STL in the news!

June 12th, 2010

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Stop The Lines! has appealed the New Jersey Board of Public Utilities’ determination on the Susquehanna-Roseland transmission line, I’ve been representing them in this fracas, and from the news reports below, it looks like we’ve hit all the bases!

The Susquehanna-Roseland transmission line is absurd — they’re tearing down an existing low capacity line and putting up towers twice as high with … well… imagine this, QUAD bundled 500 kV line.  Really… that is what they applied for, but midway through the hearing, they admitted that the structures couldn’t handle that and reduced it to TRI-bundled 500kV.  ACSR at that, could it be more primitive?  It’s absurd, if they 190 foot towers fell, with a 75 foot Right of Way, that’s 115 feet that it could extend beyond the Right of Way.  It’s beyond absurd — it’s insane, and earth to mars, there are people right there, RIGHT THERE, don’t they care?

susquehanna-roseland

Plus it’s not needed, the Marketing Analytics report says it all:

Marketing Analytics – PJM 2009 State of the Market Report

Here’s the BPU order that we’ve challenged:

NJ BPU Order – April 21, 2010

This is from the Pocono Record — be sure to click on the linkedarticle below to get to the Pocono Record comment section:

Power line fight heads to NJ court

By Wayne Witkowski

For the Pocono Record
June 11, 2010

New Jersey activists fighting proposed increases in the voltage and tower height of the Roseland-to-Susquehanna power lines are taking their battle to appeals court.

Four environmental groups and one onf the two private organizations made up of concerned homeowners filed court papers this week against the state’s Board of Public Utilities and utility company PSE&G. The papers charge that BPU, which approved the plan unanimously without comment in February, did not exercise due diligence in properly reviewing the proposal.

Stop the Lines, based in Fredon, N.J., has filed suit. It is one of two active private organizaitions in New Jersey opposing the project, along with the recently established Save the Park group in Hardwick Township, N.J., which has a sign advertising its cause on Hollow Road in Smithfield Township.

The suit contends the review lacked a proper analysis of the need for the project, failed to consider the environmental impacts of construction or weigh the secondary impacts of importing coal energy from Pennsylvania.

The existing 47-mile link of the 145-mile route, which extends through the Delaware Water Gap National Recreation Area and specifically through Saw Creek Estates in Lehman Township, would add 500,000 kilovolts and raise towers to 195 feet. It is under the auspices of the PJM Interconnection, which includes PPL on the Pennsylvania side and PSE&G, which is looking to recoup $3 billion in costs stemming from the deregulation of the energy sector in New Jersey.

The project still awaits approval by the National Park Service. New Jersey Sen. Bob Menendez recently sent a letter to park Superintendent John Donahue asking him and the National Park Service to exercise due diligence in its decision, which is due in 2012.

PSE&G spokesman Karen Johnson defended BPU’s decision, saying PSE&G is aware of the appeal and believes there is “ample evidence” to support its decision.

And from the Daily Record:

Morris area citizens group sues over power line plan


BY COLLEEN O’DEA • STAFF WRITER • June 10, 2010

The citizens group Stop The Lines has filed an appeal challenging the state Board of Public Utilities’ approval of Public Service Electric and Gas Co.’s transmission line expansion through Morris, Sussex and Warren counties.

Stop The Lines’ appeal of the BPU’s January decision permitting the upgrade on PSE&G’s Susquehanna-Roseland power line is the second filed in appellate court in the last week. Four environmental groups that like Stop The Lines also had intervened in the proceedings filed an appeal last Friday.

The Stop the Lines appeal will focus on the lack of need for the expanded transmission line, which would add 500-kilovolt lines to towers as high as 195 feet along the 47 miles in New Jersey. The group also faults the BPU’s refusal to consider information on a possible decreased demand, health and safety impacts on landowners, residents and the environment and economic impacts ranging from loss of property value and tax revenue to inability of homeowners to obtain mortgages.

