Legalectric

Catching up…  Thanks to Bloomberg for finding this — a May 29, 2018 “confidential” memo, now attempting to use a “National Defense” framing to subsidize the failing coal and nuclear power industries:

Grid-Memo_5-29-2018

This is on the heels of his prior attempts to push coal and nuclear generation.  The claim is one of grid necessity, to keep it stable, don’t cha know.  Right…  If it weren’t of such immense scope and cost, I’d be Snorting Out Loud.  Instead, it’s the other SOL!

From the horse’s mouth to the horse’s ass:

PJM Interconnection said in a statement that the power system is more reliable than ever.

“There is no need for any such drastic action,” the grid operator said. “Any federal intervention in the market to order customers to buy electricity from specific power plants would be damaging to the markets and therefore costly to consumers.”

If PJM says it’s not needed, if FERC says it’s not needed or wanted… DOH!

As was attempted in New Jersey, a bailout for PSEG nuclear plants in Salem, First Energy is at it too:

Coal power company files for bankruptcy and asks Trump for bailout

First Energy, whose systemic problems and negligence brought us the August 14, 2003 blackout, are now posing as champions of grid resilience?

No, just no.  It’s obvious that tRump can’t change the market, the free market has spoken.  What would the cost of this be to us?  MASSIVE!  So now they’re trying every excuse to prop them up at OUR expense, our expense as rate-payers, and our expense as tax payers.  No, just no…

Third try… you are OUT!

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?

New Jersey gets a bad rap, people here in the Midwest have no clue.  People think of New Jersey, and they think of Newark (which has its good points, I really enjoyed officing there during the Susquehanna-Roseland hearing) which is a mess, vacant buildings all over the place, TALL vacant buildings…

And that’s where the New Jersey Board of Public Utilities is, rolling a cart full of boxes back and forth from the R.Treat (right) to the BPU (big black glass smudged building under “Aug 2012”) in the snow was a joy:

Anyway, there’s more to New Jersey than that.  New Jersey where the Susquehanna-Roseland transmission line crossed is B-E-A-U-T-I-F-U-L.  It’s a lot like northern Minnesota, granite and pine trees, stunning.  Turns out my mother spent time there in the Army, and afterwards she worked at the Franklin Hospital, I think owned by the Franklin nickle mine.

Google Earth maps are now showing the summer’s construction of the Susquehanna-Roseland transmission project, and… OH… MY… DOG…

Here are photos from Stop the Lines in 2013 of new access roads through the Mahlon Dickerson Reservation, Lake Hopatcong, NJ to build this monstrosity:

And just google that park for another perspective:

And the view from Headley’s Overlook and Lake Hopatcong:

Here’s Lake Mohawk, another example of bizarre transmission routing:

From Stop the Lines:

And at the heart of Stop The Lines resistence:

How’s that for a depressing photo?  That’s Highview in Newton, NJ, and that’s a 500 kV AC line, TRIPLE BUNDLED (it originally was QUAD bundled, but that was over-reach beyond belief, and hey dropped it), HUGE capacity line, HUGE.  Oh, and that’s the same configuration as the GNTL line.   AAAAAAAAAAAAAAAAAAAAAAAGH!  Look how close it is, and if ice coated lines and towers meet high wind, what happens if these crumple like others we’ve seen?

Check out these solar panels, house on Marksboro Road.  The one just north has a roof full too, not just that garage!

Here’s where it crosses Mt. Holly Rd. and you can see what the construction does to this field:

Here’s a view of the Picatinny Arsenal, thanks to Stop the Lines, and the tower is 215′ tall, the transmission towers through here will be ~25 feet shorter than this:

And yes, this is the transmission line that goes over the Delaware Water Gap and the Appalachian Trail!  Here’s on the eastern side, NJ side, of the Delaware Water Gap:

DOH!  The Delaware Water Gap is one of the country’s few Wild and Scenic Rivers (like our own St. Croix River):

Just the place for transmission! Enough… transmission sucks.

One of the perks of the job and being in the neighborhood was that I got to hear Phil Woods at the Deer Head Inn, he lives right around the corner.  That must have been 2009, maybe 2010.  His relatives on the Charlie Parker side came in from the east, place was packed, and as Ed Berger would say, “way outside.”

“We make things work for you.”  Oh, ja,  sure, you betcha…

And then there’s Obama’s “fast tracking” and PSEG’s Susquehanna-Roseland transmission line is one of the seven transmission lines Obama picked to ram through.  Northwestern New Jersey is beautiful, a lot like the Minnesota “Range,” lots of rugged terrain, granite, and pine trees.  My clients, Stop the Lines, are based in Newton, NJ, and Fredon Township, which are just west of the New Jersey Highlands, and just east of the Delaware Water Gap.  It’s is such beautiful country.  Not for long if PSEG has anything to say about it.

Guess what they’re doing at 7 a.m. on a beautiful fall morning?  THEY’RE MOWING TREES DOWN:

This is a view off Verdona Road, a cul de sac off of Stillwater Road in Fredon Township.  They started on Tuesday, and were out there today at 7:00 a.m. mowing down everything down to dirt.  There was no notice to landowners and neighbors, just equipment out there clearcutting everything.

I’ve asked neighbors for more photos, will post if they arrive in the inbox.

Imagine 190 foot transmission towers through the Delaware Water Gap, between Pennsylvania and New Jersey.

That’s what’s proposed by PSE&G for its Susquehanna-Roseland transmission line.  This quad/tri bundled 500kV line is HUGE, ugly beyond belief, and it’s just so big that I can hardly comprehend, there’s nothing that large that I’ve found.  Others like it are being cancelled by PJM due to lack of demand, and this one should be too…

From the Pocono Record:

Park Service report on power line plan released

Anyway, the National Park Service is doing an Environmental Impact Statement, and leading up to that is “scoping,” which, as Grant Stevenson noted yesterday at the Task Force meeting, is THE most misunderstood term.  I agree.  It just zooms over people’s heads, and comments end up being of the “I hate this project because___” and nothing that relates to what the scope of the environmental review should be.  Utter waste of time, and something to be mindful of with the CapX 2020 transmission scoping meetings coming up.

SCOPE: Range, area of coverage, breadth

So “scoping” in this sense is the range, area of coverage, and breadth of environmental review.

We had comments on the scope a few months ago, and there were something like 6,500 comments.  Yes, that’s right, SIX THOUSAND FIVE HUNDRED!  At the meetings I went to, it was standing room only and the comments were notably on point, they were profound examples of those rare uplifting meetings.  Facilitation of the meetings was so good it felt like they really were interested in what we had to say.  It was all taken down by a court reporter.  THAT level of attention and appreciation is SO rare… and dig this … afterwards I RECEIVED A THANK YOU NOTE FOR PARTICIPATING.  That is a first, I’ve never gotten a thank you note from an agency for showing up and speaking out.  I’m thinking of framing it (after sending it to MN’s Dept. of Commerce).

NATIONAL PARK SERVICE – SUSQUEHANNA-ROSELAND 500kV TRANSMISSION LINE PAGE

Here’s their report:

Public Scoping Report – Susquehanna-Roseland transmission

The next step?

The NPS is currently developing preliminary alternatives for the project. Our plan is to host public meetings to present and receive feedback on these preliminary alternatives this summer. Announcements and news releases will be prepared to inform and invite the public to these meetings.

We’ll keep you posted.