I have not been posting to The Power Line, because I have been living off the grid since last Friday.  About 10″ of snow has devastated Calhoun County’s decrepit distribution lines.  Many breaks had nothing to do with downed trees.  Sixty year old conductors that have been repeatedly patched, but never replaced, sagged and broke under a moderate snow load.

AEP/Allegheny claim that we need PATH to prevent “brownouts and blackouts” on the East Coast.  Here in rural Calhoun County, blackouts are a relatively common occurrence.  This blackout has lasted four days and will probably last five.  We have already lost power for a total of about three days earlier in the year.

The Associated Press reported last Saturday on the widespread blackouts across West Virginia and referred to them as problems in the “transmission system.”  It is just this kind of sloppy journalism that allows AEP/Allegheny to get away with their outrageous claims about PATH.

There are two distinct systems in the US electrical grid.  The transmission system delivers power from generating plants and large substations to smaller substations.  The distribution system consists of the lines that deliver power from regional and local substations to electrical consumers.

Most experts on the US power grid believe that upgrades to the distribution grid, in the form of new switching technologies and distribution power lines, will generate much higher levels of improved efficiency than will upgrades to the bulk transmission grid.  Clearly, it makes much more sense for FERC to be offering incentives for distribution system upgrades than for bulk transmission upgrades.

In West Virginia, where we have a very old distribution infrastructure that has been patched and neglected for years, our PSC should be pushing AEP and Allegheny Energy to invest in a major overhaul of our distribution system.

Surely, real improved reliability for West Virginia power users should be a higher priority for the WV PSC than some vague PJM claims about reliability for New Jersey customers.

I have lots more to post, but I’ll get caught up when Allegheny Energy slaps a few more patches on our lines.  When our generator is running, I too busy with other chores to spend much time on the computer.

Allegheny Energy notified the MD PSC last month that Potomac Edison would file a new PATH application in Maryland by December 31, 2009.

Potomac Edison could own and operate PATH in Maryland, but, as of the present date, only PATH Allegheny has the FERC-approved cost recovery and 14.3% guaranteed return on equity incentive.  Unless Allegheny Energy applies to FERC for a transfer of PATH Allegheny’s cost recovery scheme to Potomac Edison, it appears that Allegheny Energy’s stockholders would have to bear the full cost of PATH in MD and would have to take whatever profit rate the market would allow for the project.

As you know from prior posts on The Power Line, AEP and Allegheny Energy have no interest in operating in free markets and exposing their stockholders to real risk in the marketplace.

Those of you who watch FERC filings should be watching closely for any attempt by Allegheny Energy to get FERC to transfer the cost recovery scheme from PATH Allegheny to Potomac Edison.

Citizens need to be ready to intervene in any transfer attempt to let FERC know that FERC should be creating incentives for new generation in Mid-Atlantic states and offshore, not subsidizing dangerous and destabilizing transmission from distant power sources.

Congress and FERC created the PATH/MAPP/TrAIL/Susquehanna-Roseland-Branchburg mess.  We need to use the Potomac Edison transfer case to begin to block these crazy transmission incentives at FERC.

Here is a great video from the December 1 rally at the offices of the Maryland PSC in Baltimore.

Maryland has very strong policies that restrict increased coal-burning as a source of the state’s electric power.  Using PATH as a source of future power flies in the face of that policy.  Yet Maryland policy makers continue to entertain PATH as a “solution” to the state’s energy issues.

This video shows that Marylanders know the score and are here to help us stop PATH.  You will also see West Virginia’s own Patience Wait representing all of us here in WV who couldn’t make it to Baltimore on Dec. 1.

America the Sustainable- Clean Energy Rally from Byron Banghart 2b4theWorld.com on Vimeo.

We are very fortunate that the East Virginia SCC is continuing with their PATH case.  We all get to see some excellent independent analysis of the PATH project and PJM’s shoddy claims about the power line we don’t need.

Yesterday, the SCC’s legal staff filed the written testimony by their experts.  It appears the VA SCC’s own staff does not believe that PJM’s goofy figures quite add up to a new power line.