“Building 195-foot high towers within a 150-foot wide right-of-way is simply unreasonable,” said David Slaperud, a Stop The Lines trustee.

“We believe the ample evidence in the case fully supports the BPU decision that this line is needed for reliability,” said PSE&G spokeswoman Karen Johnson.

PSE&G is awaiting final environmental permits to begin working on the eastern half of the $750 million project, from Hopatcong to Roseland. It hopes to begin work this summer. The western portion, from Hopatcong to the Delaware River, has to await the completion of a National Park Service review because the line runs through the Delaware Water Gap National Recreation Area. That is expected to take until 2012.

The project was challenged in the BPU by citizen and environmental groups, several municipalities and the Montville School District. Ratepayers would foot the bill.

The line crosses from Pennsylvania at the Delaware Water Gap and proceeds through Warren and Sussex Counties. More than half the line would traverse Morris County, through Jefferson, Rockaway Township, Kinnelon, Boonton Township, Montville, Parsippany and East Hanover before ending in Roseland.

And in the New Jersey Herald:

Activists appeal state’s power line approval


FREDON — The most outspoken local opponent of the Susquehanna-Roseland power line is appealing its state approval in the court system.

Stop the Lines, the activist group that has been the most vocal and omnipresent adversary to the PSE&G line since its proposal in 2008, is appealing the Board of Public Utilities approval issued in February.

The appeal focuses on the need of the 500kV line, running 146 miles from the Poconos across northwestern New Jersey and into the heart of the Garden State. They will also question the economic impacts to property owners and municipalities along the line — which will double the height and triple the power of the existing 1920s-era transmission towers.

“Building 195-foot-high towers within a 150-foot wide right-of-way is simply unreasonable,” said David Slaperud, a Stop the Lines Trustee.

Four state environmental groups also appealed the BPU decision by the June 7
deadline.

PSE&G has maintained brownouts could roll down the line as early as 2012 if the upgrade is not complete. However, the National Park Service blessing to cross the Delaware Water Gap will not be available until that year — and PSE&G put off seeking final environmental permits for the 20-mile Sussex County stretch of the line last month.

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Stop the Lines has appealed the New Jersey Board of Public Utilities decision approving the Susquehanna-Roseland transmission line through northern New Jersey.

NJ BPU Order – April 21, 2010

The New Jersey environmental coalition that intervened in this docket, represented by Eastern Environmental Law Center, has appealed too!

This is yet another case of utility wants but NO NEED, and now, they’re trying to build only the eastern section!  Say what?!??!!  That’s not what the BPU approved!

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Stop The Lines appeals BPU decision on PSE&G Susquehanna-Roseland power line project

Stop The Lines, a grassroots opposition group, has filed an appeal in the Appellate Division of NJ Superior Court challenging the Board of Public Utilities (BPU) decision to allow Public Service Electric & Gas (PSE&G) to build a massive power line along an existing right-of-way that was not designed to accommodate a line of this magnitude.

“Building 195-foot high towers within a 150-foot wide right-of-way is simply unreasonable,” said David Slaperud, a Stop The Lines trustee. Slaperud said that the proposed line would negatively impact property values, and that a project of this size running through residential areas is detrimental to public health and safety. “The BPU has not adequately addressed these concerns.”

“BPU was asked several times during evidentiary hearings to look at the most recent energy demand data, and they failed to request the additional information,” continued Slaperud. “Instead, they relied solely the word of Mr. Steven Herling, Vice President of Planning, PJM Interconnection, LLC (PJM), who stated, ‘We will do the analysis, but we already know what the results will be,’ when questioned during hearings. No facts, just basically a plea to ‘Trust us.’”

Tom Hill, another trustee of Stop The Lines added, “How could the BPU take Mr. Herling at his word, rather than simply looking at the data that is currently available?   Something just doesn’t seem right – while energy demand continues to drop, BPU is willing to take PJM at their word rather than requiring data to back that assumption up.”

