Direct Testimony of Thomas M. Hildebrand - Consumer Advocate ...

THOMAS M. HILDEBRAND
7336 Sheraton Drive
Manassas, VA 201 12
December 1,2007
Ms. Sandra Squire
Executive Secretary
Public Service Commission of West Virginia
201 Brooks Street
Charleston, West Virginia 25301
RE: CASE NO. 07-0508-E-CN
TRANS-ALLEGHENY INTERSTATE LINE COMPANY
Dear Ms. Squire:
Enclosed herein please find the original and twelve (12) copies of "Thomas M.
Hildebrand's Direct Testimony." An electronic copy has been emailed to:
jwatkins@psc.state.wv. us
adeaver@allea henvpower.com
ccallas@iacksonkeIlv.com
rpalmert3alleg henvpower.com
hriddle@alleghenvpower.com
bmilll 1 @aIleahenvpower.com
pmelick@iacksonkelly.com
Copies have been served upon all parties of record.
Sincerely,
Thomas M. Hildebrand
I n te rveno r
.- "I
cc:
all parties of record
*.
c,
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Direct Testimony of Thomas M. Hildebrand
Case No. 07-0508-E-CN
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Q. WHAT IS YOUR NAME?
A. Thomas M. Hildebrand
DUTIES & RESPONSIBILITIES
Q. WHAT IS YOUR OCCUPATION?
A. I’m an active duty Lieutenant Colonel in the United States Air Force.
Q. WHERE ARE YOU CURRENTLY ASSIGNED AND WHAT IS YOUR JOB
TITLE?
A. I’m assigned to the Pentagon. I work for the Assistant Secretary of the Air Force for
Acquisition. My job title is Chief of Process Improvement and Reengineering.
EXPERIENCE & EDUCATION
Q. WHAT IS YOUR PRIOR BACKGROUND?
A. Please see attached resume at Attachment 1.
Q. WHAT EDUCATION AND TRAINING HAVE YOU RECEIVED?
A. Please see Attachment 1.
Q. ARE YOU AN ELECTRICAL ENGINEER OR DO YOU CONSIDER YOURSELF
A TECHNICAL EXPERT IN ELECTRICAL TRANSMISSION?
A. No,
Q. DO YOU HAVE TECHNICAL EXPERIENCE?
A. Yes. As an Air Force program manager over the last 19 years, I had engineers on my
staffs that worked the highly technical electrical issues on my programs. I only needed a
high-level understanding,

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Q. WHAT TYPES OF PROGRAMS DID YOU MANAGE?
A. Please see Attachment 1.
Q. WHAT QUALIFIES YOU AS AN EXPERT BEFORE THE WV PSC AS THEY
CONSIDER THE REQUEST FOR PERMIT TO CONSTRUCT THE TRANS-
ALLEGHENY INTERSTATE LINE (TRAIL)?
A. An expert is a person with a high degree of skill or knowledge of a specific subject. If
you asked me how to design and build an electrical transmission network, I certainly
don’t have that skill or knowledge. That’s ok because we have plenty of experts who can
speak to that. On the other hand, I do have considerable knowledge of alternate
approaches to TrAIL. Compared to the general public, I consider myself an expert
because I’ve spent more than 500 hours studying, researching, and working this issue
over the last 12- 18 months and I know more about it than the vast majority of the general
public.
PURPOSE OF TESTIMONY
Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
A. Provide important relevant facts and information to the WV Public Service
Commissioners.
Q. FOR EVIDENCE INCLUDED IN YOUR TESTIMONY, WHAT CRITERIA DID
YOU APPLY?
A. I believe the Public Service Commission exercises some flexibility to accept evidence
it considers helphl for deciding on issues such as TrAIL. My approach was to only
include information in my testimony that met three important standards: 1) The
information had to be highly relevant to this case; 2) The information had to be from
reputable subject matter experts; 3) The information needed to have a clear message. In
other words, the statements were unambiguous with respect to the subject matter expert’s
intent. I only included supporting material that met all three criteria.
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Q. WHAT DO YOU WANT THE PSC COMMISSIONERS TO DO WITH YOUR
TESTIMONY?
A. I respectfully request this filing be accepted and evaluated by the Commissioners for
the following reasons. First, I’ve attempted to select only “high quality’’ supporting
material. Second, the Commissioners are aware that it is not feasible in cases such as this
to call witnesses who hold high-level federal and state government positions or senior
executives in private industry or those who may have a financial stake in the outcome of
these proceedings. Lastly, I’ve attempted to get important and relevant information from
TrAILCo through discovery. In many instances, TrAILCo stated it did not have the
information I requested and was not required to conduct studies and analysis to obtain it.
Given this void of information, I hope the Commission will consider information I have
compiled since this may represent the best available.
If the Commission rules I am not qualified to offer testimony and supporting evidence, I
request (file a motion) to append my public testimony given on 30 October 2007 in
Moorefield, WV so that this submission including all supporting information is included
with it and given the appropriate level of review and consideration in this case.
Q. DO YOU HAVE AN OVERALL CONCLUSION REGARDING THE NEED FOR
TRAIL BASED ON THE INFORMATION/EVIDENCE PRESENTED?
A. Yes. The TrAIL project is not the preferred solution to meeting stated reliability
concerns while also balancing other considerations directly affecting West Virginia
citizens. Planning assumptions used by TrAILCo and PJM such as those pertaining to
alternative generation sources located in Eastern PJM were unrealistic and do not reflect
reality. Additionally, adequate planning consideration was not given to alternatives to
TrAIL that could use new technology to make maximum use of existing facilities and
equipment. Additionally, huge region-wide initiatives that stand to diminish or eliminate
any stated reliability need for TrAIL such as those mandated by Presidential Executive
Order, the Department of Defense, and detailed in state and local government energy
plans have not been properly factored. The magnitude of these initiatives make them
unacceptable to ignore. In summary, the risks and costs resulting from TrAIL to the
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West Virginia public outweigh any possible anticipated benefits. For these reasons, and
not withstanding my belief that TrAILCo is not a West Virginia public utility as was
envisioned by West Virginia statute, TrAILCo’s request for permit should be denied
under $24-2-1 1 of Public Service Law.
Procedurally, TrAILCo has failed to meet several of the requirements detailed in the West
Virginia Public Service Commission ’s Rules and Regulations for the Government of
Electric Utilities.
Q. WHY DO YOU SAY TRAILCO FAILED TO MEET THE REQUIREMENTS IN
WV PSC “RULES AND REGULATIONS FOR THE GOVERNMENT OF ELECTRIC
UTILITIES?”
A. I cite the following examples and references to the Rules and Regulations for the
Government of Electric Utilities:
1) Para 9.2.1 .d states the following shall be included in the application
“evidence that the same (chemical spray used to keep rights of way clean and
pee of brush and trees and chemical contents contained) will not be injurious to
animals, humans, or vegetation beyond said right of way. ”
For instance, in Attachment 2*, TrAILCo responded to Hildebrand’s First
Discovery Request, Question R24 and disclosed that approximately 100,000
gallonshnits of herbicides were applied along transmission lines in West Virginia
from 1998-2006.2 I do not believe TrAILCo’s application contained sufficient
studies to establish the effects these applications could have on personal water
supplies, rivers, and streams. I do not believe TrAILCo has adequately shown
that no possible correlation exists between chemical applications and adverse
’ For brevity, I’ve only included the cover letter of Hildebrand Discovery Request. Full filing is available
upon request.
’ 1997 data was incomplete due to data loss resulting from company computer problems and 2007 data was
not provided.
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health affects to humans, animals, or vegetation. TrAILCo has not performed
adequate environmental impact assessments for such things as possible
correlations between these herbicides and unexplained fish kills and fish
abnormalities on the Potomac River and other waterways in the Chesapeake Bay
watershed. Additional contamination of these waterways threatens ecosystems,
tourism, and even industries. For instance, consider the large poultry industry in
Hardy and Hampshire Counties. If already fragile waterways crossed by TrAIL
are stressed even further by additional sediment and nutrient runoff, farms and
poultry operations in some areas could be placed under more stringent rules and
restrictions. This could have a significant adverse impact on local and state
economies but I see no discussion of such environmental risks in TrAILCo’s
application. One could make similar observations regarding threats West
Virginia’s wildlife and tourism industry. For instance, consider the historic
Trough bald eagle nesting area on the South Branch of the Potomac that would be
crossed by TrAIL. TrAIL would be the third such high voltage line crossing the
Trough, all within a mile. If the fish supply is impacted by herbicide applications
and runoff and if bald eagle populations suffer as a result of this or the planned
construction activities, tourism in the area will be significantly impacted. Several
weeks ago my family toured the Trough via the Potomac Eagle tourist train which
runs between Romney and Petersburg. The main attraction on the train ride is the
opportunity to site and photograph the eagles in the Trough. If eagle populations
decrease in the area, it stands to reason that fewer tourists will come to Romney
and ride the Potomac Eagle train. This is just one example of the risk this project
poses to West Virginia’s wildlife and tourism industries.
2) Para 9.2.1 .e states TrAILCo must “show the habitat and type of wildlife, both
land and aquatic, which may be in the right-of-way or adjoining thereto, and any
known effect said line may have upon the same, including feeding and breeding
habits.” It’s my understanding that several studies of rare, threatened, or
endangered species are not yet complete.
3) Para 9.2.1 .f states TrAILCo must “show what, if any, known effect upon human
and domestic animal life located along said right-of-way will result from the
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construction thereof.” No definitive studies exist that prove EMF emissions are
not harmful to humans or livestock and this topic continues to be debated among
experts. Possible effects range from annoyance electric shocks to serious health
issues like cancer. Regardless of whether or not they cause serious health issues,
the important point is that people living and working near these high voltage lines
are threatened by them. This threat is just one consideration that must be weighed
against any justifications favoring TrAIL.
Para 9.2.1 .h states TrAILCo must provide “pertinent facts showing, what, if any
environmental impact said proposed line will have upon the area on and adjacent
to said proposed line.” I do not believe TrAILCo has met this requirement. I
offer the following personal experience. TrAILCo has requested a 2,200 foot
corridor within which to place the proposed line. Our property in Ashton Woods
is inside that boundary and we have a cabin that could be in the direct path of
TrAIL. To this day, no person from TrAILCo has so much as acknowledged the
existence of our building. Furthermore, I have never seen a TrAILCo map that
placed the location of the building despite the fact that we brought it to their
attention at a meeting with TrAILCo reps in Moorefield one year ago. This is
indicative of the poor quality of planning and communication by TrAILCo on this
project.
In order to assess the credibility of TrAILCo and its parent companies’ claims
regarding impacts, I requested copies (Hildebrand Discovery Request Question
#R16) of public complaints received by TrAILCo’s parent. Rather than providing
this information, TrAILCo stated no complaints were received by its parent when
it clearly knew the intent of the question was that “parent” was to include all such
parents, including the parents of AET. I mention this mainly because it represents
the kind of treatment and lack of transparency that have frustrated the public
potentially affected by TrAIL.
6 150-3- 10 Promotional Practices, para 10.1 Declaration of Policy states, “utility
shall not implement any practice or practices which shall have an adverse affect
upon conservation, or which cannot be justified from a ratepayer benefithtility
cost standpoint.” The TrAIL line is intended to connect coal producers in the
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Western PJM region with markets to the East. By providing this additional
transmission capacity and requiring all commercial and public consumers to pay
for it rather than the generators who will benefit, this creates an unfair and
uncompetitive market advantage for western PJM generators. Distributed
generators like those burning natural gas and located closer to actual need areas
are thereby placed at an economic disadvantage.
7) Not withstanding my belief that TrAILCo should not be given status as a WV
public utility, para 10.2 states, “a public utility shall not, without first obtaining
approval of the Commission, engage, directly or indirectly, in any of the
following promotional practices: financing of land, furnishing of consideration to
any person for work done or to be done, acquisition from any person of any
tangible or intangible property or service. For many months, TrAILCo has been
negotiating land contracts which pay landowners cash for options to purchase
property. These practices have been found to be unlawful by the Pennsylvania
Consumer Advocate (See Attachment 3.) and the PA CA has requested
injunctive relief to stop it from occ~rring.~ It is reasonable to assume that the
same practices are occurring in WV. As mentioned above, I requested copies of
complaints in my discovery requests but was not granted them by TrAILCo.
Without first obtaining approval for TrAIL as required, TrAILCo has been
“financing land and furnishing consideration for work to be done and the
acquisition of property.”
8) Not withstanding my belief that TrAILCo is not a WV public utility, Para 10.2.11
states, “public utility shall not furnish underground electric distribution to any
area or customer under terms and conditions different from those applicable to
any other area or customer receiving the particular class of service involved.
First, TrAILCo has not provided evidence that the terms and amounts paid to the
various landowners under option agreements are not different. It would be
reasonable to assume the amounts negotiated with landowners are likely to vary
widely. In this case, TrAILCo would be providing distribution “under different
For brevity, I’ve only included the cover and conclusion of the PA filing. The full report is available
upon request.
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terms.” The TrAIL line will directly impact three States, PA, WV, and VA.
Several counties in Virginia have been aggressively arguing that any new high
voltage lines approved must be placed underground and there is the real
possibility that this may happen. To my knowledge, TrAILCo has not stated that
it will follow the same requirements (if underground lines are required) for
construction in West Virginia as is determined by the other impacted States. In
other words, if the line is required to be placed underground in VA, will TrAILCo
follow the same requirement in WV? If TrAILCo will not certify to the
Commission that it will follow the same installation approach in all States, this
represents an instance whereby a utility (not withstanding my belief that TrAILCo
is not a WV public utility) would be “furnishing underground electric distribution
under different terms for customers receiving the same class of service.”
9) Not withstanding my belief that TrAILCo is not a WV public utility, Para 10.4
states, “no direct or indirect expenditures may be included in a utility’s cost of
service for political advertising. Any expenditures for political advertising are
expressly disallowed.” To my knowledge, TrAILCo has not certified that all
costs associated with political advertising, public relations, etc. in newspapers
across WV to influence public opinion will not be filed to be recouped under
FERC rules and potentially charged to customers. This may be a violation of the
intent of para 10.4.
10)Not withstanding my belief that TrAILCo is not a WV public utility, para 10.5.4
states, “utility or its affiliate may not continue to engage in promotional practices
after January 1, 1997 unless a schedule regarding promotional practices has been
filed with the Commission. TrAILCo has clearly been engaged in an aggressive
attempt to sway public opinion using advertisements. I offer this for the
Commission to consider. In April of 2006, TrAILCo learned of FERC’s decision
that the cost for TrAIL would be allocated to all West Virginia ratepayers (See
Attachment 4, Supplemental Direct Testimony of Mark Mader before the PA
Public Utility Commission). In June 2006, two months later, TrAILCo sent spam
email to the public using carefully chosen words I believe were intended to
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deceive the public and thereby reduce opposition to TrAIL. These Allegheny
email messages (See Attachment 4A.) said,
“Some have claimed that TrAILCo has requested rate increases to West
Virginia ratepayers to pay for TrAIL and this is not true. ’’
In truth, TrAILCo knew that WV ratepayers would be responsible for paying for
construction of TrAIL but this was not the message. Instead, the message acted to
deceive the public by leading them to believe rates in WV would not increase as a
result of TrAIL. This act diminished the level of public opposition to TrAIL and
to some degree, it has also diminished the ability of the Public Service
Commission to hear fair and balanced arguments. It is unclear if TrAILCo filed
the required schedule with the Commission that might have prevented this
promotional pra~tice.~
11) Not withstanding my belief that TrAILCo is not a WV public utility, para 10.6.5
states, “utility or its subsidiary operating in West Virginia requesting
authorization shall provide information or data showing promotional practice will
result in the conservation of energy and promotional practice is needed in order to
foster conservation.” I have seen nothing from TrAILCo or its parents that
establish that the construction of TrAIL will result in the conservation of energy
or that promotional practices to influence public opinion are needed to foster
conservation. To the contrary, I believe TrAIL will act as a disincentive to the
conservation of energy.
12)Not withstanding my belief that TrAILCo is not a WV public utility, para 10.6.5~
states, “the direct and indirect costs associated with the promotional practice are
reasonable, are not unduly burdensome to the ratepayers, and are not likely to
impact detrimentally on the overall energy costs to consumers in its service
areas.” The aforementioned promotional practices which served to deceive the
public and sway public opinion, are certainly not reasonable, are unduly
burdensome, and may impact detrimentally on the overall energy costs to
consumers in its service areas.
‘ For brevity, I’ve only included the referenced sections of Mr. Mader’s testimony. The complete
testimony is available on request.
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13) Not withstanding my belief that TrAILCo is not a WV public utility, para 10.8.1
states, “a public utility operating in West Virginia may not, directly or indirectly,
in any manner or by any device whatsoever, offer or grant to a person any form of
promotional practice except such as is uniformly and contemporaneously
extended to all persons in the same reasonably defined class.” The techniques
used by agents acting on behalf of TrAILCo, as was determined by the
Pennsylvania Consumer Advocate (Attachment 3) make a clear and convincing
case that these techniques and practices are unlawll. Statements and remarks
were described by Robbie Matestic, Greene Co. Economic Development Director
as “over and over we hear that the facts of the project process and the project are
being misrepresented, and information is not consistent between neighbors. ”
People are being told to take the money because “thisproject is 99% approved.”
14) This shows a clear violation of rules, regulations, and the public trust. These
particular examples are from PA but it is reasonable to assume the same types of
statements, misrepresentation of the facts, and high pressure tactics are being used
in West Virginia. I attempted to confirm this by asking discovery question R23 in
Hildebrand’s First Set of Discovery Requests. TrAILCo objected and said they
were “entirely irrelevant to the Commission ’s consideration of request for
TrAIL. ” If unlawful practices by agents employed by TrAIL are also occurring in
West Virginia, these may be highly relevant to the Commission.
Q. YOU STATED TRAIL IS NOT NEEDED. PLEASE EXPLAIN.
A.
1) Mr. George C. Loehr testified in Pennsylvania as a subject matter expert and he has
over 40 years experience in electrical reliability. In his direct testimony before the PA
Public Utility Commission. Mr. Loehr concludes,
“I can unequivocally state that the proposed TrAILCo Project is not needed to
address reliability issues. ’’
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2) As further evidence, I offer the Commission a study performed by the Energy
Consulting Company, Summit Blue, LLC (Attachment 5). The Summit Blue study
concludes Demand Side Management programs could cut 17% off Virginia’s projected
peak demand and nearly 10% off projected 2007 energy use. FERC has recommended
greater use of demand resources and predicts an immediate potential savings of between
3-7% off peak demand in most regions.
Another study titled How Dominion and Allegheny Got It Wrong (Attachment 6)
concludes,
“Dominion and Allegheny have ignored less costly and less environmentally
damaging solutions; misrepresented the need for the proposed transmission line as a
local Northern Virginia issue rather than a regional issue; made wildly unrealistic (but
undisclosed) assumptions in analyzing the needs of Northern Virginia and the greater
Mid-Atlantic area; and claimed falsely that the proposed transmission line will benefit
consumers, when (as they know) studies show that the line is more likely to enrich power
generators to the west at the expense of consumers. ’’
3) The finding that other solutions to address reliability issues do in fact exist was
confirmed by discovery requests to PJM. In response to the Piedmont Environmental
Council Interrogatory Question No. 62 (Virginia Electric and Power Company Case No.
PUE-2007-003 l), Steven Herling, Vice President of Planning, PJM Interconnection
certified the following response which was an email from a PJM planner. See
Attachment 6A where PJM planner states,
“PJM has continued to review the voltage issues identiJied for the 2011 Mid-
Atlantic Region Load deliverability study. PJM has ident$ed the need for the following
reactive devices in order to adequately support imports into the Mid-Atlantic region.
600 WAR dynamic reactive device at Airdale 500 kV
400 WAR dynamic reactive device at Doubs 500 kV
525 WAR dynamic reactive device at Airdale 500 kV
300 WAR capacitor at Conemaugh 500 kV
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“ While this is still a signgcant amount of reactive devices, it is still less than originally
expected. We continue to review alternate reactive plans for 201 I, however for now PJM
recommends the reactive devices listed above to eliminate the voltage concerns identiJied
for 2011.”
4) The Federal Government and State Governments are the largest consumers of electric
power in the PJM region and the U.S. military is the largest consumer of electricity
within the Federal Government. Any demand forecasts used to justify a large regional
transmission project such as TrAIL would logically need to include estimates for future
demand by these largest of consumers who are most vital to national security. In my
discovery request (Attachment 2, Questions R9,10,1 l), I asked TrAILCo to provide
current supply and future forecast demand for Federal (non-military), Federal (military),
and State Government customers. TrAILCo replied,
“Neither PJM nor TrAILCo has this information. ”
5) To establish the importance of this evidence, I offer the Commissioners Attachment
7, Presidential Executive Order EO1 3423 and Attachment 7A, EO1 3423
Implementation Instruction. ’. Among other things, these orders and instructions require
federal agencies to reduce energy demand intensity by 3% per year or 30% by end of
2015 and starting in 2008,50% of required renewable energy supplies must come from
new renewable sources. The orders also establish new training, reviewdaudits, and
reporting requirements and directs Heads of Agencies to reduce greenhouse gas
emissions. With respect to distributed generation, the implementation instruction from
the Executive Office of the President states,
“ Where life-cycle effective, each agency shall implement distributed generation
systems in new construction or retrofit projects. Agencies are encouraged to use
For brevity, I am only including the first section of this report which discusses energy management.
Subsequent sections deal with such topics as pollution, recycling, and fleet management. The entire report
is available upon request.
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distributed systems when substantial contribution is made toward enhancing energy
reliability or security. ”
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6) Next, I offer to the Commission, Department of Energy National Transmission Grid
Study, May 2002 (Attachment 8j6.
The Executive Summary of this extensive study report states the DOE conducted a study
and found that modernization was needed.
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“There is growing evidence that the US. transmission system is in need of
modernization”
“Introducing advanced transmission technologies and improved operating
practices, siting generation closer to areas where electricity is needed, and reducing
electricity use through energy efficiency and distributed generation could all help reduce
congestion. ”
Specific Recommendation number 3 of the summary states,
“We can avoid or delay the need for new transmission facilities by improving
transmission system operations and full utilizing our existing facilities. Regional
planning must consider transmission alternatives and non-transmission alternatives when
trying to eliminate bottlenecks. ”
Specific Recommendation number 4 of the summary states,
“Opportunities for customers to reduce electricity demands voluntarily should be
coordinated within regional markets. ”
For brevity, I am only including the Executive Summary of this report. The entire report is available upon
request.
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7) The TrAILCo application does not address alternatives to new transmission, does not
make maximum use of available technology, does not factor in new distributed
generation available, and does not maximize existing facilities to meeting any claimed
reliability or economic issues within PJM. For these reasons, TrAILCo has not complied
with the findings of the DOE'S Transmission Grid Study, and has not maximized
National Security interests as discussed by the Honorable Spencer Abraham.
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Next, I offer to the Commission Attachment 9, Department ofDefense 's 2007 Energy
Management Implementation Plan.7
Federal Facilities Energy Program Goals are summarized below:
- Green House Gas 30 percent reduction by 2010 from 1990 (Executive Order (EO))
- Energy Efficiency Standard Buildings - 35 percent Btu/fi2 reduction by 20 10 from 1985
(Executive Order (EO))
- Industrial Buildings - 25 percent Btdft2 reduction by 2010 from 1990 (EO)
- All Buildings - 20 percent Btdftz reduction by 2015 fiom 2003 (EPAct)
- Excluded Buildings - no goal, but energy use must be reported (EPAct)
- Facility Audits - 10 percent/year (can count alt financing) (EO)
- Apply Sustainable Principles - (EO and EPAct)
- Model Lease Provisions Supporting Sustainable Design - (EO)
- New Buildings LCCE - energy usage 30 percent below ASHRAE (EPAct)
- Building Metering Meter all buildings by 2012 to the extent maximum practicable
(EPAct)
- Energy Efficient Products
- Include the procurement of Energy Star and DOE designated equipment in
all contracts wherever possible (EPAct)
- Renewable Energy Install 200,000 solar energy systems by 2010 (EO)
- Obtain 3 percent of electric energy from renewable 2007-2009 (EPAct)
For brevity, I am only including the Introduction section of this Implementation Plan. The entire report is
available upon request.
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- Obtain 5 percent of electric energy from renewable 2010-2012 (EPAct)
- Obtain 7.5 percent of electric energy from renewable after 2013 (EPAct)
Next, I offer to the Commission Attachment 10, Inside the Pentagon publication, May
3 1,2007 by Jason Sherman.’ The article discusses a recent DoD Energy Study and
reported significant initiatives designed to make U.S military installations energy
independent by removing them from the fragile and vulnerable electric grid.
“An influential advisory panel to Defense Secretary Robert Gates will soon
recommend the Pentagon protect critical domestic military installations by
making them energy independent, a move intended to wean the US. militaryfiom
America’s electrical grid which the panel believes is vulnerable to terrorist attack
and natural disaster. James Schlesinger, a former defense and energy secretary,
is concluding a yearlong Defense Science Board task force he is leading that
proposes the Pentagon prepare for failures of the electrical grid -- on which US.
facilities heavily rely -- by “islanding,” a concept that envisions installations
generating their own power. ”
Military installations are the largest consumer of electric power in the United States and
there are many very large military installations and vital national security facilities across
the PJM region. As such, any reasonable demand growth forecasts by TrAILCo would
certainly need to factor the implications of such major initiatives. Likewise, major
energy conservation initiatives mandated by Presidential Executive Order that would
reduce energy use by 30% of current demand by all federal government facilities would
need to be factored in as would comprehensive State energy plans like the one recently
introduced by Virginia’s Governor Kaine. It was not apparent to me that these programs
were factored into growth forecasts so I requested this information through discovery
(Hildebrand questions R9, 10, 11). TrAILCo replied neither they nor PJM had this
information.
The final report has not yet been released to the public. I will provide a copy to the Commission at the
earliest opportunity when it does (assuming security classifications allow it).
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Q. WITH RESPECT TO THE NEED FOR THIS NEW TRAIL LINE, MUCH HAS
BEEN MADE OF THE GROWING ELECTRICAL DEMAND IN THE STATE OF
VIRGINIA. WHAT IS YOUR ASSESSMENT IN THIS AREA?
A.
1) Northern Virginia has a very large population base. Many may not realize Fairfax
County, VA is not much different in population that the entire State of West Virginia.
There are many such large population centers in Virginia, Maryland, of Washington,
D.C. As such, this large concentration represents a huge and untapped energy
conservation and efficiency resource. As an example of this huge potential to conserve
energy, I offer Attachment 11,2006 State Energy Efficiency Scorecard, published June
2007 by the American Council for Energy-Efficient Economy.’ This report shows
Virginia ranked 3gfh among states for Energy Efficiency and Virginia’s Electric Utility
companies tied for last among all 50 States and receiving a score of 0 out of a possible 15
points for energy efficiency spending. It should also be noted that West Virginia
performed slightly better (ranked 35fh) than Virginia and West Virginia’s utility
companies received one-half of one point. The key is that even modest success
improving such measures would eliminate the need for TrAIL. I’d like to remind the
Commission that PJM boasts more than 51 million customers. If each of them conserved
an amount equal to a single light bulb, 51 OOMW would be saved. It makes you wonder if
a better alternative to TrAIL might be for the power companies to simply send each
household a coupon in their electric bill for two free compact fluorescent light bulbs from
Home Depot.
2) Attachment 12 is a page out of the US. Department of Energy’s 2006 Transmission
Congestion Study.” It states, there are three primary ways to deal with long-term
congestion: 1) Build new generation; 2) Build new or upgrade transmission capacity; 3)
Reduce electricity demand through energy efficiency, demand response, and distributed
generation. In TrAILCo’ s application, TrAILCo has chosen to not provide alternatives
using options 1 and 3 and focus entirely on the more controversial additional TrAILCo
line, option 2. Options 1 and 3 would clearly contribute to meeting any reliability and
For brevity, I‘ve only included the referenced pages. The remainder is available upon request.
lo For brevity, I’ve only included the referenced pages. The remainder is available upon request.
16