Two of the experts directly address PJM’s claims that PATH is needed.  James Wilson, an energy economist, demonstrates clearly that PJM has wildly overestimated electric power demand in the Mid-Atlantic states in their projections for the future.  Transmission grid engineer and planner Eddie Dehdashti gives us a detailed explanation of how PJM’s “modeling” is poorly done, incomplete and completely ignores accepted US standards for transmission planning.

Wilson and Dehdashti’s detailed accounts of specific issues support every aspect of testimony offered in East Virginia by grid experts George Loehr and Hyde Merrill about PJM’s wildly inaccurate “planning,” whose only purpose seems to be focused on propagandizing for AEP and Allegheny Energy and their pet power line projects.

Here are links to Wilson’s two part testimony, part1 and part 2.  Here is a link to Dehdashti’s testimony.

I have downloaded these documents from the VA SCC Web site and reformatted them as .pdf files that can be searched.  Be aware that my optical character recognition software may have misinterpreted some words or letters.

Here is Wilson’s conclusion:

I find that PJM’s forecast of 2014 peak load for the Mid Atlantic region is too high for three principal reasons. First, the forecast was based upon an economic growth forecast that was, and remains, highly optimistic; the expectations of the majority of professional forecasters, as reflected in both contemporaneous and more recent surveys, reflect much slower growth.  Second, PJM’s peak load forecast, which was prepared using an econometric approach that bases the forecast on past historical trends going back to 1998, fails to adequately reflect the trend of slowing peak load growth since 2002.  Third, PJM’s forecast also fails to anticipate the additional forces I noted above that will further suppress future peak load growth, such as continued efforts to achieve energy efficiency and demand response, higher electricity prices, introduction of advanced meters, scarcity pricing, time-varying prices and price-responsive demand.

You should also read the summary of Mr. Wilson’s professional history at the beginning of his testimony.  He has been directly involved in studies and planning for PJM in recent years.  He knows how PJM works from the inside.  As an independent consultant, however, he is not under any pressure to shape his analysis to the desires of PJM or AEP/Allegheny.

Dr. Dedashti testifies in detail about the inadequacy of PJM’s planning for system reliability and the need for PATH.  His analysis is thorough and clear.  If you want to understand what PJM, and state utilities commissions, should be doing, you should read Dr. Dedashti’s entire testimony.

Here are Dr. Dedashti’s conclusions:

Based on my experience, expertise, and analyses of relevant data, models and results readily available or provided through discovery, it is my professional judgment that the Applicant has not constructed a reasonable nor credible case to designate the PATH Project as the preferred solution to the Mid-Atlantic Area
reliability problems. Further, the PATH Project has not been proven to be needed, even to resolve those problems that have been identified in the simplistic and inconclusive studies that have been presented by PJM.

In the next few days, I will be posting a new page with selected quotes detailing some specific points made by Wilson and Dedashti.  In the meantime, use the links above to check out their testimony yourself.  You will learn quite a bit about electrical transmission and grid reliability in the process.  These are things you won’t learn from power company propaganda.

The Newark NJ Star Ledger had a recent article on the next PJM power line we will be paying for soon.  This line is an extension of the Susquehanna-Roseland line which will extend the S-R line to Branchburg, NJ.  For lack of a catchy name like PATH, this new line is simply called the Roseland-Branchburg line and is estimated to cost $1.1 billion.

Apparently, the Pennsylvania and New Jersy power companies who are building the Susquehanna (PA) – Branchburg power line decided that they could get state regulators to swallow their mega-power line in smaller bites if they broke it up applied in separate segments.

No matter how big each bite will be, West Virginia rate payers will be paying for the whole project through PJM and FERC’s cost recovery/guaranteed profit system.  NJ utility PSE&G says that PJM wants the new segment to begin operation in 2013.  Here is a link to the whole article.

The Roseland-Branchburg line is another of the northeastern segments of the original Project Mountaineer that was designed by AEP and PJM to carry AEP’s coal-fired power to the east coast.

