The group of non-governmental organizations within PJM has objected to a number of PJM’s proposals on revising its RTEP planning process. The issues include the “dead band” proposal that would modify PJM’s current “bright line” test for whether power lines are needed or not. The “dead band” is a kind of “land of the living dead” where projects (like PATH) that are determined to be not needed would live on in a zombie-like state in the dead band. Here is a link to the NGO’s argument against the dead band.
The NGO group also provided a broader critique at this link.
Here is the summary of the NGOs’ position taken from the report they commissioned from Synapse Energy Economics:
Our recommendations cover three broad categories:
• Improve forecasting: Develop better estimates of the likely impacts of a whole range of elements that affect the forecasts that are used as inputs to reliability testing and modeling of the bulk power system. These elements include, but are not limited to, load forecasts, energy efficiency forecasts, the impacts of demand response resources, retail advanced metering programs, renewable portfolio standards, feed-in tariffs, customer-based distributed generation, and other state and federal policies and regulations. When modeling the system, PJM needs to avoid overly conservative assumptions that bias results toward large new transmission lines.
• Assess at-risk resources: Expand PJM’s current efforts to identify at-risk generation to address the likely impacts of new EPA regulations on an aging, uneconomic fleet of specific resources (much of it coal-fired generation). Develop screens and thresholds that will allow PJM to proactively address both near-term and long-term impacts of a significant quantity of retirements over the next several years. Early identification of solutions to potential reliability violations due to retirements is essential to avoid uneconomic and costly reliability contracts (for resources that PJM cannot allow to retire).
• Expand Reliability Solutions: Develop analytical tools and revise tariff and cost allocation rules to allow for solutions to reliability violations that are composed of transmission upgrades, new supply resources, or demand resources, or any combination thereof. Particular attention needs to be paid to low-cost upgrades to the smaller lines of the bulk power system that may be able to delay, or avoid entirely, large new transmission lines.
PJM is continuing its Regional Planning Process Task Force to overhaul the PJM RTEP process. The main PJM page concerning the task force is here. You can find documents by clicking on the dates of task force meetings at the bottom of the page under “Meeting Materials.”
You might want to take a look at the section of the Synapse report, starting on page 6, that details the PATH project, because Synapse uses PATH as the prime example of what is wrong with PJM’s current RTEP process. The first section of the report also provides a simple and clear explanation of the decline in the rate of growth of demand for electricity that began in 1979 and culminated in the actual fall in demand starting in 2007. Synapse makes clear that declining demand is not just the result of the current economic situation, but is a trend that has been developing for decades. That analysis starts on page 2 of the report.
The PJM NGO group includes some of our old friends from the PATH fight such as the Sierra Club, the Piedmont Environmental Council and EarthJustice.
If you want to see if PJM succeeds in rigging its planning process to revive the PATH zombie, you need to follow the Regional Planning Process Task Force.