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congestion issues and would have little or no impact on West Virginians, yet these
2 options were neglected entirely.
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3) Virginia’s Governor Kaine published The 2007 Virginia Energy Plan (Attachment 13,
Executive Summary, pages 6-14)11 states,
“Energy efjciency and conservation provide the least costly and most readily
deployable energy resource options available to Virginia. ”
‘‘ Virginia has invested less in energy efficiency than some other states and
therefore still has signficant short and long-term opportunities for efJiciency and
conservation. ”
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“Energy efficiency and conservation opportunities can be classijied as having
technical potential, achievable potential, and achievable cost effective potential. Studies
show that Virginia has an achievable electric energy reduction potential of 14% over the
next IO years. ”
“ Virginia will need to reduce the energy growth rate through conservation and
efficiency and increase its indigenous production of energy, both renewable and
conventional. ”
Specific goals include:
1) Reduce the rate of growth in energy use by 40%; 2) Increase consumer education; 3)
Expand tax incentives to increase incentives; 4) Utilities should sponsor conservation
programs; 5) Help low income Virginians reduce their use; 6) Expand energy education;
Implement policies to improve State building efficiency; 7) Support industrial and
commercial sectors to do the same; 8) Support deployment of new conservation
technologies; 9) Federal government should expand programs also; 10) Local
governments should establish policies to increase energy efficiency of citizens; 11)
Citizens should change their daily habits; 12) Government should lead by example.
For brevity, I’ve only included the Plan’s Executive Summary. The remainder is available upon request.
17

1 Q. WHAT ABOUT NEW GENERATION THAT’S PLANNED FOR THE AREA?
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A. To answer this question, I first offer the Commission Attachment 13A from
Dominion Power’s website that describes the Lake Anna nuclear reactor project which
has passed environmental approval and is on the fast track. Lake Anna is south of
Washington D.C. and will provide more new generation alone than what Dominion has
publicly stated would make the need for TrAIL disappear (2850MW). There are also
additional projects in various stages of approval/construction including a coal-fired plant
in Wise County, VA (585MW) (Attachment 13B), and CPV Warren gas-fired plant
(600MW). According to aforementioned recent study by Summit Blue Consulting, there
are more than 9,359MW of new generation in local PJM queues and that does not even
include CPV’s 600MW (source PJM RTEP). This is 3 times the stated need and more
than 20 times more than Northern Virginia’s projected load growth of 465MW according
to the study.
Q. YOU STATED THE COSTS AND RISKS TO THE PUBLIC POTENTIALLY
SERVED BY THIS PROPOSAL OUTWEIGH ANY BENEFITS. PLEASE EXPLAIN
SOME OF THE RISKS AND COSTS.
A.
1) Let me briefly mention the risks first. Many who support TrAIL claim the region
faces the prospects of rolling blackouts without it. In order to understand the threat of
rolling blackouts better, I asked TrAILCo to provide information through discovery as to
the number of days that their modeling showed such blackouts would occur in each state
in 2011 and for what duration. Given that the reliability/rolling blackout argument was
given such emphasis and importance, I expected this information to be readily available.
Strangely, it was not. The answer I received was
“PJM does not perform studies that forecast blackout days for each state. PJM
has not calculated Loss of Load Expectation for any of the constrained areas related to
the need for TrAIL based on the possibility that TrAIL would not be granted. However,
regional transmission expansion planning analyzes against NERC criteria to prevent
blackouts ”
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I interpret this statement to say, “PJM doesn’t do the analysis to tell you what bad things
will happen if the line is not approved. Instead, they will plan a new line and then tell
you how it helped to meet NERC criteria. Unfortunately, this approach does not give the
Public Service Commissioners the ability to properly assess the costs vs. benefits of the
proposed TrAIL. This was exactly the finding of the West Virginia Public Service
Commission when they evaluated what became known as the Appalachian Power
Company, “Culloden to Gavin 765 kv transmission line,” Case No. 9003, some thirty
years ago. See Attachment 14. On page 319 of the Public Service Commission’s
Annual Report, in their order entered May 18, 1979, the WV Public Service found,
“The record (Appalachian Power’s) is seriously deficient in that it does not
contain studies reflecting the probability of each required element of outage. The
difficulty we have experienced in attempting to evaluate the probabilities of the
occurrences which must take place in the computer simulation studies lead us to the
conclusion, however, that future certiJication cases presented in this jurisdiction should
be accompanied by evidence concerning such probabilities iffeasible. ”
This is consistent with another discovery question I asked TrAILCo. In question R2, I
asked TrAILCo if they knew of any examples whereby a new transmission line would not
“economically, adequately, and reliably contribute to needs.” The answer received was
they knew of no such examples. When I asked if there was any number of lines that
would be enough, TrAILCo replied,
“Neither TrAILCo or Allegheny Power have performed any studies to determine if there
is a number of transmission lines that West Virginia needs. ”
A.
1) I already mentioned National Security. I asked for information from TrAILCo through
discovery. See Hildebrand’s Questions R6, R7, R17 requesting information about the
number, duration, and effects of potential blackouts. TrAILCo responded that they do
not have access to that information. It is inconceivable that TrAILCo would use
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reliability issues and the threat of blackouts to justiQ this line but would not have
information regarding duration and impacts of blackouts to residential, commercial, and
government customers. Several interested parties representing construction and electrical
workers supported TrAIL publicly and stressed the need to improve and strengthen our
energy grid. I could not agree more that we need to so. Unfortunately, many equate
strengthening the grid with providing more above ground high voltage transmission lines
stretching for thousands of miles across the landscape. I think, as do the nation’s top
National Security energy experts, that distributed generation will make our nation
stronger. Distributed generation will offer protection from such things as the cascading
failures which knocked more than 100 power facilities off line when improper
maintenance allowed trees to come in contact with high voltage lines in 2003.
2) There are economic costs. These are difficult to quanti@ but they certainly exist. Let
me offer one such personal example. Hundreds of families and property owners will
suffer the negative effects of degraded property values from TrAIL. These are many
such risks and costs for things such as 1) public health, 2) environmental damage, and
risk to property values, communities, and economies. Although the precise amounts can
be debated, the existence of these costs is widely accepted. I offer the following
examples:
1) With respect to public health, there is an on-going debate of EMF and the
fact that even the EPA describes EMF classified EMF from transmission
lines as a “possible cause of cancer.” See Attachment 20. It’s not as
important to prove the fact that power lines cause health problems as it is
to agree that a large segment of the public believes power lines do have
the potential to cause health issues. This means members of the public
living in close proximity to these high voltage lines live in daily threat of
potential harmful effects.
2) The other comment I will make regarding public health is to again bring
notice to the fact that more than 100,000 gallons/units of herbicides and
chemicals was applied in West Virginia between 1998 (1997 data
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provided by TrAILCo was incomplete) and 2006 (See Hildebrand
Question R24, and Attachment 15 which offers the results of studies
showing impact of agricultural runoff into the Chesapeake Bay Watershed.
This shows the eastern panhandle of West Virginia in a moderate to severe
range for nitrogen reaching tributaries. TrAIL could exacerbate this
situation. The report also discusses litigation brought by environmental
groups against polluters. This type of litigation could be considered a
significant risk to farming in the region. With thousands of acres of forest
and land cover along power line easements cleared, more chemicals and
sediment will enter WV waterways and the Chesapeake Bay Watershed. I
have seen no evidence to establish an acceptable risk. Attachment 16
offers similar findings from a study just released Nov 07. The Potomac
Conservancy gave the Potomac River a grade of “D-plus” in its State of
the River Report and blames, in part, agriculture (including poultry
production) in the Shenandoah Valley for undermining success. Poultry
production is a huge business in many West Virginia counties and is
vitally important to State and local economies. Attachment 16A from the
Chesapeake Bay Foundation discusses the importance of the Potomac
River to tourism and the connection between pollutants, tourism, and
agriculture (including poultry).
3) Attachment 17 discusses the impact of lost forest that will occur along the
proposed route. According to the EPA, one acre of forest prevents
260,000 pounds of carbon dioxide from entering the atmosphere. Given
that TrAIL will require cutting thousands of acres of forest, the impact of
TrAIL on global warming could amount to billions of pounds of carbon
dioxide entering the atmosphere.
4) With respect to potential harm to West Virginia’s economy, I offer
Attachment 18 which highlights potential lost business opportunities that
can result of TrAIL. West Virginia competes with surrounding States for
attracting businesses. One large data center named Terremark Worldwide
recently broke ground in Culpepper, Virginia. This facility will consist of
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five 50,000-square-foot independent data center structures and a 72,000-
square-foot office building. One of the reasons Terremark chose to locate
where it did was based on its ability to obtain inexpensive electricity. If
TrAIL is approved, Terremark may be powered using electricity generated
in Pennsylvania. West Virginia will aid by allowing what amounts to a
240 mile extension chord to run from Virginia to Pennsylvania. An
alternative approach, one which would be far more beneficial to West
Virginians, would be to use our excess generation to offer greater
incentives for businesses and government agencies to relocate to West
Virginia.
5) With respect to harm to families and communities, I offer the following
example. My family along with dozens of others attended an information
meeting sponsored by Allegheny in Moorefield in December 2007. At
this meeting, the Allegheny representatives we spoke with would not even
acknowledge that landowners would experience any decrease in property
values as a result of a power line on or in close proximity to their property.
This example causes a serious credibility issue with both TrAILCo and its
parent companies. A reasonable person would certainly conclude property
owners would experience some decline in value. Testimony to this was
provided by Mr. Charlie Winfree on 30 October in Moorefield. Mr.
Winfree has been selling real estate for 20 years and is the top-selling
realtor in the five-county area. In his testimony, he stated,
“Many properties will be unsellable at any tolerable price whatsoever. I can
tell you that residential properties will plummet nearby or in sight of these lines.
You won’t see the market value effect for a long time because many impacted
property owners will suffer more by simply being unable to sell at all, ”
Q. WHAT NEGATIVE HEALTH CONSEQUENCES MAY OCCUR IF TRAIL IS
APPROVED?
A. Attachment 19 is the U.S. Department of Justice press release announcing the recent
legal settlement with AEP over AEP’s operations at several coal-fired generation
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facilities which were found to be in violation. The EPA source estimated 32 billion
dollars in savings to consumers in annual healthcare costs will be avoided as a result of
this settlement and the upgrades to equipment that must now be met. From this estimate
of 32 billion dollars in health costs, it is reasonable to predict that additional coal
emissions containing particulate and mercury resulting from TrAIL transmission will
produce similar heath costs. It does not matter if the amount is 32 billion or some amount
less than that.
Attachment 20 is from the Environmental Protection Agency and describes the
controversy surrounding Electric and Magnetic Fields (EMF) from power lines. It finds,
“Based on studies about the incidence of childhood leukemia involving a large
number of households, National Institute of Environmental Health Sciences found that
power line magnetic fields are a possible cause of cancer. ”
Q. ARE THERE ALTERNATIVES?
A. Yes. I offer the following examples from well-respected experts:
1) Attachment 21 if from California’s Independent System Operator and shows one way
California has handled high demand periods that could stress the grid. They have
achieved rather remarkable results, showing the ability to conserve as much as 1500
megawatts during a day just be issuing “Flex Alerts’’ to the public.
2) At the 2006 National Energy Forum, Mr. Tom Eckman, Manager, Conservation
Resources, Northwest Power and Conservation Council gave Attachment 22 briefing
regarding “non-wire solutions’2.” According to his report, conservation is a bargain
compared to other alternatives and is significant enough to factor into transmission
decisions. He says it costs 2.4 cents per kWH and met 40% of regional growth needs.
’’ For brevity, I’ve only included the referenced pages. The entire brief is available upon request.
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3) Attachment 23 was another briefing given at the National Energy Forum by Mr. Terry
Boston, Executive Vice President, Power System Operations. l3 Mr. Boston discusses
advances in technology that can now allow existing equipment to carry 10 times more
current and conduct heat 4 times better than copper wire.
4) Attachment 23A is also from the National Energy Forum and was a presentation
given by Mr. Phillip Pellegrino, President, Superpower, Inc. Mr. Pellegrino describes
new High Temperature Superconductivity (HTS) transmission wires that have 100 times
the power density of copper, are more efficient, safer, suffer reduced transmission losses,
are lighter, improve aesthetics, improved reliability, and will replace copper by the end of
the decade.
5) Attachment 24 was another presentation given at the 2006 National Energy Forum by
Mr. Anthony Ahern, President and CEO of Buckeye Power, Inc. Mr. Ahern notes that
Ohio’s Electric Cooperatives can now interrupt 30% of residential consumer water
heaters through direct load contr01.l~
6) Attachment 25 is a presentation given by Mr. Andrew Ott, PJM Vice President,
Markets on May 31,2007. After running simulations, Mr. Ott presented a slide titled
“Relative Benefit Depends on Location.” The graphic presented shows those on the
supply side of a constrained corridor receive a “generation benefit” but no “load benefit.”
In contrast, those on the receiving side of the congested area receive “no generation
benefit” but they receive the “load benefit.”
7) Attachment 26 is a presentation given by Mr. Richard E. Morgan, Commissioner,
Public Service Commission of the District of Columbia. In his presentation, Mr. Morgan
shows demand response is an “essential component.” He also says “a little goes a long
way and it is an idea whose time has come.” Further, he states it represents operational
l3 For brevity, I’ve only included the referenced pages. The entire brief is available upon request.
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For brevity, I’ve only included the referenced pages. The entire brief is available upon request.
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savings, lower market prices, reduced volatility improved grid reliability, customer
options, and positive environmental benefits.
8) Attachment 27, Wall Street Journal, article titled “Incentives Prove Powerful,” by
Rebecca Smith. Ms Smith reports “New England businesses this year have agreed to cut
electricity use by 1,222 megawatts, twice as much as last year.” The same success can be
achieved across the PJM region. In other cases, companies have been incentivized to
shift use to non peak hours. Businesses in Chicago have signed up to cut use by 647
megawatts.
9) Attachment 28 is a presentation given by Ms. Kathleen Hogan from the
Environmental Protection Agency’s Climate Protection Division.” Ms. Hogan discusses
in detail the benefits of energy efficiency compared to alternatives. She finds efficiency
to be lower cost, less pressure on other suppliers, lower electricity prices, and improved
local economy and service to low income and seniors. There are also many long-term
benefits to the utility systems including improved security, improved resilience, lower
base and peak demand, reduced need for new generation and transmission, and
modular/manageable design. She presents significant results through 2004 including 24
gigawatts avoided.
Q. WHAT IS YOUR RECOMMENDATION FOR THE PUBLIC SERVICE
COMMISSION?
A. I recommend the request for TrAIL be denied based on my conclusion that the
negative impacts far exceed any possible positive ones. For West Virginians, this TrAIL
project is clearly a very bad deal.
Q. DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes.
l5
For brevity, I’ve only included the referenced pages. The entire brief is available upon request.
25