Stop The Lines attorney Carol A. Overland strongly agrees.  “This BPU decision comes at a time when any utility infrastructure is suspect.  PJM’s demand has been steadily decreasing since 2006, and recently PSE&G proposed to build only a part of it.  That alone shows we’re not going to be freezing in the dark, the lights won’t go out. Add PJM’s State of the Market Report and the increasingly delayed RTEP, it’s just not plausible that they need this line.  What’s clear is they WANT it, but their business plan and PJM’s marketing plan are not sufficient reasons to put landowners and communities through this transmission hell.”  Overland stated that the proposed new project is far beyond what a demand increase would require. “It’s transmission on steroids at a time when we are in conservation training. The Susquehanna-Roseland Project is going backwards down the wrong path.”

The Stop the Lines appeal will focus on the lack of need for this massively expanded transmission line, and the BPU’s refusal to consider new PJM information showing an decreased demand now or in the foreseeable future; the uncertainty of rate-recovery, which is currently at issue at FERC; health and safety impacts on landowners, residents and the environment; and economic impacts ranging from loss of property value and tax revenue to inability of homeowners to obtain mortgages.

Stop The Lines also fully supports the issues raised by the four Environmental Groups – Environment New Jersey, New Jersey Highlands Coalition, New Jersey Environmental Federation and the New Jersey Chapter of the Sierra Club – in their appeal of the BPU decision, and will work in collaboration with them throughout the appeal process.

It’s out, hot off the press:

BPU Susquehanna-Roseland Order

I feel a Motion for Reconsideration coming on…

NPS scoping hearings in progress

February 18th, 2010

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Scene from yesterday’s NPS meeting at Camp Jefferson, Lake Hopatcong, NJ

PSEG’s Susquehanna-Roseland transmission line through the Delaware Water Gap is under scrutiny.

Here’s the Daily Record’s photo gallery

Just out – PSEG year end info (just searched SEC and don’t see it there yet):

PSEG 4Q 2009 – Generation Measures

PSEG 4Q 2009 – Electric Revenues

And for some reason, I get that old hook line, a little perverted, i.e., “We gotta lock down our electric revenue, and then we’ll take it higher!”:

Yesterday was the second of three public comment hearings that the National Park Service is holding regarding PSEG’s application to expand the Right of Way and run its Susquehanna-Roseland through the Delaware Water Gap, a premier federally designated “wild and scenic” area.  The good news is that people are really turning out, the first meeting, in Bushkill, PA, was about 100, and this meeting was twice that, standing room only in the log hall of Camp Jefferson.

Here is the NPS’ take on framework and issues for the Environmental Impact Statement:

NPS Internal Scoping Document

Here’s a few snippets that I really find interesting — and of course want to expand on:

Air Quality
Construction and maintenance activities would impact air quality.

Viewsheds
The new transmission lines and associated roadways would affect the visual viewshed. Viewshed impacts would be permanent. A separate viewshed analysis should be done for scenic and visual impacts. A comprehensive list of the viewsheds at DEWA does not exist at this time. However, the APPA is considered a scenic viewshed. The baseline conditions are represented by the current viewshed, which has not yet been evaluated.

Climate Change/Greenhouse Gases
How the project contributes to the production of greenhouse gases and climate change, as well as how climate change would impact the project and park resources must be addressed in the EIS.

Viewshed Appreciation
The new transmission lines and associated roadways could adversely affect the visitors’ appreciation of the visual viewshed. These impacts would be permanent. A separate viewshed analysis should be done for scenic and visual impacts for visitor experience.

The one that jumps out to me is “air quality.”  I note that under “Climate Change/Greenhouse Gases” they acknowledge the project contribution of greenhouse gas and climate change, and that also needs to be added to the Air Quality section, the project contribution of pollutants to air quality.

