“Misleading the Public”?

We have received some reports that AEP and Allegheny(FirstEnergy) lobbyists telling legislators that Resolution 58 “misleads the public.”

Here are the facts.

Dominion Virginia Power presented its description of Alternative One to PJM Interconnection’s Transmission Expansion Advisory Committee on June 9, 2010.  Here is page 5 from their Power Point presentation:

Here is a link to the entire presentation as it appears on the PJM Interconnection Web site.

Every one of Resolution 58’s assertions about Alternative One is right here on this Power Point slide.

On January 19, 2011, Virginia SCC Hearing Examiner in that state’s PATH case required PATH partners AEP and Allegheny Energy to include a complete analysis of Alternative One on an equal footing with PATH, in their PATH Virginia application?

I’ll let Mr. Skirpan speak for himself:

Specifically, PATH-VA is directed to file the results of PJM’s load deliverability and generator deliverability tests for each of the following scenarios on or before March 15, 2011 :

1. Updated Base Case – The Updated Base Case load flow analysis shall reflect: (i) PJM’s 2011 Load Forecast ; (ii) the most currently available generation and generation queues; (iii) the results of PJM’s May 2010 RPM auction, including demand response; and (iv) an update of PJM-approved transmission system projects, including reactive power support.
The Updated Base Case scenario should not include: (i) the PATH Project; (ii) the rebuilding of the Mt. Storm – Doubs line; (iii) Dominion Alternative I (the rebuilding of the Mt. Storm – Doubs line, the installation of a 900 MVAR SVC on the 230 kV bus at Loudoun and the T1 57 tap 500 kV bus, the installation of 900 MVAR of static capacitors at other locations, the installation of series compensation on the Meadow Brook – Loudoun 500 kV line, and the rebuilding of the Pruntytown – Mt. Storm 500 kV line); (iv) the Liberty Project;

2. PATH Case – This scenario shall include the Updated Base Case load flow analysis and the PATH Project ;

3 . Mt. Storm – Doubs Rebuild Case – This scenario shall include the Updated Base Case load flow analysis and the rebuilding of the Mt. Storm – Doubs line;

4. Dominion Alternative 1 Case – This scenario shall include the Updated Base Case load flow analysis and Dominion Alternative 1 ; and

5. Liberty Case – This scenario shall include the Updated Base Case load flow analysis and the Liberty Project .
In addition, as discussed during the pre-hearing conference, further, limited analysis may be requested: (i) to explore the impact of the additional generation of the proposed Dominion Warrenton generating facility ; and (ii) to explore the reactive reinforcements needed to address specific voltage issues. Any such requests would be made based on the initial results of the above scenarios. [emphasis added]

Here is a link to Mr. Skirpan’s ruling on the Virginia SCC Web site.

PJM Interconnection staff engineers are assiduously avoiding talking about Alternative One.  Is it “misleading” to state that PJM is wedded to the PATH project and will try to distort and suppress discussion of any alternatives?

Here are two sections from a November 24, 2010 letter signed by West Virginia Consumer Advocate Byron Harris.  The letter was a formal complaint by state consumer advocates to the management of PJM about how PJM staffers were rigging analyses of alternatives to PATH.  In particular, the state officials identified a clear conflict of interest in this PJM process.

First, the evaluation of the costs of PATH and the proposed alternatives were not conducted on a basis that allowed any meaningful comparison of costs. PATH is based upon 2007 costs that we understand have been revised by PATH three times and not independently evaluated. The cost projections for the Liberty alternative were independently evaluated by Burns & McDonnell. We appreciate that PJM management saw the value in the independent evaluation of project costs; however PJM management did not require a comparable analysis of the PATH costs using the same assumptions as those used in evaluating the Liberty costs (or any other PATH alternative). While no doubt this gave PJM  management a better understanding of the Liberty costs, it provided no information whatsoever of how the PATH and Liberty costs compare, or whether the PATH costs are themselves reasonably projected.


Finally as it relates to the evaluation of the Liberty costs, we were surprised to learn that PJM engaged Burns & McDonnell for the independent evaluation. PJM management never disclosed to the TEAC Committee participants – or at least to the consumer advocates – that PATH had engaged Burns & McDonnell for significant work on the PATH project. The conflict of interest is undeniable and should have been immediately disclosed. For a project of the magnitude of PATH it is unrealistic that Burns & McDonnell should be expected to objectively evaluate a competing project regardless of what specific employees may or may not have been assigned to the project. [emphasis added]

So, can we trust PJM’s analysis?  Who is “misleading” whom?  Is it “misleading” to say that PJM is not the most honest judge of West Virginia’s power needs?

The West Virginia PSC has failed to act decisively on Dominion’s Alternative One.

In their most recent PATH order, filed January 7, 2011, the PSC failed to order an inclusion of the full Alternative One in the power companies’ case for PATH in West Virginia.  In its order dated December 16, 2010, the PSC swiftly ordered one half of Alternative One to be built when it approved Dominion’s application to rebuild the Mt. Storm to Doubs, MD transmission line.  To date, the WV PSC has failed to act as decisively as the Virginia SCC on Alternative One, and has been silent on ordering the rebuilding of Allegheny Energy’s Pruntytown to Mt. Storm transmission line, the remaining half of Alternative One.

I suspect that AEP/Allegheny FirstEnergy’s lobbyists think Resolution 58 is “misleading” only because the Delegates who sponsored the resolution believe that West Virginians and their Legislature, and Public Service Commission, actually have legal control of the electrical system in our state.  The power companies have repeated time and again over the last three years that PJM Interconnection, a power company membership organization based in Pennsylvania, is the only authority that can “order” construction of transmission lines in our state.

Now is the time for West Virginia government officials to stand up for our state and our people.  Alternative One strengthens our state’s transmission infrastructure without taking new land from anyone, and saves West Virginia rate payers millions of dollars.

A vote for Resolution 58 is a vote for West Virginia.