THOMAS RI. HILDEBRAND
Lieutenant Colonel. USAF
Senice History
Yo!. 06 - Pres
Chief, Continuous Process Improvement and Reengineering, Assistant Secretat-?- of the Air Force
Acquisition, Pentagon
Lead transformation efforts for $30 billion a >ear Air Force research. del elopinent. & modernization programs
Integrate process mproreinent strategies & plans in support of Air Force priorities Plan. eLecute. and
champion reengineering iiiitiatir es Train lean manufacturing and process improvement tools and techniques
No\ 05 - NOY 06 Spacecraft Program Manager, Program Office, National Reconnaissance Office (NRO)
Responsible for $2 5 billion spacecraft acquisition Led the go\ eminent & contractor teclinical & management
team responsible for cost. schedule. and performance ch ersan pat load bus. & ground equipment
derelopinent. integration 81 test from component let el to go\ erninent acceptance of spacecraft
Sep 04 - NO\ 05
Director, Operations and Engineering, Program Office, NRO
Led ops and engineering di\isions for $6B satellite program pro\ iding intelligence to militan.. intelligence
agency. and civil customers. Managed contractor and government teams performing prograin management
aiid engineering for spacecraft. supporting ground architecture, and advanced systems integration.
Jul03 - Sep 04
Chief, Space Professional Management Office, NRO
Led the hX0 efforts resulting from the 2001 Space Commission. Met congressional mandate to establish a
inilitary jvorkforce of dedicated space professionals. Authored iinpleinentation plan including nen. training.
certification. and career tracking: coordinated with other senices/ageiicies: represented in DoD fonlms.
Dec 02 - Jul03
Chief, Sustainment Division, Systems Operations Office, NRO
Led goiernment and contractor teains and executed a $71M satellite coininand and control maintenance
program Directed the IF ork of 1 10 personnel deplo? ed norldtt ide. eLecuting operations maintenance. aiid
training aclii ities De7 eloped RL implemented sustainment policies for intelligence collection and processing
Apr 99 - Dec 02 Deput! Chief, Information Operations Dhision, Directorate for Intelligence, Sun eillance, and
Reconnaissance, Deput? Chief of Staff for Air and Space Operations, Pentagon
Deiked and implemented information operational plans for SecDEF appro\-ed special program. Integrated
plans into Air Force and joint operations supporting theater combatant commanders. De\~eloped numerous
technical plans for DoD agencies to protect emergent technologies: briefed plans to Pentagon senior leaders.
Aug 98 - Apr 99 Chief, Sensors Integrated Product Team
Sacramento Air Logistics Center, McClellan AFB, CA
Directed 23 go\ erntnent and contractor SJ stem managers and engineers Managed planning. budgeting. and
e\ecution for inoderiii7ation upgrade program of the AN/TPS-75 radar s> stein Supen ised procureinent
program for a nen radar shelter Prot ided ops support €or $730M in operational assets deplo) ed 11 or1dt.i ide
Rlar 98 - hug 98 Transportation Flight Commander
Logistics Squadron, 4406t” Operations Group (P), Ahmed-Al-Jaber AB, Kuwait
Led ehicle ops maintenance. passenger sen ices. and freight inanageinent during Operation SOUTHERN
WATCH deplo! itient Orchestrated inassn e force deplo! mentiredeplo! iiieitt including nine fighter

Squadrons and 2000 personnel, Planned $8.5 million in impro\.eiiients to broken base infrastructure.
Mar 96 - Mar 98
Chief, Posture Planning Analysis Team, Plans and Programs Office
Sacramento Air Logistics Center, McClellan AFB, CA
Led the Base Realignment and Closure (BRAC) planning team of inanpon er. workload. and infrastructure
experts Dei eloped a comprehensive roadmap for 350 offices. 12.000 personnel. and numerous facilities
Del eloped proposals and decision tools for senior leaders and coordinated plans nith other logistics centers
Apr 95 - Mar 96
Logistics Plans and Programs Analyst, Plans and Programs Office
Sacramento Air Logistics Center, McClellan AFB, CA
Managed efforts and developed inipleineiitation plan for the USAF's Agile Logistics Program. Evaluated
logistics process improvement proposals and made recommendation to senior leaders. Performed economic
analysis to determine optimal repair/overhaul source for such programs as the C-17 and Joiiit Strike Fighter.
Oct 92 - Apr 95
F-22 Aircraft hrmament Integration Manager, F-22 System Program Office
Aeronautical Systems Center, Wright-Patterson AFB, OH
Managed a $70M weapon integration effort on the Air Force's highest priorih FiA-22 fighter aircraft
program. Led 30 Air Force and contractor engineers and managers n ho incorporated advanced technologies
and programs. Oversan efforts through Preliininaq and Critical Design Reyiew engineering milestones.
Aug 89 - Oct 92
F-15E Aircraft Weapon Integration Manager, F-15 System Program Office
Aeronautical Systems Center, Wright-Patterson AFB, OH
Led two teams responsible for cost. schedule. and performance of ueapon and life support program
integration. Responsible for new munitions. a leading-edge oxTgen generation sjstem; and anti-gravity force
suit. Led two time-critical iiitegratioii efforts adding critical F- 15E mr-fighting capabilities for Operation
DESERT SHIELD.
Education - Master of Business Administration, UniT.ersitJ of Dayton. May 1995
- Bachelor of Science. Business Management. West Virginia Uili\ ersity. magna cum laude. May 1988
- ,4ir War College. 2005
- Defense Systems Management College, Apr 2001
- Air Command and Staff College. Jul2000
- Program Element Monitor Course. Apr 2000
- Education with Industq (Henlett Packard). Nov 1997
- Squadron Officer School. Feb 1996
Achiei ements - Meritorious Service Medals, 1999. 2003. 2006
- Company Grade Officer Award. 4406" Ops Group. A1 Jaber AB. Kunait. Jun 1998
- Commendation Medals. 1992. 1995
- Achievement Medal. 1991
- Certified Le1 el I11 in Program Management. 1994
- Certified. Process Improvement "Black Belt." Uni\.ersit\. of Tennessee, 2007
Interests
Sports. fitness. nature. hiking. gardening. Ci.i il War histoq-

?
c
1600 LAIDLEYTOWER * EO. BOX 553 * CHARLESTON.WESTVIRGINIA 25322 -TELEPHONE: 304-340- IO00 TELECOPIEk 304-340-1 I30
www.j~ksonkelly.com
Direct Dial No. (304) 340-1251
Fax NO. (304) 340-1080
November
19, 2007
Via Hand Delivery
Ms. Sandra Squire
Executive Secretary
Public Service Commission of West Virginia
201 Brooks Street
Charleston, West Virginia 25323
Re:
Case No. 07-0508-E-CN
Application of Trans-Allegheny Interstate Line Company for a certificate of
public convenience and necessity under W. Va. Code 6 24-2- 1 1 a authorizing the
construction and operation of the West Virginia segments of a 500 kV electric
transmission line and related facilities in Monongalia, Preston, Tucker, Grant,
Hardy, and Hampshire Counties, and for related relief
Dear Ms. Squire:
Pursuant to Procedural Rule 13.6.c, enclosed please find one copy of TrAILCo’s
response to Thomas Hildebrand s First Set of Discovery Requests. We are providing copies to
counsel for the CAD, the Staff (two copies), Laurel Run Community Watershed Association, the
WVEUG, CPV Warren, and Mr. Thomas Hildebrand.
Please file this letter and the response and circulate the twelve additional copies of the
letter to the appropriate parties at the Commission. We also ask that you date stamp the extra
copy provided and return it with our messenger. As always, we appreciate your assistance in this
matter.
Very truly yours,
Enclosure
cc: Randall B. Palmer, Esq, (wienc.)
Gerald Deaver, Esq. (w/enc.)
Mr. Stephen Lord (wlenc.)
5-
Mr. Michael Lewis (wienc,)
Mr. Keith A. Latham (wienc.)
Parties on the Service List (copied as described above}
Christopher h - LL. w Callas
Clarksburg,WV Martinsburg,WV = Morgantown, WV * New Martinsville, WV * Wheeling,W
(C1284230 1) Denver, CO 9 Lexington, KY Pittsburgh, PA Washington, D.C.

TRANS-ALLEGHENY INTERSTATE LINE COMPANY
CASE NO. 07-0508-E-CN
HILDEBRAND FIRST DATA REQUEST
Responsible Case Witness for this material: Alan Fleissner
Response Date: November 19,2007
HILDEBRAND-I-R1
TrAILCo states TrAIL “will economically, adequately, and reliably contribute to the
present and anticipated requirements for electric power of WV customers.” As such, please
provide ail previously filed economic estimates by TrAILCo and its parent for past lines or
transmission projects in WV along with supporting evidence for each that would show the extent
to which such economic predictions have been accurate and materialized.
RESPONSE:
Allegheny Energy Transmission, LLC (AET) is the parent of TrAILCo. Neither AET nor
TrAILCo has proposed to construct any transmission projects in West Virginia prior to the
proposal pending in this proceeding and, therefore, neither has filed economic estimates with the
Public Service Commission or any other agency for past lines or transmission projects in West
Virginia.
(7,
..__

BEFORE THE
PEWSYLVANIA PUBLIC UTILITY COMMISSION
IN RE: APPLICATION OF
TRANS-ALLEGHENY MTERSTATE
LIKE COMPANY (TRAILCo)
Docket Nos. -4-110172:
A-1 107172F002-FO04
and G-0007 1229
(Consolidated)
MOTION OF THE
OFFICE OF CONSUMER ADVOCATE
FOR INJUNCTIVE RELIEF
Pursuant to 52 Pa. Code Section 5.103, the Office of Consumer Advocate (OCA)
files this Motion For Injunctive Relief. The OCA requests that TrAILCo and its land agents.
acting on behalf of Allegheny Power, be enjoined from engaging in activities including
misrepresentation of facts, coercive acts, or harassment of consumers, all of which violate
Section 1501 ofthe Public Utility Code and pertinent regulations. 66 Pa. C.S. $1501: see
_generally. 52 Pa. Code $56.1 (good faith, honesty and fair dealing required in utility billing.
termination and collection practices). In support of this Motion, the OCA provides the
following:
I. Background
&4mple on-the-record evidence in the form of testimony and exhibits offered bi-
Allegheny Power customers throughout Washington and Greene Counties supports
injunctive relief against the agents of TrAILCo, acting on behalf of Allegheny Power.
Many Allegheny Power customers testified under oath at the public input hearings that they
1

have been subjected to harassment, factual misrepresentations and misinformation, and
coercive acts used by TrAILCo agents. According to the public input testimony, many
customers were pressured by TrAILCo agents to sign "Damage Release-Right of Way"
(Damage Release contracts). These Damage Release contracts refer to claimed existing
rights of way on the consumers' properties'; require consumers to give up all rights with
regard to any damages caused by the transmission line; require that the consurners withdraw
all complaints against the transmission line, and refrain from opposing TrAILCo in any
courts or regulatory proceedings. A sample of such a contract appears in the record as
Cheryl Piroch's Exhibit 3 and a copy is attached to this Motion.
According to the public input testimony, the tactics used to obtain these Damage
Release contracts include false statements by TrAILCo agents to the effect that neighbors
have already signed Damage Release contracts when, in fact, they have not. Other
significant misrepresentations by the agents include such assertions as the transmission line
is a "done deal" or "99 percent sure." Tr. 392, 446, 1164, 1524, 1526, 1920. The OCA
submits that Section 1501 of the Public Utility Code has been violated by the many factual
and legal misrepresentations to induce consumers to sign Damage Release contracts, by the
TrAILCo agents acting on behalf of Allegheny Power. 66 Pa. C.S. 5 1501. The Public
Utility Code and applicable case law support the determination that such statements and
conduct constitute unreasonable service and the Commission has jurisdiction to act to
prohibit such unreasonable service.
' The OCA would note the recent filing of a Complaint in Civil Action and For Declaratory Judgment in
Washington County Common Pleas Court that challenges the validity of the existing rights of way referenced
in the TrAILCo filing. Sawezysmn. et al v. TrAILCo, Alleghenv Enerm Transmission, LLC. Alleghenv
Energy. Inc., West Penn Power Co.; Docket No. 20078072.
2