In past posts, I covered power company psychological operations designed to obscure power line issues.  FERC has done the same thing by using bureaucratic mumbo jumbo to conceal what it is really doing with national transmission line policy.

Whenever I want to find out what bureaucrats or corporations are really trying to do, I look for the euphemisms they use to cover their tracks.  In the case of FERC, we have two such innocent sounding concepts, “postage stamp rates” and “backstop authority.”  “Postage stamp” makes us think of things we use every day that are cheap and easy to understand.  “Backstop” calls up vague images of childhood games and something that protects us.  Let’s look more closely.

FERC’s term “postage stamp rates” actually refers to the Cheney-inspired system for forcing all rate payers to pay for new power lines, so that power companies and big bank traders who sell electricity can make higher profits.  The term “postage stamp” comes from the fact that no matter how far your letter goes in the US Postal system, you only pay a flat rate per ounce, as opposed to paying by the mile for the distance the letter travels.

The problem is that the US electrical grid is nothing like the postal system.  The US Postal Service is a government service.  Private businesses own and operate, and profit from, the sale of electricity on the power grid.  The “postage stamp rate” system is just another phrase for “direct rate payer subsidy for power company profits.”  Not only do we pay the power companies’ costs under this system, FERC also awards power companies guaranteed “incentive” (another euphemism, in this case for “subsidy”) profit rates that are built into the innocent sounding “postage stamp rates.”

“Backstop authority” sounds even more obscure than postage stamp rates.  Before the (again) Cheney-backed National Power Act of 2005, state public service commissions had complete control over the approval of all power line projects within their borders.  The big energy traders, who are depending on new mega-transmission lines to generate new electricity arbitrage profits, were frustrated that state regulators could doom their pet projects.  These bankers, speculators and corporate power conglomerates, like American Electric Power, lobbied Congress to include a system that would allow FERC to gain control of power line approval through the National Interest Electric Transmission Corridor (NIETC) provisions of the 2005 National Power Act.

In any region of the country designated as a NIETC, Congress gave power companies the power to request FERC intervention to completely remove new power line projects from state authorities.  This dictatorial process of violating state sovereignty was daintily referred to as “backstop authority.”

Keep in mind what a backstop does in baseball.  It keeps the ball “inbounds” on the official field of play.  That is exactly what FERC’’s “backstop authority” does, except in this case, the power companies and federal bureaucrats have created the rules and established the limits of the field of play.  States and citizens are no longer part of the game.  Only the big corporations and the federal government can play.

We may very soon have to be playing in the FERC games to stop the PATH power line if and when AEP/Allegheny decide to “go federal” with us.  We need to get used to the FERC mumbo jumbo so we can figure out what is really going on.

The C.A.K.E.S. list of issues to include in comments to FERC by the Dec. 15 deadline is so good, it deserves its own post.  I have made a few editorial changes, but the list comes directly from the information sheet C.A.K.E.S. sent me.

• FERC’s current regulations do not let citizens have a meaningful input early enough to make a difference.  The process is not transparent.  There is no opportunity for interested parties to have any meaningful participation.
• FERC does not provide for national security as an element of transmission siting process…Cyber security and the dangers of system dependence of distant power sources should be addressed.
• FERC needs to create a mechanism for direct state and local involvement in all federal siting processes.
• States should have final say on routing and siting decisions.
• FERC should consider critical and significant environmental and public health and safety factors.  The siting of the line must be environmentally sound, undergrounding line as much as possible.
• Plans should be consistent with public interest and should protect the health and safety of the public.
• Power lines should be buried if they pass near residences, schools, hospitals and other sensitive facilities.
• Alternatives should be fully considered:  local generation, re-conductoring of existing lines, demand side management and improved system efficiency, as well as distribution and alternative transmission improvements. Currently, non-transmission alternatives are not considered!
• Rate payers should not have to bear the financial burden with the  reward to the owner of transmission lines.  FERC’s cost recovery scheme of making everyone pay for new transmission projects is contrary to all past FERC policy in which only the rate payers who benefit from a project pay for that project.
• Ferc siting will strip states of resource planning, preventing them from using low carbon alternatives, damaging competition, limiting technological innovation and driving up electric rates.
• Generous FERC profit incentives designed to encourage investment in new transmission have created a rush to develop projects for private profit only even when these projects don’t represent optimum or cost effective solutions for customers.
• New transmission plans should dramatically enhance our capacity to meet steep greenhouse gas emission reduction goals by targeting new clean renewable energy resources and technological innovation.
• Every effort should be made to improve the use of the existing transmission infrastructure, reduce the need for new supply, and encourage clean distributed generation.
• All new transmission projects and their proposed generation sources must meet renewable energy standards and carbon limits in their entirety.