Why?  Check the RTEP, PJM’s 2007 RTEP that this Susquehanna-Roseland project was based on:

Critical RTEP Issues and Upgrades

PJM continues to address a number of issues with
a bearing on reliability in Pennsylvania and the
regional transmission expansion plans required to
maintain it:

• Increasing power transfers through Pennsylvania to feed eastern Mid-Atlantic PJM load centers including those in Pennsylvania are expected to cause overloads beginning in 2016 on key circuits in Pennsylvania. New high voltage backbone facilities are required to mitigate these reliability issues. The new backbone facilities will also be assessed for their ability to support deliveries from a cluster of new coal-fired generating facilities currently proposed for central and northeastern Pennsylvania. Three major new backbone transmission facilities have been approved by the PJM to resolve growing reliability criteria violations in eastern Mid-Atlantic PJM and west/central Pennsylvania, upgrades that are now part of PJM’s RTEP:

• Susquehanna – Lackawanna – Jefferson – Roseland 500 kV circuit
• Amos – Bedington – Kemptown (PATH) 765 & 500 kV circuit
• Mid-Atlantic Power Pathway (MAPP): Possum Point – Calvert Cliffs – Indian River – Salem 500 kV Circuit

2007 RTEP, p.259-260 (emphasis added)

Beginning on p. 262, the RTEP lists 2,712 (check my math) of coal in queue.  Yup, Susquehanna-Roseland could handle that!  Here’s the full PA chapter of the 2007 RTEP — see for yourself:

2007 RTEP – Section 4k – Pennsylvania

The New Jersey one says essentially the same thing:

2007 RTEP – Section 4h – New Jersey

Those new coal plants and the impacts of facilitating/enabling those new coal plants and the impact on the Class I park must be addressed.   The operational impacts, contributions to greenhouse gases, applies equally to air quality.   This was an issue with Voyageurs National Park in the Mesaba Project review, and it should be here.

Here’s the “study area” designated by National Park Service – the “no data” spot is Picatinny Arsenal.  What happens if you build transmission over an arsenal?  What is the impact on the park if Picatinny Arsenal goes BOOM!?!?!

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Here are some articles, thanks to Scott Olson ( Fired up and ready to go one more time! ) for compilation:

Susquehanna-Roseland reopened!

January 27th, 2010

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The Susquehanna-Roseland hearing has been reopened.  And off we got to FERC.  It’s been quite a hectic week, with a “flurry” of filings, and here’s the update.  First, remember the NJ BPUat a special 1/15 meeting said they were NOT going to decide on PSE&G’s Susquehanna-Roseland transmission line and said they’d be asking for more information from PJM.  Well, they asked PJM to answer a few questions (though not specific enough, not the right questions):

BPU Secretary letter to PJM

Here’s what PJM had to say:

PJM Letter in response to BPU Query

Suffice it to say, the letter is … ahem… INSUFFICIENT!

And then the responses started coming in, first the Municipal Intervenors, then :

Municipal Intervenors response to PJM Letter

Environmental Intervenors – January 25, 2010

Stop The Lines! January 25, 2010

And the BPU issued an Order reopening the docket and first scheduled a hearing for February 2, 2010, and then THANKFULLY changed it to February 4, 2010:

BPU Scheduling Order Jan 25, 2010

BPU Amended Scheduling Order Jan 26, 2010

The concept is that PJM is coming in as a witness regarding the assertions of their January 21, 2010 bullshit letter, and what does that mean?  Is Steve Herling THE witness, or are there others?  Is whatever witness/es coming with a truckload of exhibits that they’ll dump on us the day of the hearing?  Is he going to be prepared in any way to back up his conclusory and unsupported statements?  So I fired off a couple missives, first Discovery to get the requests in quick and let them be on the record of ignoring or refusing to answer, and then a letter to the BPU with my view of the fine mess we’re in:

STL Discovery re: PJM Letter 1/21/10

STL Letter to BPU 1/25/10

As a sidebar, the escrow that PSE&G had to put out for the Municipal Intervenors is gone, this has been an intense case, and so they’re reasonably asking for more:

Municipal Intervenors – Motion for Escrow

Meanwhile, back at the ranch, remember that great 7th Circuit decision tossing out the cost allocation for this project?  Everything’s been up in the air since then, because if they can’t settle how they’re going to allocate the costs, this sucker won’t be built:

Illinois Commerce Commission v. FERC – August 6, 2009

It was remanded to FERC and after some wrangling, just like in the BPU case, where the utilities were saying, “It’s all there in the record, you don’t need anything more to make a separate decision” and Illinois said quite succinctly, “AHEM, WE DON”T THINK SO!” and FERC issued an Order stating that the record was not sufficient, needed more information and directed PJM to provide some information and also provided some questions for parties to mull over in their comments:

FERC Order January 21, 2010

Here’s the fun part – what they asked PJM to provide (hee hee hee hee hee hee), starting on p. 5 of the above Order:

10. PJM should provide the following information:

A. The total costs that have been approved through PJM’s Regional Transmission Expansion Plan (RTEP) process for facilities that operate at or above 500 kV (and necessary lower voltage facilities), and whose costs are assigned pursuant to Opinion No. 494. For these projects, calculate the total costs that have been assigned to each PJM zone, and estimate the total costs that would be assigned to each zone using PJM’s DFAX methodology.

B. PJM manuals require that, in planning projects, it seek to optimize projects in order to reduce the cost of addressing individual reliability criteria. Describe how the optimization process is performed. Also, explain how PJM determines the relative priorities of resolving numerous reliability issues with one project. For 500 kV and above facilities, explain whether PJM could accurately determine the beneficiaries of a project that resolves numerous reliability issues using its DFAX methodology.

C. PJM’s most recent RTEP report (2008), at P 5 states that:
Baseline thermal and voltage analysis encompasses an exhaustive analysis of all Bulk Electric System (BES) facilities for compliance with NERC Category A (TPL-001), Category B (TPL-002) and Category C (TPL-003) events. In addition, consistent with NERC standards TPL-004, a number of extreme events including those judged to be critical from an operational perspective as well as those defined in Table I of TPL-004 were evaluated for risk and consequence to the system. Describe the types of anticipated reliability requirements addressed by the PJM RTEP (i.e., voltage, thermal, stability). Explain whether and how the DFAX analysis applies to the NERC reliability analyses listed above and any other reliability requirements. Explain whether the RTEP upgrades designed to address these reliability requirements also will address other reliability concerns. In particular, explain whether the geographic location or voltage level of an RTEP upgrade makes that upgrade more likely to address broader reliability concerns.
Provide any relevant studies.

D. In this proceeding, PJM recommended the adoption of a postage-stamp rate design for new 500 kV and above facilities.

1. Describe the benefits generated by such facilities that are not captured in the DFAX methodology used by PJM to allocate costs for lower voltage facilities. Indicate whether such lines provide reliability or economic benefits to the areas producing electricity.

2. Provide engineering or other studies showing any differences in regional benefits between 500 kV and lower voltage facilities (e.g., 345 kV
and 230 kV).

E. Provide any existing engineering or other studies that indicate whether the modeling assumptions used in the RTEP analysis, such as the direction of flow,
remain consistent or vary over time.

The Municipal Intervenors sent in a Motion to FERC, PSEG objected, and then Stop the Lines sent in a Motion for Limited Intervention:

Municipal Intervenors – Motion to Intervene

PSEG Response to Munis FERC Intervention

Stop The Lines! Motion for Limited Intervention

Municipal Intervenors – Renewal of Motion to Intervene

PSEG Response to STL Intervention Motion

PSEG’s response to our Motion to Intervene… yeah… (yawn)… what-ev-er…

And just now, hot off the press, the Municipal Intervenors have filed a Motion to Depose PJM’s Steven Herling!  Oh, yes, this is much needed, so we can get an idea where they’re going and what they plan to present (I doubt they’d produce the pre-filed testimony I requested!):

Municipal Intervenors Motion to Depose PJM’s Herling

As you can see, it’s been an intense few days, and isn’t letting off anytime soon.  More to follow as it develops.