111. Conclusion
WHEREFORE, the Offce of Consumer Advocate respectfully requests that Your
Honors enjoin TrAILCo and its agents, acting on behalf of Allegheny Power, from engaging
in hrther acts of bad faith or coercion; making further misrepresentations as described
above: declare any claimed Damage Release contracts with affected consumers to be
voidable, upon the request of customers induced to sign through misleading statements and
coercive tactics; and provide notice and opportunity to be heard anew, if requested, for those
who relinquished those rights as a result of the misrepresentation and coercion.
Respectfully submitted,
Dianne E. Dusman
Senior Assistant Consumer Advocate
Pa. Attorney Id. No. 38308
E-mail: ddusman@paoca.org
Darryl A. Lawrence
Pa. Attorney Id. No. 93682
E-mail: dlawrence@paoca.org
Jennedy Santolla
Pa. Attorney Id. No. 203098
E-mail: j santollal@paoca.org
Christy M. Appleby
Pa. Attorney Id. No. 85824
E-mail: cappleby@paoca.org
Assistant Consumer Advocates
Office of Consumer Advocate
jth Floor, Forum Place
555 Walnut Street
Harrisburg, Pa. 17101-1923
Telephone: (717) 783-5048
Fax: (717) 783-7152
Date: October 18,2007
Counsel for:
Irwin A. Popowsky
Consumer Advocate
95 802 .doc
23

TrAILCo Statement No, 1OA
Witness: Mark ,4. Maden.
BEFORE THE
PESNSYLVANIA PUBLIC CTILITU COMMISSION
Ih RE: APPLlCATION OF TRANS-ALLEGHENY
INTERSTATE LI3 E COMPANY FOR
(I) A CERTIFICATE OF PUBLIC COKVENTENCE
TO OFFER. RENDER, FURNISH AKD/OR
SCPPLY TRANSMISSXON SERVICE ??i THE
CQ.MMOIVFWALTB OF PENFSYLVANIA;
(IX) AUTHORIZATION AND CERTIFICATION
TO LOCATE, CONSTRUCT, OPERZTE AND
MAIKTAIN CERTAM HTGH VOLTAGE ELECTRIC
TRASSMllSSION LIhTS AND RELATED ELECTRIC
SUBSTATION FACILITIES; (IXr) AUTHORITY
TQ EXERCISE THE POWER OF EMINENT
DOMAPI FOR THE CONSTRUCTION AND
ISSTALLATION OF AERIAL ELECTRIC
TRANSMlSSfON FACILITIES ALONG THE
PROPOSED TUYSMISSION LISE ROUTES
Ihr PEENSYLVANIA: (IV) APPROVAL OF AN
EXEMPTTON FROM MUNICIPAL ZONING
REGULATIOY WITH RESPECT TO THE
CONSTRUCTION OF BUILDINGS; AND
(17) APPROVAL OF CERTAIN RELATED
AFFILIATED INTEREST AIGL~NGEMENTS
: Docket Nos. A-lf0142,
A-l10172FOQ02,
A-1 10172F0003,
A-ll0172FOOO4, anti
G-00071229
SUPPLEMENTAL DIRECT TESTIMOSY OF
MARK A. MADER
Re: Updated Allocation of Revenue Requirement for TrAIL
July 26,2007

Trans-Allegheny Interstate Line Company
Supplemeiital Direct Testimony of Mark A. Mader
Page I of 12.
TrAILCo Statement Yo. 1 OA
I Q.
7, ‘4.
PLEASE STATE YOUR NAbIE AND BUSINESS ADDRESS.
My name is Mark A, Mader, and my business address is 800 Cabin Hi11 Drive.
?
4 Q.
5 A,
5
7
S
9
10
ii Q.
i2
1.,, A.
iJ
15
16
17
18
Greensburg, Pennsylvania 1 560 1.
BY Vv’HOhf ARE YOU EMPLOYED -AN9 E UWT CAPACITY?
I am employed by Allegheny Energy Service Corporation, and my title is Director, Rates.
My time is devoted to tasks performed for the regulated companies of Allegheny Energy,
Inc.. (.”Allegheny”) including The Potomac Edisoii Company (“Potomac Edison”).
h4onongahela Power Company rMon Power”), and West Perm Power Coinpany (“West
Perm”). all doing business as “Allegheny Power”. and Trans-Allegheny Interstate Line
Company (-‘TrAILCo”).
DID YOU PREPARE DIRECT TESTIMONY THAT WAS FILED PREVIOUSLY IN
THIS CASE?
Yes. My Direct Testimony was filed on April 13. 2007 C‘April 13 Testimony‘*). That
testimoiiy generally described how PJM had allocated the revenue requirenisiits for the
Trans-Allegheny Interstate Line (“TrAIL‘‘) among load serving entities in the PJM
transmission zones, what West Penn‘s allocation was projected to be, and how West Penn
would recover its portion of the TrAIL revenue requirement. 1 also described certain
affiiiate agreements governing interaction of TrAILCo with other Allegheny companies,

Trans-Allegheny Interstate Line Company
Supplemental Direct Testimony of Mark A. Mader
Pagc 2 of 12
TrAILCo Statement No. 10'4
PL'RPOSE OF TESTIMOW
PLEASE DESCRTBE THE PURPOSE OF YOUR SUPPLE%IENTPJ, DIRECT
TESTIMONY.
Recent orders by the Federal Energy Regulatory Commission ("FERC") h 7 e changed &e
cost allocations by PJM, and the associated revenue requirement allocated to Allegheny
Power, that are described at page 4: line 10, through page 10, line 17 of ni? April 13
Testimony. The purpose of my suppfeEenta1 testimoiiy is to describe how. based on these
FERC orders, TrXILCo expects the revenue requirements €or Tr.4IL. and the coritmmon
of the line and associated substation expansions (..DVP Facilities'') to be onned b)
Virginia Electric and Power Company ("Dominion Virginia Power") will be detemiined
and allocard based on those orders to distribution utilities, also referred to as load serlxg
entities ("LSEs"), in the PJM transmission zones. I will also describe the updated
estimated budgeted costs for TrAL This suppiementai direct testimony updates and
supersedes the seven pages of my April I3 Tesimonl that 1 note abo~s. but diem
ise rhar
previous testimony remains unchanged.
EXHIBITS
PLE.4SE IDENTIFY A'ND DESCRIBE THE EXHIBITS TO YOUR SUPPLEMENTAL
DIRECT TESTIMOXY XWD SIJWIZE THE COhTEX'TS OF THOSk
EXHIBITS.
I am sponsoring two additional exhibits with my supplemental direct testimon!.:
o
TrAILCo Exhibit No. MAM-5 presenrs the updated allocation of revenus
requirements to Allegheny Power: and

_,--I_-
-I
Trans-Allegheny Interstate Line Company
Supplemental Direc.t Testimony of Mark A. Mader
Page 3 of 12
TrAILCo Statement No. 10A
1
e
TrAILCo Exhibit No. MpLz/I-6 presents updated TrhIL cost estimates.
2
UPDATED FERC COST ALLOCATION PROCESS
3 Q.
-1
5 A.
6
-
I
8
9
10
11
12
13
14
15
16
17 Q.
:8
19
10 A.
31
22
PLEASE DESCRIBE THE RECENT FERC ORDERS YOU REFERRED TO
EARLIER.
On April 19: 2007, FERC issued orders in Docket Nos. EL05 121 -000, et d, and ER06-
/---
-
1271-003, e! ai. (“April 19 Orders”) directing that new, centrally-planned facilities
within PJM that operate at or above SO0 kV (such as much of the TrAIL facilities) be
M1y allocated on a region-wide “postage stamp’’ basis and that costs for facilities below
500 kV (such as the Prexy 138 kV facilities of TrAIL) be allocated baed on a
“beneficiary pays” methodology. Under a region-wide “postage-stamp” raie design. the
costs of new, centrally-planned transmission facilities in the PJM region will be allocated
to all LSEs in PJM according to each LSE’s share of the regional load. Currently the
XIv--.-- i ~ ~ ”-
_._
” .~ i___
total Allegheny Power zonal load is approximately 6% of the total PJM regional load,
This load ratio share is updated atmually. Under a "beneficiary pays” methodology. the
beneficiaries of a particular transmission upgrade will be identified and dLrectly slliocated
the costs of that upgrade.
HOW DO THE REVENUE REQUIREMEKTS FOR TRAIL DIFFER FROM WHAT
YOU DESCRIBED IN YOUR APRIL 13 TESTLMONY AS X RESC‘LT OF FERC‘S
.@RE 19 ORDERS?
Under the prior methodology, as I pointed out at pages 5 through 10 of my April 13
Testimony, dl the revenue requirements associated with the non-Presy portrons of TrrUL
and the DVP Facilities were allocated to loads outside the Allegheny Power Zone. dde
7.N

I KHIL iuewsierrer Page 1 of 1
We at Allegheny- Energy are committed to open and ongoing dialogue to inform the public and our
customers about The Trans-Allegheny Interstate Line (TrAIL), the proposed 500-kilovolt transmission
line. That's why we want you to be aware that inaccurate information appeared in articles published
yesterday by several West Virginia newspapers and a national wire service.
Let's set the record straight: we have not requested a rate increase in West Virginia in connection
with the Trans-Allegheny Interstate Line.
The TrAIL has a simple, yet vital mission: to ensure the reliability of our region's electric transmission
system for years to come. We urge you to stay informed, keep an open mind and support a thorough,
fair review of our plans by your state regulators. Visit our Web site at rJ;.:y~:!:< ?p?.r..;r~~ilf~~~:!~~~~.
for more
information.
To contact us, send e-mail to ~ ~ ~ ~ or write ~ to TrAIL, ~ 800 ~ Cabin Hill ~ Drive, ~ ~ ~ ~
Greensburg, PA 15601.

1 INTRODUCTION
The Commonwealth of Virginia currently ranks near the bottoiii of all states in expenditures on demandside
nianagement (DSM)'- comprising more efficient uses of energ (energy efficiency) and the abiliq.
of a consumer to respond to scarcity and high costs (demand response) - according to the American
Council for an Energ)--Efficient Economy (ACEEE) and the Alliance to Saye Energ- (ASE).' This
creates a unique opportunity for the Conimonn.ealth to leverage key lessons learned and best practices
identified in other jurisdictions to develop efficiently and implement a cost-effecti7.e portfolio of DSM
program offerings.: Such a portfolio could rely on proven DSM tecluiologies and strategies to achieve
significant energy savings and peak demand reduction over a relatively short timefranie (i.e.. ivitliin moto-three
j-ears). as well as over the longer term. In addition. such a portfolio would generate additional
benefits by protecting ratepayers against future increases in energ! costs. proyiding system reliability
benefits. offering customers the abilic to better manage their energ costs. and maintaining a competitii e
regional economy as businesses increasingly look for locations with robust. diJ.erse energ supplies from
demand-side and supply-side resources.
' For the purposes of this report, DSM refers to energy efficiency. demand respnse. and iiino~ativ electric rates designed TCJ
shift energy use from peak demand periods. DSM coT:ers the panoply of activiries custoiners can take to nianaee their energ! iise
on their side of the meter. The 2Vnfiontrl .Irfion Plan for Energ?, Eflcienq defines energy efficienc!. a5 "Using less energ! to
provide the same or improved le.;el of service to the energy consumer in an economically efiicient way The teriii energ!'
efficiency as used here includes using less energy at any time." The US DOE defines demand response as "Chaiiges in eiectnc
usage by end-use customers from their normal consumption patterns in response to changes in the price of electriciv over tline.
or to incenti1.e payments designed to induce lower eIectrici6 use at times of high \\holesale market prices or nhen s!'stem
relinbilip is jeopardized." '4s specified in the report Een&ts of Demnd Respume hi Elecrncir?, .Lfarkers mid Recommei?n'nho?ls
for Achieving Them. the US DOE identifies two primq tspes of demand response: (1) Price-based demand response slrcll as
real-time pricing (RTP). critical-peak pricing (CPP) and time-of-use (TOU) tariffs. give customers time-vFing rates that reflect
the \due and cost of electricit\i in different time periods. h e d with this infonnation customers tend to use less electricit\ at
times \\hen electricitl; prices are high mid (2) 1ncenti.c-e-based demand response program pa! participating custoniers to reduce
their loads at times requested b!' the program sponsor. triggered either by a grid reliabilih. problem or high electricin prices.
Dan York Rr Martin Kushler. American Council for an Enerav-Efficient Econornv. .iCEEE's 3rd .\irtiontr/ Scoreborrrd oil
' Numerous sources exist compiling DSM best practices including the US DOE and US EPA. 3'afioml rlcrion Plan for Etrerg,
Eficiency. (July 2006); US EPA. Clean Energy-Emironmefit Guide to .-1ctio~7. Policies. Be57 Practices. mid .4ciiotz Steps for
Smtes. (April 2006): and California Best Practices Project Advisory Committee. .Yafional Energy&ficzenq~ Besr Pracrices Siz~d,
(Dec. 20043. http: I wwn..eebestpractices.coin
-1-

Resenations about DSM that the Virglnia State Corporation Commission (SCC) may have had under the
price-capped transition to retail competition no longer apply since that transition has been abandoned in
the new "reregulation" bill.4 In particular. the bill:
- Provides incentiJ,es for utilities to find renewable forms of energy and establish demand-side
in ana gemeiit and conservation pro grams:
-
..\llo\vs each utility to seek rate adjustment clauses to recover costs of FERC-approved demand
response programs and costs of providing incentives for the utility to design and implement
demand-side management programs; and
-
Directs the SCC to "conduct a proceeding to establish goals for the amount of enera and demand
to be reduced by the operation of demand side management. consen-ation. energy efficiency. and
load management programs. and deyelop a plan for the development and implementation of
recommended programs."'
More recently Govenior Kaine issued Executive Order 48 that directs the Commonwealth's executive
Branch to reduce the aimual cost of enerE purchases from nomenewable sources by at least 20% by
fiscal year 2010. These initiati\-es provide the Commonwealth with an opportunity to integrate costeffective
demand- and supply-side options into system planning processes. Ois-cn that L'irginia irtilities
ha~t: among the nation's least chdoped DSM programs and fi3di12g rhis direciive cc:il:! engezrder
cunsiderabie bush~:ys opprl-imiiies i'm kkpend~ni vendors ulr DSM prrsgranrs md tschnciogies.
ili sarieh of DSM programs that incorporate both energy efficiency (Le., permanent energy savings) and
demand response (i.e., targeted peak demand reduction) goals could be effectively applied in the
Commonwealth given Virginia's current economics and demography, These are characterized by
population and economic groivth6. a large concentration of commercial data centers, and significant
public sector facilities. The list of available program options can be narrowed by focusing on only those
DSM strategies and technologies that are most applicable to the Commonwealth's situation and have been
proven successful in other jurisdictions. Doing so shows that five DSM programs have the greatest
potential to generate energj savings and peak demand reduction. together with corresponding cost
savings. over a relatively short timeframe. The programs are described below. Estimated energy savings
and peak demand reduction associated with these programs are presented in Section 3.
1. Residential and Commercial High-Efficiency Lighting Programs provide financial incentives
to end-use customers to offset the incremental costs associated with pie-qualfied. hgh-efficiency
lighting sj stems as well as financial and educational incentives to lighting retailers and specialty
contractors to increase promotions and installations of high-efficiency lighting systems.
2. Residential HVAC Retrofit and Quality Installation Programs provide financial incentives to
end-use customers to offset the incremental capital costs associated with hgh-efficiency HVAC
equipment as well as utility financial and technical assistance to HVAC retailers and specialty
' Summa ssed House of HB 3068. wai I .st3te.\:a.us:ce;- .
Il!l?!.BBE.$
sc:s7:.1 ........o!.I.&%2
i-...biiff~di-.-.htiiO ..... . :I =. (accessed Mar. 19,2007)
'Id
' Peak demand for Dominion Virginia Power, the Commonwealth's largest electric utili?. is expected to increase b.i 1.8O.v per
?ear through 2016, from 18.138 MW in 2006 to 21,680 in 2016; Memll. Hyde. "Proposed Mt Storm-Meadow Brook-Loudoun
500-kV Line: Critical Analysis and Alternatives." confidential internal ivork product prepared for Bracewell t Giuliani. LLP
(March 2007)
2

Exhibit 5. Estimated Peak Demand (Mw) Reduction 29
Demand Response
44%
1 % Appliances & Office
Results from the current assessment suggest that a well-designed portfolio of DSM program offerings
including both energy efficieiicj- and demand response strategies could cost effectiyely reduce the
Commonwealths peak demand by approximately 5 .OOO MW and its enera. consumption forecasts bq-
7.800 GWh over a ten-year planning horizon. These estimates represent near15 17% of the
Commonwealth’s projected 2007 peak demand and nearly 10% of the Conimonn-ealtli’s projected 20117
enerz use. The estimates are well within the ranges presented in e\-aluations of DSM potential in other
jurisdictions. and are 1ikel:- conservative in that only basic DSM strategies viere considered. Additional
energy savings and peak demand reductions could lilielq- be achieved through DSM program offerings
that overcome barriers to DSM program participation, including customers’ lack of experience ivith high
efficiency products. lack of infomiation about available technologies and erpected sayings. and
uncertainh about equipment reliability and performance characteristics.
3.2 Demand Response in Wholesale and Retail Markets
Based on a surveq- of electric utilities nation~ide.~~ FERC recommended implementing actiTities to
enable greater use of demand resources in regional transmission planning and operations procedures. The
agency concluded that dentand response has an important role to plal; in both wholesale and retail
electricity markets. FERC estimated that the potential immediate reduction in peak electric demand that
can be achieved from existing demand response resources is betlveen thee and seyeu percent of peak
electric demand in most regions.” FERC Staff recommended that FERC: 1) esplore how to better
accommodate demand response in n-liolesale markets: 2) explore how to coordmate nith utilities. state
comniissions and other interested parties on demand response in wholesale and retail markets: and 3)
consider specific proposals for conipatible regulatorq- approaches; including h o to ~ eliniiiiate regulaton
” Id
30
Federal Energ> Regulaton, Cornrnlssion ,4ssessmen/ of DeiimndRespurm mzd.-Id cinced,\fzerenng. Staft Report. Docket No
AD-06-2-000. August 2006
I’ Man land Public Senice Commission. Ten-Yea1 Plan ofElectnc Companies in Mqland (2006-2015) (P 70)
13

arriers to improved participation in demand response, peak reduction, and critical peak pricing
pro grams. ''
A recent study done for the Mid-Atlantic Distributed Resources Iaitiati\-e (MADRI) quantfied the dollar
benefits of demand response in PJM." MADRI was established in 2004 by the public utility conmissions
of Delaware. the District of Columbia. Maryland, New Jersey and Pennsylvania. aloiig with the U.S.
Department of Energy (DOE), U. S. Environmental Protection Agency (EPA). Federal Energy Regulatop
Coniniissioii (FERC), and the PJM Interconnection. The MADRI study esainined the effects of reducing
electricity use by tliree percent during the Iughest use hours for five utility areas-Baltimore Gas &
Electric. Delmarva Power. PECO, PEPCO and Public Service Electric & Gas. The study quantified the
economic benefits of demand response by comparing prices R-ithout aid nith demand response reduction
during the 20 five-hour periods in 2005 with the highest electricity demand for each utilitl;.
As shom in Exhibit 6. findings from the study were that a three percent reduction in peak demand would
have generated a 5% - 8% reduction in wholesale electricity prices during the time periods in question.
"In addition to reductions in electricity prices. demand response participants were estimated to save $9
million - $26 million for eneru annually and another $73 million for capaciG- charges." Since Virginia is
part of the PJM Interconnection. it is reasonable to assume that similar benefits mould be realized in the
Commonlx-ealth if comparable demand response programs were put in place. Eshibit 6 summarizes the
prima? stud! conclusions.
.?
'- Mal? land Public Service Commission. Ten-Year Plan of Electric Companies in Maqhnd (2006-2015) (P. 76)
.'' Quantihing Deinand Response Benefits in PJM, Prepared by the Brattle Group (Jan. 29. 2007)
\\ n .en2?cetics,corn,.m3dri. pdfi Rrattle~roripl2eport.pdi'