There is one big issue missing from this list that should be in any public comments:

The only real justification for FERC’s role in transmission siting is that FERC is increasing the reliability of the transmission system.  In fact, we now have clear evidence that FERC has no definition of what “reliability” means in the context of the US power system or FERC’s role in transmission siting.  Here is a link from the Congressional Research Service that states that there is no agreed upon definition of reliability and a link about Judge Posner’s order challenging FERC’s control of rate setting for power lines in PJM which states that FERC itself has provided no clear definition of reliability.

Pick and choose what issues you want to address in your comments.

Here is the basic on line filing information:

Comments may be filed either electronically or in paper format, and should refer to DOCKET NO. IC1O-729-000.  If filing electronically the Docket No. is IC10-729 Documents must be prepared in an acc3eptable filing format and in compliance with the Federal Energy Regulatory Commission submission guidelines at http://www.ferc.gov/help/submission-guide.asp.

Comments may be filed electronically via the eFiling link on the Commission’s Web site at http://www.ferc.gov.  First time users will have to establish a user name and password before eFiling.  (http://www.ferc.gov/docs-filing/eregistration.asp You will get an automatic acknowledgement upon receipt through eFiling. DOCKET NO for eFiling is IC10-729

There is more information at my other post on FERC comments here.

The Federal Energy Regulatory Commission (FERC) wants to expand its power to force power lines into our states and to make us pay for this obsolete technology that will make our transmission grid less reliable and less secure.

FERC’s regulations concerning power line siting are up for re-authorization right now.  You can let FERC know what you think through their public comment system, but the deadline is December 15, 2009.  You have to let them know NOW.

Here is a link to an information guide to the public comment process and the issues involved from C.A.K.E.S., our friends in Maryland who are fighting PATH.

Here’s the basic info on commenting, as well as links to file your comment on line:

Comments may be filed either electronically or in paper format, and should refer to DOCKET NO. IC1O-729-000.  If filing electronically the Docket No. is IC10-729 Documents must be prepared in an acc3eptable filing format and in compliance with the Federal Energy Regulatory Commission submission guidelines at http://www.ferc.gov/help/submission-guide.asp.

Comments may be filed electronically via the eFiling link on the Commission’s Web site at http://www.ferc.gov.  First time users will have to establish a user name and password before eFiling.  (http://www.ferc.gov/docs-filing/eregistration.asp You will get an automatic acknowledgement upon receipt through eFiling. DOCKET NO for eFiling is IC10-729

Commenters that are not able to file electronically must send an original and 2 copies of their comments to:  Federal Energy Regulatory Commission, Secretary of the Commission, 888 First Street, NE. Washington, DC 20426.

If interested in receiving automatic notification of activity in the docket may do so through eSubscription at http://www.ferc.gov/docs-filing/esubscription.asp

Further info contact:  Ellen Brown 202 502-8663, or fax at 202 273-0873, or email at ellen.brown@ferc.gov.

The C.A.K.E.S information sheet includes a list of ideas and issues that you might want to address in your comments.  Read the information sheet first so that your comments will be in the form that FERC requires and will focus on issues that will have an impact on the FERC process.  Here is a link to another post on The Power Line on the suggested FERC comments.

