshore wind farm projects, all still on the drawing board, are being planned to include cables from the turbines to a substation on land to bring the power to the existing transmission grid.

The “backbone” power line the governors envision would connect the wind farms to each other, making it easier to spread wind power from areas where the wind is blowing robustly at that moment to states where electricity demand exceeds supply.

They see the backbone as preferable to a national investment in a transmission line that brings wind power from the Midwest to the East.

Gov. Jack Markell broached the subject this week in his address to the American Wind Energy Association’s offshore wind workshop, the industry event of the year on this side of the Atlantic. Markell signed onto letters the governors sent to members of Congress this summer, and the Federal Energy Regulatory Commission last month.

Governors of Vermont, New Hampshire, New York, Virginia, Maryland, New Jersey, Massachusetts, Rhode Island and Maine also signed the letters.

In an interview, Markell’s natural resources secretary, Collin O’Mara, said he wants to find out if there’s a way to spread out the costs of such a project. Building a backbone would help states satisfy their renewable electricity purchase requirements, and relieve the “spaghetti” structure of the current power grid, he said.

“Let’s have the conversation,” O’Mara said. “It’s extremely worthy of further study.”

Transmission is vitally important to getting offshore wind energy to population centers, said Denise Bode, the wind association’s president. And Gov. Donald Carcieri, R-R.I., called it “the elephant in the room.”

The power grid is “organized like a patchwork to meet local needs” rather than as a planned national system — almost an assemblage of local roads compared with an interstate, Carcieri said. The developers and government officials in attendance were very much aware of the role transmission will play in whether the offshore wind industry lives up to its potential.

The discussion comes as various offshore wind projects are maturing from concept to permitting, construction and design. At the moment, NRG-Bluewater Wind holds the only contract for offshore wind power, with Delmarva Power.

It’s starting the permitting process, getting ready to build weather towers off Delaware and New Jersey next summer, and preparing to bid for the right to develop an offshore wind project in New York City.

Jim Gordon, president of the Cape Wind venture that hopes to build in Nantucket Sound, told the convention he has all of the permits he needs from the state and federal government, but is working to overcome a tribal challenge that the waters in Nantucket Sound are protected.

The developer is working with the local utility — National Grid — to develop a contract to purchase power from the wind farm.

National Grid is also negotiating with Deepwater Wind for a contract to provide power to Rhode Island’s Block Island from a small, five-to-eight turbine facility in near-to-shore state waters. The company is also planning a larger wind farm in federal waters off the Rhode Island coast, which will take longer to build.

Deepwater, Bluewater and Fishermen’s Energy are planning wind farms off the New Jersey coast and the state government has provided incentives.

Deepwater CEO Bill Moore said, in principle, the backbone transmission line is “a terrific idea. It makes a lot of sense.”

But he said it’s a “daunting task” to complete an infrastructure project that crosses state boundaries, impacts different developers, and brings together different regional power grids.

“It obviously won’t happen in the absence of federal leadership,” he said.

Fishermen’s Energy President Daniel Cohen said it’s a good idea, but “it’s another moving part.”

“What comes first? Do you build the project or the backbone? People need to make decisions soon,” Cohen said, noting that the answer affects financing arrangements.

Gordon van Welie, president of ISO New England, the regional power grid manager, said there has been some investment in transmission upgrades, but a national plan is needed before new elements are selected.

“The rhinoceros in the room is the transmission cost allocation” — who benefits from a transmission line, and who pays for it, he said.

He noted that the New England governors adopted their own long-term vision of renewable energy, which included $6 billion in lines to transmit power from inland and offshore turbines to population centers.

The benefits of building lines transmitting wind power from the Midwest are less certain, he said.

“It will be difficult to get progress in this area until there are clear national goals,” he said.

Steven Bruckner, conservation chairman of the Virginia chapter of the Sierra Club, looked kindly upon the backbone idea. He said he didn’t have environmental concerns, although he wondered whether such a project would be economical.

“You’re talking hundreds, thousands of wind turbines off the coast, eventually displacing those coal burning power plants,” he said. “It’s the scale. It’s the beginning.”

Note that “cost allocation” is raised.  Since the 7th Circuit decision tossing out FERC approval of PJM’s transmission cost allocation dream/nightmare, all transmission projects 500kV and over based on that cost allocation scheme are in limbo.

Illinois Commerce Commission v. FERC – August 6, 2009

So as noted, who pays, and submarine transmission is EXPENSIVE, is THE big issue now.  It’s the big issue for land transmission, it’s the big issue for offshore transmission, and, given the uncertainty since the 7th Circuit decision, maybe some of the sturm and drang could be circumvented if it’s designed at 345kV or below, and uses the “benefactor pays” theory.  We shall see…

Yeaaaaaaaaaaaa!  One for the home team!!!!

First it was NYISO and ISO-New England:

Feb 4 2009 NYISO & ISO-NE Letter to JCSP

Then it was New York’s Deputy Secretary of Energy testifying before Senate Energy Committee:

DeCortis Testimony- March 26, 2009

And now the Governors from the Northeast and Mid-Atlantic states have stood up against the insane Midwest transmission plans — transmission plans like CapX 2020, JCSP/MTEP, Green Power Express, and the unnamed group announced on April 3rd, starting in North Dakota, banding southern Minnesota, and shooting out into Wisconsin.

Here’s their letter:

East Coast Govs Transmission Letter

It’s blurry, so click the letter and read the whole thing.  An eye opener for the Midwest, those who don’t recognize that there’s a big world out there and it’s not all about Midwest wind.  Folks, you have a marketing problem, your target market says NO!  What about NO can’t you understand?