O h Load Red1
tion in the Top 100 Hours ii
i 324DRI Zones"
Benefits
Caveats
S7-20 Million
(enerp only)
(1-2% price
reduction in
curtailed hoursj
n a
- Capacity price decrease
due to reduced demand
- Enhanced competitiveness
in energy and capacity
markets
- Real-time vs. day-ahead
- Value of reduced volatility
- Insurance against extreme
events
- Avoided T&D costs
ia
- Probably significantly
offset in long-run
equilibrium as capacity
and capacity prices
adjust, "long-run''
might not be so long
- Load shifting and
demand elasticity
offset some benefit in
short-term
- Based on simplifying
assumpbons regarding
the value of load that
is curtailed
n. a
nia
- Based on generic
long-run cost of
avoided capacity
- Ignores cost of
equipment and
demand response
program
administratron
S7-20 MiUion
- Additional benefits to noncurtailed
load could be
large
- Includes both the solid
economic efficiency
gains to curtailed load
and the less robust
benefits to noncurtailed
loads
34
Quantifiing Demand Response Benefits in PJM. Prepared bs- the Brattle Group (Jan. 29. 2007)
:$ ~~'i\.e!ier;etiCS.crJin, rsndri. pdts- RrattleGr~!inRecori.Ddl'
15

4. CONCLUSION AND ACTION AGENDA
Demand for electricity is increasing throughout the Commonwealth due to population growth. increasing
per capita energy consumption, and other factors. In order to meet current and anticipated energy needs.
the Coinmonwealth should consider both supply- and demand-side solutions. The potential for costeffective
energ savings and peak demand reduction delkered through well-designed DSM programs
using pro\-en enerG efficiency and deniand response technologies and strategies is substantial within the
Commonwealth and worthy of consideration by system planners, regulators. and lawmakers as they
deliberate the optimal resource portfolio to satisfv future demand.
4.1 Action Agenda
State legislatures. both within the PJM Interconnection and across North America (e.g.. Pennsylvania.
New Jersey. Minnesota. Illinois), have taken action rn 2007 by setting DSM targets and promoting -4MI
and inno\.ative time-differentiated rates that are much more ambitious than current proposals in the
Coimonviealth. In order to avoid falling further behind its peers. the Commonwealth should act novi to
apply key lessons learned and adopt DSM best practices pioneered in other jurisdictions." Such a
portfolio could rely on DSM technologies and strategies to achieve significant energy savings and peak
deiiiand reduction oyer a relatively short timeframe (i.e.? within three years). In addition, such a portfolio
n.ould pro\-ide additional benefits by protecting ratepayers against future increases in energ costs.
enhancing overall s>-steni reliability. proyiding customers the ability to inanage their energy costs, and
maintaining a competitive regional economy as businesses increasingly look for locations with robust,
diverse energTi supplies from demand-side and supply-side resources.
This is a critical time for the Commonwealth as large-scale electric infrastructure investments are being
considered throughout the region. Inyestments not made on the demand-side now. may be lost forever as
growing enerR needs are met through higher cost supply and transmission investments. The
Common\A ealth needs to use the powers of the State Corporation Commission or of the State Legislature
to.
- Set DSM targets and proyide incentives for deniand response programs. innovative rates, and
advanced metering technology.
- Set targets for 1% reductions per year in forecast energy consumption and peak demand growth,
goals that are well within reach of Dominion Virginia Pover. the largest utihg in the
Commonwealth.
- Address financial disincentives for utility investment in DSM. This generallj includes cost
recovery of iinestnients 111 DSM and related infrastructure. treatment of lost margins on fixed
costs (not total lost revenues) stemming from reduced sales due to DSM.j6j7 and alloning the
.-
'' Nunieroiis sources exist compiling DSM best practices including the US DOE and US EPA. See EPA. et al.. .Yanomddcrioi7
Phi for EHPI"&I' Eficienc): (July 2006): EPA. Clean Etlergy-E~ro~wneizr Guide to .1 ction: Policies, Best Pmctices. mid .4ction
Steps ,for States. (April 2006): and California Best Practices Project Advisory Committee, .Vationnl Ene~g), Eficzenc~~ Best
Pm7ncticr.s Stir&. (Dec. 2001), -v. nn .rrbestnracrices.com. ndf;BP Sunlrnan:.pjf.
'@
A comnion mistake is to assume that DSM increases energy costs. DSM does not increase energy costs. Even if DSM were to
reduce sales so dramaticall!. that fixed costs were not recovered by the utility and the price per kWh \\-ere to increase. then the
16

6
How Dominion and Allegheny Power
Got It Wrong
The 502 Junction-Mt. Storm-Meadow Brook-Loudoun (TrAI L)
500-kV Transmission Line
September 2007
Piedmont Environmental Council
45 Horner Street
Warrenton, VA 201 86

1
Contents
SECTION 1: INTRODUCTION AND CONCLUSIONS ............................................ 2
REFERENCES
................................................................................ 3
......................................................................................................... 3
...................................................................................................... 3
.................................................................... ............. 5
SECTION 2: WHY DO DOMINION, ALLEGHENY, AND PJM WANT TO DO
THIS? ................................................................................................................................. 6
HAMMERS AND NAILS ..... ............................................................ 6
MARKETS FOR COAL-FIRED GENERATORS ................... .............................................. 6
POR LIOS ....................................... 6
LOW-RISK ADDITION TO DOMTN-ION/ALLEGKENY
SECTION 3: WHAT IS THE REAL PROBLEM?. ..................................................... 7
LINE OVERLOADS AND LOW VOLTAGE ............................................................................ 7
THE OVERLOADS REFLECT A BAD ASSUMPTION ....................................
A REGIONAL ISSUE - NOT A NORTHERN VIRGINIA ISSUE .......................
SECTION 4: DID THEY LOOK AT THE RIGHT SOLUTIONS? . 11
SOLUTIONS THEY CLAIM TO HAVE CONSIDERED ........................................................... 11
SOLUTIONS NOT CONSIDERED ........................................................................................ 11
SECTION 5: DID THEY FIND THE BEST SOLUTION? . 14
WHAT IS "BEST"? ................................................................................................... 14
SELECTION AMON TERNATIVES .......................................................
SECTION 6: WHAT IF THE LINE IS BUILT? ........................................................ 17
CONSUMER COSTS ......................................................................................................... 17
GENERATION MARKET EFFECTS .................................................................................... 18
JOB AND INVESTMENT TRANSFERS ....................... 19
LINE AFTER LINE ........ ....................... 19
ENVIRONMENTAL QUA ....................... 19
A LESS-RELIABLE SYSTEM ................................... .................................................... 19
APPENDIX A: ALTERNATIVES TO THE LOUDOUN LINE . 20
APPENDIX B: DOMINION'S ANALYSIS OF GENERATION AND DEiMAND
MANAGEMENT ALTERNATIVES ............................................................................ 22

2
Section 1: Int7.oduction and Conclusions
i
Dominion Virginia Power (Dominion) and Allegheny
Power (Allegheny, through its TrAlLCO subsidiary)
have applied to the Virginia State Corporation
Commission (SCC) to build a 500-kV line through the
Shenandoah Valley and Northern Virginia Piedmont.
To sell the project, they have said that burdening this
area with 165-foot-tall towers and 150-foot-wide rightsof-way
is the only way to prevent power blackouts in
Northern Virginia. This alarm is false - a scare tactic
- coming from;
0 Failure to understand that reliable and
economic power comes from a combination of
power generation, transmission, and
management of the quantity and timing of
demand; and
A myopic search for solutions that looks only to
transmission from remote plants and ignores
new local power sources and demand
management.
The SCC should deny the Dominion and TrAlLCo
request to build this line. It is an unnecessary, risky,
high-impact, sub-optimal solution.
In this report, the Piedmont Environmental Council (Piedmont) shows that the
sacrifice that Dominion and Allegheny demand of Northern Virginia cannot be
justified. Specifically, they have:
s
e
e
Ignored less costly and less environmentally damaging solutions;
Misrepresented the need for the proposed transmission line as a local
Northern Virginia issue rather than as a regional issue;
Made wildly unrealistic (but undisclosed) assumptions in analyzing the
needs of Northern Virginia and the greater Mid-Atlantic area; and
0 Claimed falsely that the proposed transmission line will benefit consumers,
when (as they know) studies show that the line is more likely to enrich
power generators to the west at the expense of consumers.
For these reasons, authority to build the proposed transmission line should be
denied,

3
Background
This paper analyzes the proposed 502 Junction-Mt. Storm-Meadow Brook-
Loudoun 500-kV power transmission line (Loudoun line) that Dominion and
Allegheny seek authority to build across Northern Virginia. We analyze their
filings with the SCC and related documents from the US. Department of Energy
(DOE), Dominion, and PJM. PJM operates the electric power system in several
eastern states. It also plans the extra-high voltage (EHV) electrical grid in that
area.
Some History
May 12, 2005: PJM proposed to the Federal Energy Regulatory Commission
(FERC) the Mountaineer concept to provide 5,000 MW of new capacity to
transmit predominantly coal-fired electric generation from power plants on the
Ohio-West Virginia border through new corridors ending at New York City. This
would be PJM's largest initiative ever. PJM did not show the need for 5,000 MW.
PJM's objective seems to have been to provide markets for western generation.
Strategic alternatives (local generation, demand management, and transmission)
and the various trade-offs were not addressed.
Auaust 8, 2005: The President signed the Energy Policy Act of 2005. This gave
the DOE authority to define "national interest" transmission corridors and to
facilitate new transmission.
March 6, 2006: Allegheny asked the DOE to confer early "national interest"
designation on its proposed "TrAIL" 500-kV line, funning from western
Pennsylvania to northern Maryland. This was the first concrete plan to
implement the Mountaineer concept.
June 2006: PJM endorsed the Loudoun line instead of the TrAlL line. The
Loudoun line is a revision of the TrAlL line, with a route shift into Virginia. We will
show that PJM's analysis of the Loudoun line was superficial. Allegheny now
calls its portion of the Loudoun line "the TrAlL line."
Auqust 2006: The DOE released its "National Electric Transmission Congestion
Study," which explicitly endorsed the assumptions underlying PJM's Mountaineer
concept. The study did not question or analyze PJM's assumptions or
conclusions.
Conclusions
Arguments for the Loudoun line are wrong. Dominion, Allegheny, and PJM
argue that it is needed to solve a possible voltage problem' at Meadow Brook in
2011, possible overloads of the Mt. Storm-Doubs 500-kV line in 2011, and
Voltage in an EHV system may drop below its normal level when a local area draws power from
the grid. An excessive drop results in voltage collapse and a local blackout that may cascade.

possible overloads of the Pruntytown-Mt. Storm 500-kV line in 2014. These
problems would only occur under certain unlikely contingencies.
PJM's planning process is biased to find solutions only using transmission
lines. The process is incapable of asking for, or finding, optimal solutions
that include generation, demand management, and transmission options
on a level playing field.
The threatened overloads are not real. They flow from PJM, Allegheny.
and Dominion unrealistically and unreasonably assuming that essentially
all new generation will be built in western PJM and essentially none in
eastern PJM. To the contrary, there are more than enough proposed
generation projects in eastern PJM to avoid the overloads without a new
line.
0 Voltage may become a real concern at Meadow Brook. But this can be
solved at low cost with no environmental impact using conventional
technology, wifhout the Loudoun line.
Building the Loudoun line would adversely affect the environment along its route
and the economy and reliability of power in eastern PJM. Specifically, the
Loudoun line would:
Directly damage the environment. A line with towers as high as a 16-story
building could be seen from at least two miles on either side of the line. A
270-mile line would negatively affect over 1,000 square miles. In addition
to damage to birds, other wildlife, habitat and vegetation, land-use
damage would be significant, resulting in change to current and planned
land uses. These issues are explored in more detail in other Piedmont
documents .
Make eastern PJM even less attractive for new generation than it is now,
with more coal-fired generation built in western PJM instead. This would
lead to spiraling west-to-east transmission needs.
Transfer jobs and tax revenues from eastern PJM to western PJM.
Compound the direct and indirect environmental impacts of transmission.
Western coal-fired generation would be much more harmful
environmentally than the eastern natural gas-fired generation it displaced.
Condemn populous eastern PJM to increasing dependence on remote
western generation, making PJM more vulnerable to cascading blackouts.
Increase cost to ratepayers.

5
References
We quote most often from five sources.
1. RTEP - "Regional Transmission Expansion Plan," a 330-page PJM report,
dated February 27, 2007, and available at
h ttp://ww. an n i ncl/req-tran s-em- RI an. htm i .
rs j rn . co m/~l
2. Dominion Filing - an April 19, 2007 six-volume filing Dominion made with
the SCC in support of the Loudoun line, and available at
http://w . dom .ccm/aboest/elec-transm issionlsiowerlinelmeadowbr~c~
sccam. iss
The oft-cited KEMA Report is contained within the Dominion filing at
~ttp://~~.d0m .com/aboutlelec-transmissian/Bower[ineim~~
ap~Iicatjon/vsI2lkema reoort.odf
3. TrAlLCo Filing - an April 19, 2007 filing TrAlLCo made with the SCC in
support of the Loudoun Line, and available at
http:l~w.aplraijinf0.c0m/index.DhD?page=vir~inia
4. Discovew - Dominion answers to discovery by Piedmont and others in the
SCC proceeding and available in relevant part on Piedmont's website at
http ://www. pecva . ora/ d ow n loads/ts owe rhn es/dccum ents/industn//Dm i nio
nDiscoverv.Ddf .
5. DOE - "National Electric Transmission Congestion Study," a 122-page
DOE report, available at
httsi:l/nietc.anl.aov/documentsibocs/Con~~~ Studv 2006-9MB.~df

6
Section 2: 7Vhj do Don ii io
Allegheny a i PJMtwnt LO do this?
PJM - a transmission system operator and planner - is
predisposed to solve all power challenges with
transmission.
Coal-fired utilities in western PJM, including Allegheny,
will get lucrative access to eastern markets and
ratepayers will pay the freight.
Dominion/Allegheny can invest surplus cash in a lowrisk
project with guaranteed return - an addition to
balance their portfolios.
Uammers and Nails
If you are a hammer, then every problem looks like a nail. PJM is responsible for
planning the transmission system. PJM has transmission engineers and the
tools and data for transmission planning. This predisposes PJM to meet every
problem with a transmission hammer.
Markefs for Coal-fired Generators
Western-PJM utilities Allegheny and American Electric Power (AEP) are primarily
coal-fired. With only modest internal demand growth, they are actively seeking
new markets. The obvious targets are in the East. With the Loudoun line and
other proposed west-to-east transmission, western utilities will secure access to
these markets, financed by ratepayers throughout PJM.
By burning cheap fuel to sell into high-priced markets, Allegheny, AEP and
others may make more money per kWh than by selling to their regulated
customers. Sales to the east will let them profit from any spare generating
capacity that they may have from time to time. It is no accident that Allegheny
and AEP are partners on the proposed Amos-Bedington-Kemptown 765-kV line,
and that Allegheny is partner with Dominion to build the Loudoun line.
Low-Risk Addition to DominioMAllegheny Portfolios
In the past, Dominion invested some of its excess cash in oil and gas exploration
and production and in interstate gas pipelines. Some of this investment was
speculative and most of it was more risky than electric power transmission.
In fact, the return on all of the investment by Dominion and Allegheny in the
Loudoun line is guaranteed.