In my limited experience with FERC, nothing is transparent or clear.  FERC is a bureaucratic puzzle palace that should not be managing our national electrical system.  This is particularly true when it comes to navigating FERC’s Web site or even doing something as simple as providing public comments.  Here is some more useful information from C.A.K.E.S. about how to manage the FERC maze when you submit your comment:

The process is not as simple as it should be, so in case you or others have questions, here’s a guide for efiling: The registration is very easy:  You register, (REMEMBER PASSWORD) hit next, enter street address, etc; hit next; and for me, I had to enter an alternate address.  It wouldn’t let me continue without this. When you get your response from registration, you just have to hit the website they give you to verify the registration. At this point, you’ll want to have your comments saved in a file because you have to attach them later.  It seems to take power point, and older word versions.  (It wouldn’t accept my newer Word Vista, but did accept 2007 word) When you click on the site they’ve sent you in the email,  you go to eFiling and enter email and password to log in, the filing should be directed to ELECTRIC.  And when it asked what kind of filing:  Use the Report/form for existing docket #; next Then it’s simple, put in docket # (IC10-729), search, select it, next, browse, upload comment.

FERC is a big part of our problem with PATH.  We need to engage in the FERC process to insure FERC doesn’t destroy the reliability and security of the US power grid.

Over the Thanksgiving holiday, I read John Robb’s Brave New War about the future of security threats.  Robb, a former special operations soldier and expert on global security, points out that guerrillas in Iraq have become expert at paralyzing electrical transmission grids.

One of the main points that Robb makes in his book is that knowledge now flows quickly around the world among “global guerrillas” who want to disrupt developed economies.  Here’s what he says about the special vulnerability of the US:

A long term target of global guerrillas in our emerging war, will be the large infrastructure networks that our national economy relies upon (as do all modern developed economies). The most critical and complex network is our power grid which contains over 1 m kilometers of high-voltage power lines between 115 -765 kVs.

Here is a link to the rest of the post on Robb’s blog.

So, do we need a bigger, more centralized, more vulnerable transmission grid, as PJM, FERC, the power companies and the Obama Administration want?  Or do we need much more widely disbursed power generation that provides a safer, more redundant power system with fewer juicy targets?  Extra high voltage AC lines like PATH are particularly vulnerable to the kinds of cascading failures that Robb describes.

Robb says that the solution to our security problems lies in local solutions based on smaller generation units that are in the hands of power users as much as possible.  He states clearly that bigger power lines and a more centralized system is a recipe for a national security disaster.

The wind power smokescreen is being pumped out by FERC for a new attempt to rapidly expand obsolete power technologies.  FERC wants new long distance monster transmission lines (just like American Electric Power).

Some national environmental groups are going along with FERC, NERC and the Obama Administration in this disaster to nationalize transmission planning:

The Conservation Law Foundation filed views with FERC last week on behalf of itself and nine other leading environmental organizations, urging the commission to set national rules for transmission cost allocation. The rules would give predominant weight to recommendations by new planning organizations that would be created in the Eastern and Western interconnections, based on formal agreements by state governors.

While that path would seem promising in the West, some governors in the Northeast oppose paying for long-distance transmission projects to bring Great Plains wind power to their states. They will do their own wind projects, they say.

“We’re organized to do it in the West,” said Rick Sergel, chief executive of the North American Electric Reliability Corp., the grid’s operations monitor. “They just need to get to the finish line,” he said in an interview. The finish line is much farther away in the Eastern grid interconnection. Transmission projects “hopefully will be done with the authorities that exist today. If not, that will have to change,” he said.

Instead of developing a plan for creating a more secure and reliable energy grid based on distributed generation spread widely across the US, FERC wants to create an even more centralized power grid linked by a few huge power lines.  Smaller, more efficient power generation near where power is used is what we need, not more coal by wire gussied up as wind power transmission.

And now, FERC is developing plans to force everyone in the US to pay for these obsolete boondoggles.

Here is a New York Times article about FERC’s latest adventure to force PATH and other obsolete power lines down our throats in the coming decades.