7
Section 3: What is the Real Problem?
Dominion, Allegheny, and PJM planners say that two
key lines may overload in 2011 and 2014, and that
northwestern Virginia may experience voltage
problems in 2011. According to the planners, the
overloads and voltage problems will occur only in the
event of certain known low-probability contingencies.
If these occur, voltage could be low. But the
threatened line overloads are not a real risk. PJM's
unrealistic and unreasonable assumption that
essentially no new generation will be built in eastern
PJM fuels the DominionlAllegheny cries of "Wolf!"
Dominion claims that Northern Virginia load growth
requires the line. To the contrary, the Loudoun line is
to serve loads in a broader region, of which Northern
Virginia is a small part.
Line Overloads and Low Voltage
Power system equipment occasionally fails. The power system is therefore
planned redundantly and operated conservatively, The goal is to withstand
"contingencies"- failures of one or more bulk transmission or generation
facilities. Dominion and PJM planners say that under certain contingencies:
1. The Mt. Storm-Doubs and Pruntytown-Mt. Storm 500-kV lines may
overload in 201 1 and 201 4, respectively, and
2. Low voltage may occur near the Meadow Brook substation in 201 1.
See Fig. 3.1 for these locations on the Northern Virginia grid.
In addition, utility planners claim that some lower voltage lines and transformers
in western Virginia will overload under certain contingencies. Building the
Loudoun line would fix some of the problems on the lower-voltage system. But
new extra-high-voltage transmission lines are not built to address local problems
on the lower-voltage system. Local, cheaper, and less obtrusive fixes are readily
available.
Finally, PJM says that under some contingencies many lines in eastern PJM
could overload and that voltage problems could occur throughout eastern PJM in
2016. This reflects the gradual growth of electrical demand and PJM's unrealistic
assumption that little or no new generation will be built in the area, and that

demand growth will not be moderated by new demand management programs.
In recent years, demand has grown at around 2% per year in most of PJM,
including Dominion's territory. This modest growth rate is predicted to continue.
Planners constantly study future conditions to find where the system needs
1
Fig. 3.1. Key transmission facilities in and near Northern Virginia.
The Overloads Reflect a Bad Assumption
The Dominion/Allegheny/PJM projection of overloads on the Pruntytown-Mt.
Storm-Doubs 500-kV lines is not supportable. This also is true for many of the
problems in 2016. These overloads show up in computer models as a direct
result of an unrealistic and unreasonable assumption.
This assumption is that almost no new generation will be built in eastern PJM.
PJM databases used for all reliability studies assume, for instance, only 19.8 MW
of new generation added in Virginia, Maryland, and the District of Columbia by
2012 and only 640 MW more by 2016.2 In contrast, the same databases assume
that thousands of MW of new coal-fired generation will be built in western PJM.
None of the utilities publicly acknowledges this assumption or its implications.
The thousands of MW of generation projects proposed for eastern PJM belie the
assumption. See Table 3.A. Most of this is gas-fired generation with in-service
dates of 201 1 or earlier.
2
Dominion's Response to Discovery (Bates No. DOM000558)

9
Table 3.A does not include the proposed 600-MW CPV gas-fired Warren plant to
be built near Meadow Brook by 2010. The plant reportedly has obtained all
needed permits and has had an interconnection agreement with Dominion for
several years. It was put on hold temporarily but the developers told Dominion
and PJM in 2006 that they now would go forward. Remarkably, it is not in any of
the databases.
With modest demand growth, but essentially no new
generation in eastern PJM through ten years, of course
imports from western PJM would Qrow. Of necessity the
computer models using this assumption will show westto-east
lines overloading, and the 2016 voltage
I
Table 3.A
New gene,ation in
local PJM queues
Source PJM RTEP
Location
problems, too. MD + DC 5,170
Dominion 3,209
If even some - not necessarily all - of the generation
in Table 3.A materializes, major new transmission will not be needed in 201 1.
Mirant Mid-Atlantic is one of the largest independent power producers in PJM,
with 5,000 MW of capacity in the Washington DC area. "Mirant has been
analyzing the [Loudoun line] . . . . Our analysis shows that facility overloads are
highly sensitive to . . . [generation] assumptions used in the model." Mirant says
that this may amount to "perhaps 2 MW of transmission flow for every [I] MW of
generati~n."~ Mirant complains that PJM made independent and far-reaching
assumptions about Mirant plants.
The real problem, then, is the need for new generation in eastern PJM. In
the past, generation development in the area lagged. In 2006 Joseph T. Kelliher,
Chairman of the Federal Energy Regulatory Commission, placed the blame
squarely on a broken PJM market.4 Since then some fixes have been made, and
more than the needed amounts of new generation are in the pipeline for eastern
PJM. But PJM, Dominion, and Allegheny still assume that almost none will be
built.
A Regional Issue - Not a Northern Virginia Issue
Dominion claims that the Loudoun line is for Northern Virginia. This is a political
claim advanced to overcome local opposition to the line. It is not a fair
description of the primary purpose of the line.
The supposedly overloaded Pruntytown-Mt. Storm-Doubs 500-kV path begins
near huge coal plants on the Ohio River. It connects them and West Virginia's
Mt. Storm coal-burning plant to an important transmission substation in Maryland,
' Robert E. Driscoll, CEO, Mirant Mid-Atlantic LLC, letter to Steve Herling, Vice President
Planning, PJM (June 7, 2007). http:/lwwv piin.comicommilteeslteacidov:nlcadsi20070509-
mirant-comments. pdf
4
Joseph T. Kelliher, statement on PJM Reliability Pricing Model (Apr. 20, 2006).
I
I

north of Washington DC. Most of the power on this and a parallel line serves
Washington DC, Baltimore, and their Maryland suburbs. Some of it finds its way
north and east to Philadelphia and Delaware. Only a small fraction flows south to
Northern Virginia.5
In the RTEP report, PJM concedes that the Loudoun line will serve needs in
Pennsylvania, Delaware, Maryland, the District of Columbia. and possibly other
load centers, in addition to Northern Virginia.'
Table 3.8
Northern Virginia accounts for a small fraction of the demand
(in megawatts, MW) that the Loudoun line is supposed to serve.
Table 3.B shows
that
Virginia demand is
2006 2011 Forecast Increase
Northern Virginia
6,368 6,833 465
PEG0 Energy Co. - PA 8,337 8,904 567
Delmarva Power & Light - DE, MD 3,994 4,403 409
Baltimore Gas 8 Electric - MD 7,212 7,703 491
PEPCO Holdings - DC 6,953 7,474 521
Totals 32,864 35,317 2.453
Sources:
Northern Virginia: Dominion filing, Attachment I 8.3
AII others. RTEP report
Northern Virginia's projected load growth of a mere 465 IWW obviously does
not require a new 3,000 IMW line. The real problem is regional.
7
KEMA Report, pp. 23-33.
PJM RTEP, pp. 171, 215, 270,297.
Table 3 B actually overstates Northern Virginia's fraction of the load to be served by the
Loudoun line The table does not include Allegheny Power's customers in Northern Maryland,
who are served from the Doubs and Bedington substations and would be served by the Loudoun
line. We do not know their demand since PJM lumps it with that of other AP customers further
west, but the KEMA Report indicates that it might be 2,200 MW in 2011.

11
Section 4: Did they Look at the Right Solutions?
Dominion and PJM purport to have studied four
alternatives to the Loudoun line. But three of the four
were straw men, set up to be knocked down.
Inadequate voltage can be solved inexpensively and
with no environmental impact, using conventional
technology.
Line overloads have many real solutions. The most
important is to build local power plants in proximity to
demand instead of siting them remotely in western
PJM and then needing transmission, too. Demand
management could contribute. And there are real
transmission alternatives to the Loudoun line.
Solutions they Claim to Have Considered
Dominion and PJM considered four putative alternatives to the Loudoun line.
1. A second Mt. Storm-Doubs 500-kV line;
2. A Mt. Storm-Loudoun 500-kV line;
3. Reconductoring the existing Mt. Storm-Doubs 500-kV line; and
4. The originally proposed 502 Junction-Mt. Storm-Kemptown 500-kV line -
Allegheny's original TrAlL.
Of these, only the last is a real alternative. The first two obviously would make
the Pruntytown-Mt. Storm overloads worse. The third, reconductoring, would
require taking the Mt. Storm-Doubs 500-kV line out of service for a long period.
That would be risky and reconductoring might not appreciably increase transfer
capability.
Solutions not Considered
If load grows, then power plants must be built somewhere. Transmission lines
don't generate power. Transmission options are really "new western coal-fired
power plants, plus transmission." The real choice is between these options and
"new eastern power plants, without major new transmission." See Appendix A
for more details on the options below.
1. Build power plants in eastern PJM. PJM power markets need to be
repaired so that they support continued operation of existing generation
and induce investment in new generation in eastern PJM, near urban load

~~ ~~~
h
12
centers nd 0th r demand. PJM has recently undertaken some
encouraging efforts to fix its market. New generation, including gas-fired
power plants near Washington, DC, has been announced recently beyond
what is included in Table 3.A and retirements have been postponed. Even
the continued operation of Mirant's plant in Alexandria, near demand
centers in the District of Columbia and Northern Virginia, would represent
a major change in the assumptions used by the utilities. Similar efforts
have recently met with success in New England.
2. Develop demand-side resources. Dominion's demand-side management
(DSM) efforts to date have been minimal. Even moderate development of
DSM resources could make a significant contribution to power supply in
Virginia and eastern PJM, as documented in a recent study by Summit
Blue Consulting. A 10% reduction (more than 3,500 MW) in eastern PJM
is feasible, though perhaps not quite by 201 1,
3. A 525-MVAR static VAR compensator (SVC') at the Meadow Brook
substation. This would fix the only real problem that Dominion advances
as justification for the Loudoun line, low voltage near Meadow Brook. It
would cost about $35 million, with no environmental impact. In contrast,
the Loudoun line would cost more than $850 million and have a
devastatingly destructive impact on a historically important and largely
pristine environment."
4. A phase-angle regulator (PAR) on the Pruntytown-Mt. Storm line. It would
direct some flows away from the Pruntytown-Mt. Storm-Doubs lines onto
lines that are less heavily loaded.
5. The proposed Amos-Bedington-Kemptwn 765-kV line. Allegheny and
American Electric Power propose to build a huge line from the Ohio River
to a point just north of Washington, DC. According to PJM, even with the
Loudoun line, this 765-kV line is needed to solve serious problems in the
region beginning in 2012. But our studies show that if it is built, the
Loudoun line will not be needed.
There are other options, conventional as well as innovative, for meeting needs in
201 1, 2016, and beyond. But Dominion, Allegheny, and PJM investigations into
alternatives thus far have been very shallow,
a
The Federal Energy Regulatory Commission chairman blames apparent generation shortages
on a broken PJM market. See Joseph T. Kelliher, Chairman, Fed. Energy Regulatory Comm'n,
Statement on PJM Interconnection, LLC Reliability Pricing Model (Apr. 20, 2006).
9
SVCs are widely used devices that control voltage by supplying or absorbing reactive power, or
VARs. They are controlled by solid-state valves, which have no moving parts. They are used in
place of older, larger rotating devices whose footprint was as large as a house
lo if there were a drop in water pressure at your house the water company could consider two
alternatives. It could install a giant new pipe all the way back to the reservoir - tearing up
hundreds of miles of ground. Or it could put a small pump near your house. If it chose the
former, you would guess that they had some other use for all that water.

13
KEMA, Inc., a consulting firm, evaluated demand-side and generation options for
Dominion.” KEMA was not part of the planning process. Its evaluation was
done months after Dominion had already committed to the Loudoun line. KEMA
was hired to bolster Dominion’s filing with the SCC.
KEMA did not consider viable demand and generation options. Furthermore,
KEMA ignored transmission, generation, and demand management options that
could in combination displace the Loudoun line.
KEMA‘s analysis was overly simplistic. Its conclusion that a massive new
transmission line is the best solution is not justified. See Appendix B for details.
” KEMA Report, pp 69-70

14
Section 5: Did they find the Best Solzition?
The objective of Dominion, Allegheny, and PJM is to
maximize reliability at the lowest cost. But the
planning process ignores important generation,
demand-side, and transmission alternatives as well as
environmental protection and regional development
issues.
I
PJM claims that its transmission decisions are optimal
because it only acts when generators have failed to
solve problems. This remarkable fallacy has it just
backwards. PJM has evaluated very few of the
generation proposals for service before 2011 and
hence ignores them for planning purposes - "the
generators have failed to act!" PJM is only now
beginning to accept generation study requests for
2014. PJM's decision to build the Loudoun line, if
approved, will foreclose future generation decisions in
a self-fulf i I I in g prophecy .
I
What is "best" is measured in relation to some
criterion. The utilities' criterion is reliability (in
this case, maximum improvement in
transmission capability) at minimum cost.'*
This limited perspective virtually ensures that
Dominion's choices will not be "best" in relation
to many important criteria.
Environmental protection plays no role in PJM's
transmission planning. It seems to be an addon
after the major decisions are made. Table
5 . Summar,zeS ~ word searches of PJMI~ 330-
page RTEP. On average, forms Of the words
"reliable," "economic," and "cost" appear f'nOre
Word Occurrences
Table 5.A
in the RTEQ
report reflect PJM's priorities
Various forms of Occurrences
reliable 444
economic 141
cost 131
environment 12
cu Itu ral 1
historic' 0
scenic 0
+"Historic" Was never used In the Context
"historic site" It was used ten times in
the context "past and continuing
operatlon of the power system
l2 For instance, see Dominion Application, testimony by Scott Gass, pp. 17-18.

15
Ten of the twelve uses of the word "environment" referred to power plants. Only
one referred specifically to transmission. It did so only to bemoan the difficulty of
siting transmission lines due to environmental concerns.
By contrast, Virginia places a great deal of importance on the environment. The
State Code reflects that in § 56-46.1 which states that, 'IAs a condition to
approval the Commission shall determine that the line is needed and that the
corridor or route the line is to follow will reasonably minimize adverse impact on
the scenic assets, historic districts and environment of the area concerned." This
evaluation should be done when the planners are evaluating the various
alternatives. It should not be an afterthought, done after the key decisions have
been cast in concrete. 13
The focus of Dominion and Allegheny is the same as PJM's. They failed to
consider the relative environmental impacts of alternatives. A line with towers as
high as a 16-story building could be seen for miles on either side. The 270-mile
line Loudoun line would visually mar over 1,000 square miles. Wildlife,
vegetation, and other land-use damage would be ~ubstantial.'~
PJM ~ Dominion, and Allegheny have ignored other important considerations as
well. They failed to consider the effect a transmission line has on a number of
environmental attributes, including air quality. The Loudoun line would bias
generation plans, encouraging new coal-fired generation in western PJM and
discouraging new natural gas-fired generation in the east. Coal-fired plants are
much more environmentally damaging than natural gas plants.
Se/ec tion among A ltern a fives
"We can order transmission owners to build lines, but we cannot order generation
to be built," admits a PJM spokesman. "So if we are seeing overloads
developing, the only thing we can order is power lines."15 From this crabbed
perspective, PJM concludes: "When PJM proposes a transmission upgrade . . .
to resolve a reliability issue or transmission constraint, by virtue of the market's
inaction regarding other potential solutions, the . . . transmission solution
becomes the most economical option."16
73
The Electric Power Research Institute developed a multi-objective method to find out how
much transmission a system needs. One of the objectives of this analytical framework was to
minimize "corridor impact." EPRI, An Approach for Determining Transfer Capability Objectives,
EPRI EL-3425, Mar. 1984. PJM utilities and engineers were heavily involved in this work,
14
"Comments of the Piedmont Environmental Council" Statement of Catherine Gilliam,
Attachment A, filed with DOE July 6, 2007. (Comments regarding the DOE'S National Interstate
Electric Transmission Corridors.)
15
Mark Clayton, Cheap Power to Northeast US: a mixed blessing, The Christian Science
Monitor, May 9, 2007, at p. 4.
l6 PJM RTEP, p. 121. See also p 40.

16
This flagrant non sequitur shines the light on PJM's (and Dominion's) myopia.
Compared to nothing - inaction - any course of action can be pawned off as
optimal.
PJM does not recognize a proposed plant in its transmission studies until (1) a
Generation Interconnection Feasibility Study, (2) a System Impact Study, and (3)
a Facilities Study have been completed and (4) an Interconnection Service
Agreement has been executed.
Except for large new projects, like nuclear units and (western} coal-fired plants,
PJM will not allow a proposed generator to begin this process more than seven
years before its in-service date. The study queues for 201 I were therefore not
open until 2004. The transmission planning data bases used to analyze the
Loudoun decision were developed in 2005 or early 2006. Few generators had
had time to complete the interconnections studies by then. Proposed generators
are still entering the study queues for in-service in or before 2011. In fact!
interconnection studies have not yet been completed for most of the power plants
proposed for service in eastern PJM between 2007 and 2011.
PJM is only in 2007 beginning to allow proposed generators to enter the study
queues for 201 4 in-service. The queues for 201 6 will not open for two years.
Thousands of MW of generation projects were and are pursuing this process in
good faith. But in PJM's "Chicken Little" approach, "The sky is falling; the
generators have failed to act; therefore we will build the Loudoun line, and our
decision is optimal!" Joseph Heller calls this "Catch-22."
If the line is built, it will cause prices on the eastern PJM bulk electricity market to
drop. This will discourage new generation in that region. PJM can then say,
"See, we were right!" in a self-fulfilling prophecy.
The true optimal course is to fix the PJM market so that it induces desired
actions, such as maintaining and refurbishing existing generation and attracting
investment in new, clean generation and demand management where it is
needed in eastern PJM. By taking these options off the table, and committing
only to transmission solutions, PJM, Allegheny, and Dominion foreclose or bias
decisions on demand management, new generation, and refurbishing older
power plants.

17
Section 6: Khat ifthe Line is Bziilt?
1 If the Loudoun line is built:
The PJM system will be inherently less reliable
and more vulnerable to cascading blackouts.
PJM studies show that consumers will pay
more and generators (primarily in western PJM)
will profit more.
Changes in marginal cost will discourage new
generation in eastern PJM and encourage it in
western PJM.
This will cause a spiral of more and more major
west-to-east transmission.
Related jobs, investments, and tax revenues
will migrate from the east to the west.
Environmental damage will be greater.
Consumer Costs
If the Loudoun line is built, regional transmission congestion may be reduced.
But a PJM study shows that ratepayers will pay more for power and generators
will make more profits.I7 To demonstrate this we must analyze the PJM study
and the Byzantine PJM market process. We regret that these are complex. The
complexities have kept people from understanding what will really happen.
When congestion occurs in PJM, the price of electricity in the bulk markets goes
up dramatically. To keep generators from reaping windfall profits, and to protect
ratepayers, part of the price increase is captured by PJM and reimbursed to the
ratepayers through "financial transmission rights" or FTRs. The FTR payments
reduce the net costs of congestion to ratepayers.
In a 2010 test year, the PJM study shows that ratepayer payments to generators
(summed throughout PJM) will increase by $169 million if the line is built, even
though congestion is reduced. (One would think that reduced congestion would
mean lower payments. The increase is due to defects in market processes.)
In addition, generator production costs (fuel costs) will go down by $140 million.
This saving, though, is not passed through to ratepayers. Rather, the generators
" "Market Efficiency Analysis Preliminary Results," PJM TEAC committee report, Feb. 21, 2007.
Later versions of this report analyze a more distant future in three scenarios. Depending on
assumptions about new generation, the benefits of the Loudoun line may accrue to generators or
consumers. In the most likely scenario, the benefits accrue to the generators, at the cost of the
ratepayers, as in 2010.

18
as a whole (but mainly those in western PJM) will be $309 million richer ($169
million more in revenue plus $140 million less in fuel cost). See Table 6.A.
r
Dominion publicly argues that
gross payments by the
ratepayers will go down by
"f'?lore than $600 million'' (the
number is actually $621 million,
according to the PJM study),
Table 6,A
The Loudoun line will make generator income
increase (2010 PJM test year)
$ 169,000,000 Increase in revenue
140,000,000 Decrease in production (fuel) cost
$ 309,000,000 Net increase in generator income
The ratepayers also will
pay for the line itself - an
average "mortgage
Table 6.B
The Loudoun line will make customer costs increase
(2010 PJM test year)
$ 621,000,000 Decrease in gross customer payments
790,000,000 Decrease in FTR reimbursements to customers
$ 169,000,000 Net increase in customer costs
200,000,000 Annualized cost of the line itself
$ 369 000 000 Total increase in customer costs
In summary, building the Loudoun line may make congestion go down. But
because of imperfections in the PJM market processes, PJM's study shows that
the line will make generator profits and customer costs go up.
Generation Market Effects
If the Loudoun line and other new east-to-west lines are built, then market prices
and revenues to generators in eastern PJM will drop, as will output from those
generators. Conversely, prices and revenues to western generators as well as
output from western generators will rise. As discussed earlier, PJM studies show
that revenues to generators as a whole will increase. Constellation Energy, a
major eastern PJM generating company, pointed out that "it would simply be
imprudent to make an investment [in eastern PJM] that had no opportunity to
recover its fixed costs" after new lines are built." For the same reason, older
generators in the east will tend to be retired instead of cleaned up and
'' Dominion Application, testimony by Steven R. Herling, p. 19.
19
Letter from Divesh Gupta, Counsel for Constellation Energy to PJM Board (June 15, 2007),
(available h~p:iiLt?r,/wlp!~.ccrmi~omm~~~~~/~eac/~~w~loads~~O@7~~#9-~~~-i~~~~,

19
refurbished. New cleaner generation will not be built in eastern PJM. Dirtier
coal-fired generation will be built in western PJM instead.
Job and Investment Transfers
If the Loudoun line is built, jobs building and running power plants will be in the
west, not the east. Western communities and school districts, not eastern ones,
will get the high property taxes on power generation that will be paid (as part of
their rates) by eastern consumers.
Line after Line
If the Loudoun line is built, then major urban centers in eastern PJM, including
Washington DC, will become increasingly dependent on imported power. More
and more transmission will be needed resulting in an "aluminum sky."
Environmental Quality
If the Loudoun line is built, it will scar some of the most scenic and historically
important parts of the country. Many of these lands are held in permanent
conservation easements. Wildlife (including endangered species) and its habitat
will be injured. The resulting transmission spiral will make environmental
damage spiral too.
New power plants will burn coal in western PJM instead of natural gas in eastern
PJM. The local (western PJM) environmental impact of new coal plants will be
much greater than the local (eastern PJM) environmental impact of new natural
gas plants. In addition, coal plants emit more greenhouse gases and other
airborne pollutants than do natural gas plants.
A Less-Reliable System
If the Loudoun line is built - leading to spiraling dependence on long-distance
power plants - then PJM will become more vulnerable to cascading blackouts.
Depending on long-distance energy transfers is less reliable (all else being
equal) than relying on local generation or local conservation.
The province of Quebec epitomizes this. Hydro-Quebec, the provincial power
company, gets much of its power from huge, remote hydroelectric plants. As a
result, the system has been so highly prone to blackouts that all of Hydro-
Quebec's interconnections are expensive direct-current links that effectively
quarantine the province from its neighbors to prevent cascading failures.
Quebec didn't have much choice - you have to put the dams where the water is.
PJM has a choice. Choosing to depend on transmission from remote generation
is imprudent and will create unnecessary risks.

Appendix A: Alternatives to the Lozrdoun Line
This appendix contains some details on alternatives to the Loudoun line that
should have been but were not considered by Dominion/Allegheny and PJM. We
emphasize that this is a partial list. There are many other options, conventional
as well as innovative.
Some of the options listed cannot meet all of the need by themselves. But they
can do so in combination with other options.
*'
'I. More power plants in eastern PJM. PJM and Dominion/Allegheny
carefully ignored this obvious and central option. Thousands of MW of
new power plants are proposed for eastern PJM. If they are not built. it
will be because of failure of the PJM market. In 2006, FERC Chairman
Kelliher said in very strong terms that the PJM market is broken. New
generators, especially in the East, cannot make a sufficient profit to attract
investment. He told PJM to fix the market or else he would.20 PJM is
making efforts to do so and early results are encouraging.2'
We noted above the proposed CPV Warren plant to be built near Meadow
Brook by 2010. The plant reportedly has obtained all needed permits and
has had in place an interconnection agreement with Dominion for several
years. It was put on hold, but in 2006 the developer told Dominion and
PJM that they were going forward with it. Remarkably, however, it is not
in the PJM databases from which PJM and Dominion forecast overloads
and voltage problems.
Also, in July 2007 CPV announced a proposal for another 600 MW gas
fired plant in Charles County, MD, near Washington, DC. According to
CPV, "the new facility will generate enough electricity to power 600,000
homes and use state-of-the-art technology to produce electricity efficientiy
and cleanly to help meet the region's demand for energy.""
2. Dernand-side resources. Energy Information Administration data for 2005
shows that Dominion is ranked 3gth overall in spending on demand-side
management. It spends the least of any company with a similar level of
sales. A serious effort in this area needs to be part of the eastern PJM
energy portfolio. PJM's recent auctions evidence the significant
contribution that demand management can make. A 10% reduction is
Joseph T. Kelliher, Chairman, Fed. Energy Regulatory Comm'n, Statement on PJM
Interconnection, LLC Reliability Pricing Model (Apr. 20, 2006).
21 Press Release, IS0 New England Inc., Competitive wholesale Markets Prove an Effective Tool
for fulfilling Regional Electricity Needs (Mar. 16, 2007) (htt~:/fi,Y\aL"vZ.is~-
ne.comin~\isiss/~ri2.3C;7ifcm soi results 03-16-2907. Wf) (In comparison, New England's recent
initiative called forth more than 17,000 MW of new power plants and demand-side resources.)
22
See http://w. cpv. com/pdf/presreIease7.25.07.

21
3.
4
-
feasible. This would amount to more than 3,500 MW and by Dominion's
numbers would eliminate the need for the Loudoun line. Perhaps 3,500
MW are not feasible by 2011, but in combination with generation options
or less-obtrusive transmission options demand management could still
eliminate completely any need for the Loudoun line.
A 525-MVAR static VAR compensator (SVC) at Meadow Brook. Four
such devices would solve voltage problems in Pennsylvania (two places),
Maryland, and Meadow Brook.23 The first three are in PJM's plan. The
one at Meadow Brook was never mentioned publicly. Installing it would
solve the only real problem used by Dominion to justify the Loudoun line.
It would cost about $35 million, while the Loudoun line would cost more
than $850 million. The device would have a footprint measured in square
feet - its only environmental impact. The impact of the Loudoun line, in
contrast, would be enormous.
The proposed CPV Warren plant to be built near Meadow Brook by 2010
will provide nearly half of the MVARs needed at zero cost if it is connected
to the grid properly, reducing the size and cost of the Meadow Brook SVC.
A phase-angle regulator (PAR) on the fruntytown-Mi. Storm line, A PAR
is a special transformer. PARS increase the impedance of a line, thereby
reducing its flows and increasing flows along other paths. It would direct
some flows away from the Pruntytown-Mt. Storm-Doubs lines onto lines
that are less heavily loaded. It would increase the west-to-east transfer
capability by more than half what the Loudoun line would give. It would
cost about $150 million. Its environmental impact would be limited to its
footprint. PJM has had several in service for many years. They are more
reliable than any thermal power plant.
A PAR could be a useful hedging option. It could provide some increase
in transfer capability while other options (new plants, demand
management, etc.) were being built,
Alternatively, it could be a permanent element of the system, in
combination with other options,
3. The proposed Amos-Bedington-Kemptown 765-kV line. This line would
be much larger than the Loudoun line, which it in essence would parallel.
In July 2006, PJM said that building the Loudoun line in 2011 would solve
all problems in the local region through 2021. By early 2007, PJM said
that, even with the Loudoun line, the 765-kV line is needed to solve
serious problems in the region beginning in 2012. Neither
Dominion/Allegheny nor PJM admits addressing whether the Loudoun line
would still be needed if the 765-kV line were built. We have studied this,
using PJM's data and the same software PJM and Dominion use. The
answer is, "no."
23 PJM and Dominion e-rnails show that they knew this at least as early as May 1, 2006.
Dominion Discovery Response, (Bates No DOM000218.)

22
Appendix B: Dominion 5 Analysis of Generation and Demand
Management Alternatives
KEMA Incorporated evaluated demand-side management (DSM) and generation
options in connection with Dominion's SCC filing.24 This evaluation was not part
of the planning process, but rather was performed after the fact to justify
Dominion's decision to build the Loudoun line.
KEMA's "analysis" of DSM or new generation as alternatives to the Loudoun line
is biased and shallow. KEMA considered only "new northern Virginia
generati~n''~~ and DSM. The power system is regional as are the markets to be
serviced by the proposed Loudoun line, There is no justification for restricting the
alternatives to northern Virginia. The supposed reliability need for the line is
regional.
KEMA admits that DSM could displace the Loudoun line, but goes on to argue
that to do so DSM would require "about a 3,000 MW load reduction" in Northern
Virginia by 2011 .26 The Northern Virginia load growth that supposedly requires
the line is only 465 NIW. KEMA offers no reconciliation of these wildly
inconsistent numbers.
KEMA "analyzed" only two generation alternatives - both destined to fail.
0 Distributed generation. "Our analyses show that nearly 30,000 small new
distributed generators would be needed by 2011 and nearly 80,000 by
2016. . . . The number of new distributed generating units that would be
required . . . is beyond reasonable expe~tation."~~ KEMA is right - a new
technology will not achieve such market penetration so fast. The 80,000
number is especially disingenuous; it refers to what would be needed to
displace other major transmission additions - such as the Amos-
Bedington-Kemptown 765 kV transmission line - needed even if the
Loudoun line is built.
0 New Loudoun substation power plant. According to KEMA: "[Tlh~s would
require a 3,000 MW plant by 2011 - by far the largest plant in Virginia,
and one of the largest in North America . . . . Such a large new plant
would be nearly impossible to license and build by 2011."28 KE MA
ignores that it is distinctly possible to site reasonably sized plants
24KEMA Report pp. 69-70
25 Id. at p. 4
Id. at p. 69 (emphasis added)
27 Id. at pp. 69-70
28 Id. At p. 70

23
summing much more than 3,000 MW in the region to be supplied by the
Loudoun line; such plants have been proposed and are awaiting approvals
by PJM and the local utilities.
Both KEMA generation "options" are obvious non-starters. KEMA says as much;
consequently, they didn't do any analysis. In particular, KEMA did not consider
the thousands of MW of generating plants that are now in the eastern-PJM
interconnection study queues, all of which are real options. KEMA did not look at
other projects that are or were temporarily on hold, such as CPV Warren. They
did not consider other potential generation, conservation, and efficiency options
that will be called forth by PJM's recently reformed capacity market. Neither did
Dominion. Neither did Allegheny. Neither did PJM.

Ronnie
BaileylCOMMOPSNANCPOW
ER
05111112006 01:19 PM
TO
CC
bcc
Subjec!
William BigdelylCOMMOPSNANCPO\PIER@VANCPOWEFI,
Riahard ...-..-.-
LaVignelCOMMOPSNANCP~WE~~VANCPOWER,
Craig CridedCOMMOPSNANCPOWER@VANCPOWER,
Kirit Doshi/COMMOPSNANCPOWER@VANCPO\NER.
-
Nelson BurksiCOMMOPSn/ANCPOWER@VANCPOln(ER
Fw: MidAtlantic 201 I Laad Deliverability Voltage issues
)
1
'
i 1
\
FYI
- Fowarded by Ronnie Bailey/COMMOPSNANCPOWER on 05/0li2006 01:: 9 PM -
To
cc
Subject
------- - - ---..-____
E3ill..Mitcheil@conectiv.com, bawillis@pepco corn,
cbeard@gpu,com, escook@pplweb.com,
monisond@firstenergycorp .corn,
hohlbaughdg@firstenergycorp corn, ESorber@ugi .corn.
esam.khadr@pseg .corn, frank.caroselli@~onec!iv corn,
Glenn.Catenacci@pseg.com, harvey.zwyer@bge .corn,
jayers@pplweh. corn, jim.summers@conectiv.com:
jaradrnari@pepco corn, mdonnefly@peco-energy corn,
Michaei C.Ziegler@bge.com, rhrabah@gpu corn,
mangononr@oru .corn. david.weaver@peco-energy .corn,
segiatz@pplweb. corn, Charles P.Matassa@bge cam,
JSYNER@alleghenypower corn,
CVOGEL2@alleghenyenergy.corn,
Ronnie-Bailey@dom .corn, RMATTlU@alleghenypower corn
mirdih@pjm.com, tesfan@pjmexchOl .pjm. corn,
coodrj@pjmexchOl .pjrn.com, simsm@pjmexch01 pjm.com,
hadgel@pjmexchOl. pjrn.com, kernjon@pjmexcbO; .pjm.com
Mid-Atlantic 201 1 Load Deliverability Vatlage issues
--. --_ - -.- ___-_
"-42
'\
PJM has continued to review the voltage issues identified for the 20 1 1 Mid-Adantic Region Load
deiiverability study PJM has identified the need for the following reactive devices in order to adequately
support imports into the Mid-Atlantjc Region
600 MVAR dynamic reactive device at Airydale 500 kV
400 MVAR dynamic reactive device at Doubs 500 kV
525 MVAR dynamic reactive device at Meadow Brook 500 kV
300 MVAR capacitor at Conemaugh 500 kV
While this is still a significant amount of reactive devices, it is much less than originally expected Nebiat
was able to obtain more imports from New York which backed off the west to east flows Wlth the devices
above, no reactive sceling of TO zonal load is required I realize that we will continue to review alternative
reactive pians for 20 17, powever for now PJM recommends the :@active devices listed above to eliminate
Ip__9__n___l_--__i.)
u
\ the voltage concerns identified for 20 1 1
*II -=h'-%w-r
i.:T-+.*.- -- --- IC_,..-.--
___I___~,__
If anyone has alternative solutions that can be completed by June 202 1, please provide so that PJM can
evaluate
Thanks,
- .--- -
DOM 0002 i 8

Vireinia Electric and Power Company
Case No. PUE-2007-00031
Piedmont Environmental Council
Second Set
The foliowing response to fnterrogukxy Question No. 62 of the First Set of
Interrog;ltories and Requests for Production of Documents of Piedmont Environmental
Council received on May 21,2007 has been prepared under my supervision as it concerns
the PJM R.TEP.
Vice President ofPlaming
PJM htercowection, L,.L.C.
Qucsfion No. 62
a Were my new generating units, and of what capacity, assumed to be built in
Virginia, Mayland, and the Delmarva Peninsula in conducting the 2011,2012, and 20 16
studies?
o, If the answer to subpart (a) is ‘eyes,” then identify those new generating units,
including their assumed Iocation, in-service date, and capacity..
Response:
a
Yes.
b These are the generators not yet in service located in Maryland, Virginia and the
Delrnma Peninsula
Queue
GSl W62
Location
Proiected In- MW Capacitv (C) i
Service Date MW Enerw (?3)
Maryland I 200992 1 640 C
--+
Alt the generators listed above were included in the 2016 basecase. The IUg genemtor
wa5 included in the 201 I, 201.2, and 2016 basecases
DOM 000558

i
Friday,
January 26, 2007
Part II
The President
Executive Order 1342?--Strengthening
Federal Environmental, Energy, and
TranSpQrtatiQn Management

Fpderal Register
T’ol 72 No 17
Presidential Documents
7 I
3919
Friday. January 26. 2007
____
Title 3- Executive Order 13423 of January 24. 2007
The President
Strengthening Federal Environmental, Energy, and Transportation
Management
Bv the authoritv vested in me as President by the Constitution and the
laws of the United States of America, and to strengthen the environmental.
energy, and transportation management of Federal agencies. it is hereby
ordered as follows:
Section 1. Policy. It is the policy of the LJnited States that Federal agencies
conduct their environmental, transportation, and energy-related activities
under the law in support of their respective missions in an environmentally.
economicallv and fiscally sound. integrated, continuously improving, efficient,
and sustainable manner.
Sec. 2. Goals for Agencies. In implementing the policy set forth in section
1 of this order, the head of each agency shall:
(a) improve energy efficiency and reduce greenhouse gas emissions of the
agency, through reduction of energy intensity by (i) 3 percent annuall?
through the end of fiscal year 2015, or (ii) 30 percent by the end of fiscal
year 2015, relative to the baseline of the agency’s energv use in fiscal
year 2003;
(b) ensure that (i) at least half of the statutorily required renewable energy
consumed by the agency in a fiscal year comes from new renewable sources.
and (ii) to the extent feasible, the agency implements renewable energy
generation projects on agency propertv for agency use;
(cl beginning in FY 2008, reduce water consumption intensitv, relative to
the baseline of the agency’s water consumption in fiscal year 2007, through
life-cycle cost-effective measures by 2 percent annuall? through the end
of fiscal year 2015 or 16 percent by the end of fiscal year 2015;
(d) require in agency acquisitions of goods and services (i) use of sustainable
environmental practices, including acquisition of biobased. environmentally
preferable, energy-efficient, water-efficient, and recvcled-content products,
and (ii) use of paper of at least 30 percent post-consumer fiber content;
(el ensure that the agency (i) reduces the quantity of toxic and hazardous
chemicals and materials acquired, used, or disposed of by the agency, (ii)
increases diversion of solid waste as appropriate, and (iii) maintains costeffective
waste prevention and recycling programs in its facilities;
(f) ensure that (i) new construction and major renovation of agency ‘buildings
comply with the Guiding Principles for Federal Leadership in High Performance
and Sustainable Buildings set forth in the Federal Leadership in High
Performance and Sustainable Buildings Memorandum of Understanding
/2006), and (ii) 15 percent of the existing Federal capital asset building
inventorv of the agency as of the end of fiscal year 2015 incorporates
the sustainable practices in the Guiding Principles;
(gj ensure that, if the agency operates a fleet of at least 20 motor vehicles,
the agency, relative to agency baselines for fiscal year 2005, (i) reduces
the fleet’s total consumption of petroleum products by 2 percent annually
through the end of fiscal year 2015, (ii) increases the total fuel consumption
that is non-petroleum-based by 10 percent annually. and (iii) uses plugin
hybrid (PTH) vehicles when PIH vehicles are commercially available at

3920 Federal Register/ Vol. 72, No. 17 /Friday, January 26, 2007/Presidential Documents
a cost reasonably comparable, on the basis of life-cycle cost, to non-PM
vehicles; and
(h) ensure that the agency (i) when acquiring an electronic product to
meet its requirements, meets at least 95 percent of those requirements with
an Electronic Product Environmental Assessment Tool (EPEATj-registered
electronic product, unless there is no EPEAT standard for such product,
(ii) enables the Energy Star feature on agency computers and monitors,
(iii) establishes and implements policies to extend the useful life of agency
electronic equipment, and (iv) uses environmentally sound practices with
respect to disposition of agency electronic equipment that has reached the
end of its useful life.
Sec. 3. Duties of Heads of Agencies. In implementing the policy set forth
in section 1 of this order, the head of each agency shall:
(a) implement within the agency sustainable practices for (i) energy efficiency,
greenhouse gas emissions avoidance or reduction, and petroleum products
use reduction, (ii) renewable energy, including bioenergy, (iii) water conservation,
(iv) acquisition, (v) pollution and waste prevention and recycling,
(vi) reduction or elimination of acquisition and use of toxic or hazardous
chemicals, (vii) high performance construction, lease, operation, and niaintenance
of buildings, (viii) vehicle fleet management, and (ix) electronic equipment
management;
(b) implement within the agency environmental management systems (EMS)
at all appropriate organizational levels to ensure (i) use of EMS as the
primary management approach for addressing environmental aspects of internal
agency operations and activities, including environmental aspects of
energy and transportation functions, (ii) establishment of agency objectives
and targets to ensure implementation of this order, and (iii) collection,
analysis, and reporting of information to measure performance in the implementation
of this order;
(c) establish within the agency programs for (il environmental management
training, lii) environmental compliance review and audit, and (iii) leadership
awards to recognize outstanding environmental, energy, or transportation
management performance in the agency:
(d) within 30 days after the date of this order (i) designate a senior civilian
officer of the United States, compensated annually in an amount at or
above the amount payable at level IV of the Executive Schedule, to be
responsible for implementation of this order within the agency, (ii) report
such designation to the Director of the Office of Management and Budget
and the Chairman of the Council on Environmental Quality, and (iii) assign
the designated official the authority and duty to (A) monitor and report
to the head of the agency on agency activities to carry out subsections
(a) and (b) of this section, and (B) perform such other duties relating to
the implementation of this order within the agency as the head of the
agency deems appropriate;
(e) ensure that contracts entered into after the date of this order for contractor
operation of government-owned facilities or vehicles require the contractor
to comply with the provisions of this order with respect to such facilities
or vehicles to the same extent as the agency would be required to comply
if the agency operated the facilities or vehicles;
(f) ensure that agreements, permits, leases, licenses, or other legally-binding
obligations between the agency and a tenant or concessionaire entered into
after the date of this order require, to the extent the head of the agency
determines appropriate, that the tenant or concessionaire take actions relating
to matters within the scope of the contract that facilitate the agency's compliance
with this order;
(g) provide reports on agency implementation of this order to the Chairman
of the Council on such schedule and in such format as the Chairman
of the Council may require; and

Federal Register/ Vol. 72, No. 17 / Fridav, Tanuarv 26. 2007 ,’ Presidential Documents 3921
(h) provide information and assistance to the Director of the Office of Management
and Budget, the Chairman of the Council, and the Federal Environmental
Executive.
Sec. 4. Additional Duties of the Chairmnn of the Council on Environmpntd
Quality. In implementing the policy set forth in section 1 of this order.
the Chairman of the Council on Environmental Quality
(a) (i) shall establish a Steering Committee on Strengthening Federal Environmental,
Energy, and Transportation Management to advise the Director of
the Office of Management and Budget and the Chairman of the Council
on the performance of their functions under this order that shall consist
exclusively of (A) the Federal Environmental Executive, who shall chair.
convene and preside at meetings of, determine the agenda of. and direct
the work of, the Steering Committee, and (B) the senior officials designated
under section 3(d)(i) of this order, and (ii) may establish subcommittees
of the Steering Committee, to assist the Steering Committee in developing
the advice of the Steering Committee on particular subjects;
(b) may, after consultation with the Director of the Office of Management
and Budget and the Steering Committee, issue instructions to implement
this order, other than instructions within the authority of the Director to
issue under section 5 of this order: and
(c) shall administer a presidential leadership award program to recognize
exceptional and outstanding environmental, energy. or transportation management
performance and excellence in agency efforts to implement this
order.
Sec. 5. Duties of the Director of the Office of iMonogemenf nnd Budget.
In implementing the policy set forth in section 1 of this order, the Director
of the Office of Management and Budget shall. after consultation with the
Chairman of the Council and the Steering Committee, issue instructions
to the heads of agencies concerning:
(a) periodic evaluation of agency implementation of this order;
(b) budget and appropriations matters relating to implementation of this
order:
(cl implementation of section 2(d) of this order; and
(d) amendments of the Federal Acquisition Regulation as necessary to implement
this order.
Sec. 6. Duties of the Federal Environmental Executive. A Federal Environmental
Executive designated by the President shall head the Office of the
Federal Environmental Executive, which shall be maintained in the Environmental
Protection Agency for funding and administrative purposes. In implementing
the policy set forth in section 1 of this order, the Federal Env’ (ironmental
Executive shall:
(a) monitor, and advise the Chairman of the Council on, perforniance by
agencies of functions assigned by sections 2 and 3 of this order;
(b) submit a report to the President. through the Chairman of the Council.
not less often than once every 2 years, on the activities of agencies to
implement this order; and
(c) advise the Chairman of the Council on the Chairman’s exercise of authority
granted by subsection 4(c) of this order.
Sec. 7. Limitations. (a) This order shall apply to an agencv with respect
to the activities, personnel, resources, and facilities of the agency that are
located within the United States. The head of an agencv may provide that
this order shall apply in whole or in part with respect to the activities,
personnel, resources, and facilities of the agency that are not located within
the United States, if the head of the agencv determines that such application
is in the interest of the United States.

3922 Federal Register / Vol. 72, No. 17 / Friday, January 26, 2007 / Presidential Documents
(b) The head of an agency shall manage activities, personnel, resources.
and facilities of the agency that are not located within the United States:
and with respect to which the head of the agency has not made a determination
under subsection (a) of this section, in a manner consistent with the
policy set forth in section 1 of this order to the extent the head of the
agency determines practicable.
Sec. 8, Exemption Anthorify. (a) The Director of National Intelligence may
exempt an intelligence activity of the United States, and related personnel,
resources, and facilities, from the provisions of this order, other than this
subsection and section 10, to the extent the Director determines necessary
to protect intelligence sources and methods from unauthorized disclosure.
(b) The head of an agency may exempt law enforcement activities of that
agency, and related personnel, resources, and facilities, from the provisions
of this order, other than this subsection and section 10, to the extent the
head of an agency determines necessary to protect undercover operations
from unauthorized disclosure.
(c) (i) The head of an agency may exempt law enforcement, protective,
emergency response, or military tactical vehicle fleets of that agency from
the provisions of this order, other than this subsection and section 10.
(ii) Heads of agencies shall manage fleets to which paragraph (i) of this
subsection refers in a manner consistent with the policy set forth in section
1 of this order to the extent they determine practicable.
(d) The head of an agency may submit to the President, through the Chairman
of the Council, a request for an exemption of an agency activity, and related
personnel, resources, and facilities, from this order.
Sec. 9. Definitions. As used in this order:
(a) “agency” means an executive agency as defined in section 105 of title
5, United States Code, excluding the Government Accountability Office;
(b) “Chairman of the Council” means the Chairman of the Council on
Environmental Quality, including in the Chairman’s capacity as Director
of the Office of Environmental Quality;
(c) “Council” means the Council on Environmental Quality;
(d) “environmental” means environmental aspects of internal agency operations
and activities, including those environmental aspects related to energy
and transportation functions;
(e) “greenhouse gases” means carbon dioxide, methane, nitrous oxide,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride;
(f) “life-cycle cost-effective” means the life-cycle costs of a product, project,
or measure are estimated to be equal to or less than the base case (i.e.,
current or standard practice or product):
(8) “new renewable sources” means sources of renewable energy placed
into service after January 1,1999;
(h) “renewable energy” means energy produced by solar, wind, biomass,
landfill gas, ocean (including tidal, wave, current and thermal), geothermal,
municipal solid waste, or new hydroelectric generation capacity achieved
from increased efficiency or additions of new capacity at an existing hydroelectric
project;
(i) “energy intensity” means energy consumption per square foot of building
space, including industrial or laboratory facilities;
(j) “Steering Committee” means the Steering Committee on Strengthening
Federal Environmental, Energy, and Transportation Management established
under subsection 4(b) of this order;
(k) “sustainable” means to create and maintain conditions. under which
humans and nature can exist in productive harmony, that permit fulfilling

Federal Register IVoL 72, No. 17 /Friday, January 26, 2007 /Presidential Documents 3923
the social, economic? and other requirements of present and future generations
of Americans: and
(1) “United States” when used in a geographical sense, means the fifty
states, the District of Columbia, the Commonwealth of Puerto Rico, Guam.
American Samoa, the United States Virgin Islands, and the Northern Mariana
Islands, and associated territorial waters and airspace.
Sec. 10. General Provisions. (a) This order shall be imDlemented in a manner
consistent with applicable law and subject to the availability of appropriations.
(b) Nothing in this order shall be construed to impair or otherwise affect
the functions of the Director of the Office of Management and Budget relating
to budget. administrative, or legislative proposals.
(e) This order is intended onlv to improve the internal management of
the Federal Government and is not intended to, and does not, create any
right or benefit, substantive or procedural. enforceable at law or in equity
by a party against the United States, its departments, agencies. instrunientalities,
entities, officers, employees or agents, or any other person.
Sec. 11. Revocations; Confarming Provisions. (a) The following are revoked:
(i) Executive Order 13101 of September 14, 1998;
(ii) Executive Order 13123 of June 3,1999;
(iii) Executive Order 13134 of August 12,1999, as amended:
(iv) Executive Order 13148 of April 21, 2000; and
(v) Executive Order 13149 of April 21, 2000.
(b) In light of subsection 317(e) of the National Defense Authorization Act
for Fiscal Year 2002 (Public Law 107-107): not later than January 1 of
each year through and including 2010, the Secretary of Defense shall submit
to the Senate and the House of Representatives a report regarding progress
made toward achieving the energy efficiency goals of the Department of
Defense.
(cl Section 3(b)(vi) of Executive Order 13327 of February 4. 2004, is amended
by striking “Executive Order 13148 of April 21, 2000’’ and inserting in
lieu thereof “other executive orders”.
THE lVHITE HOUSE,
Junuary 24, 2007.

il ...:"#(;R,3,yn!.,!:\

1. Introduction
The Federal government has made si,Onificant progress in improi,ing em-ironmental and
energy performance through a series of executive orders, Memoranda of Understanding.
and other guidance. Executive Order 13423 (E.O.), Smngilieizing Federal
Environmental. Energ).: and Tr’msportntion Marnagemem. intends to build on that bod!.
of work and success by integrating and updating prior practices and requirements into a
cohesiye, strategic approach to further ensure enhanced performance and compliance
with statutory and other legal requirements.
Section 2 of the E.O. directs Federal agencies to implement sustainable practices for:
e
0
0
e
e
e
0
0
e
0
Energy efficiency and reductions in greenhouse gas emissions.
Use of renewable ener5.
Reduction in n-ater consumption intensit\..
Acquisition of green products and services.
Pollution prei-ention, including reduction or elimination of the use of tosic and
hazardous chemicals and materials.
Cost-effective waste prevention and recycling programs.
Increased diversion of solid waste.
Sustainable desi,onkigh performance bwldings.
Vehicle fleet management, including the use of alternative fuel vehicles and
alternative fuels and the further reduction of petroleum consumption.
Electronics stewardship.
A. Purpose
The purpose of this document is to define agency requirements for implementing E.0
13423 and to define broad strategies for achieving them. This document is the first of
such E.O. implementing instructions. In order to ensure effectiye and efficient
implementation, and to meet the goals and objectives of the E.O.. it is mandato? that
executive departments and agencies implement the activities described in these
instructions in accordance with Sections 1: 2, 3, and 4(b) of the E.O.
B. Authority
These instmctions are issued under the authority of Section 4(b) of the E.O. This section
authorizes the Chairman of the Council on Environmental Qualit\. (CEQ) to issue
instructions on implementing the E.O. after consultation nith the Director of the Office
of Management and Budget (OMB) and the interagency Steering Committee.
@. Organization and Oversipht
The organizational structure of the entities established to coordinate and o\-ersee
implementation of E.O. 13423 is shown in Figure 1. The organizational structure as well
as the roles and responsibilities of each entih are described below.
1

Figure 1. Organization of entities established to implement E.O. 13423. The agency
chair of each Worhng Group is shonn in parentheses.
(1) SteerinP Committee. In accordance with the E.O., agencies ivill designate
Senior Officials, xho will comprise the Steering Committee. The Steering Committee
\vi11 be responsible and accountable for implementation of the E.O. and these
instructions. Semiannual meetings will be held, usually in Februan and August.
Additional meetings of the Steering Committee may be called by the Federal
Ensironmental Executive (FEE), as appropriate.
(2') E.O. Ad\-isory Group. This group shall consist of Office of the Federal
Enyironmental Esecutive (OFEE), OMB, Department of Energy (DOE), and
Enyironmental Protection Agency (EPA) staff and others as appropriate as determined by
the Chairman of CEQ. The Advisory Group will support the Steering Committee by
scheduling meetings, providing logstical support, coordinating approyal of guidance
documents, conducting assessments of agency implementation, and ensuring cooperation
and coordination between workgroups. The Advisory Group shall coordinate reporting
2

V. Training
E 0 13423. sec 3(c), excespted In implemennng rhe pol’~cj~ ser forth In secrm I
ofthis order the liead qf each agency shall.
Establish w rrhn rhe agency program for (I) environmental mnmgernent
training
A. Reauired Training
Each agent!' shall ensure that all personnel n.hose actions are affected b) the E.O. recei1 e
initial awareness trainin,o as well as necessary refresher training on the goals of the E 0
and any related instructions. including the environmental impacts of the employees‘
actions.
The interagency a.orkgroups shall discuss training needs and del-elop guidance on
training. as appropriate.
B. Scone and Sources
Each agency shall provide environmental management training to its employees. Each
agency shall identifc. the specific training needs of individual emplo),ees, u-hich shall be a
function of operations and responsibilities related to the EO. goals and other legal
requirements. The training shall address the role of indiyidual employees in ensuring the
asency pursues the policy, goals, and objectives set forth in the E.O. and emphasize the
benefit of improved environmental: enera: and transportation management to the
mission of the organization. Training shall be provided to employees and others, such as
contractors. as appropriate, at all le\-els: and repeated as necessan to ensure improl-ed
awareness.
Training can be, but is not limited to, agency-developed training, training proi;ided by a
third pam such as a contractor or non-profit organization. trainins provided by another
agency. Defense Acquisition University or Federal Acquisition Institute courses. or
educational sessions provided during relevant conferences such as the annual Federal
environmental symposium, annual GSA Expo, DoD‘s annual Joint Services
Eni;ironmental Management conference, FedFleet, or the annual EnerE conference.
11

VI. Energy and Water Management
__..._ ~. .-".*TI.- --,.,.. '
"--'I -,--..-. __,,
,. ~
. .,
,&Oxsec. 2(cQ. 0). and (c): In implementing rhe policy set forth in section .
-I-. __. .-.-.
I I of this order, the head qf'ench agency shall:
i
I (0) improve energy efficiency and reduce greenhouse gas emissions ofthe agency,
j through reduction of energy inrensitl, by (i) 3 percent annually rhrotigh the end of :,
1 FY 2015. or (ii) 30percent by the end of FY 2015, relative to the baseline ofthe
i 1 ngencjs 's energy use in FY 2003; 1
i 1 ensure that (zj at least ha(f of the statutorily required renewable energtl
1 i slimed by the ngency in a$scal year comes@om nau renewable sources,
i
L
baseline qf the agency 3 water consumption in FY 2007, through l@-cycle costeflecrive
measures by 2percent annualiy through the endofFY 2015 or 16
percent by the end of FY 201 5.
Sec. 3(a). excerpt: In implementing the policy set.forth in section I of this order,
the head qfeach agency shall:
(n) implement within the agency sustainable pracricesLfor (i) energy eflcienqy
geenhowe emissions avoidance or reduction, and petroleum products use
reduction. (ii) renewable energy, including bioenera:, (iii) water conservation ... .
Technicnl Lead: DOE
Workgroup: Interagency Energy Management Task Force
A. Strategies and Tools
Each agency shall use a va.rieQ- of energy and tvater management strategies and tools to
meet the goals of the order. Strategies and tools include, but are not limited to, the
folloning .
(1 ) Funding. The following instruments should be utilized to the maximum extent
practical to implement energy efficiency management projects, water management
projects, and renewable energy projects with energy conservation measures (ECMs)
ha\:ing long- and short-term payback periods that can be incorporated into life-cycle cost
effective contracts. Appropriated funds may be combined with Energy Savings
Performance Contracts (ESPCs) and Utility Energy Service Contracts (UESCs) to
leverage government funding and optimize project scope and reductions in energ?. use
and cost of facility operations. Renewable energy measures shall be considered in each
ESPC or UESC proposal and be implemented where practical.
ESPCs. ESPCs can facilitate and accelerate completion of large projects that can
incorporate ECMs Fvith long- and short-term payback periods. through life-cycle
cost-effective performance contracts.
12

74
I;ESCs. UESCs enable projects in States where the utility companies are
permitted and encouraged to perform energy savings sen ices, especially in peak
load constrained regions of the country.
Direct Appropriated Funding. Appropriations should be requested in annual
budget requests and priontized for application in projects or measures that do not
generate savings sufficient to support private sector financing or for application as
cost share to ESPCdUESCs so that larger, more comprehensive projects can be
undertaken..
Enhanced Use Leasing. This tool can be utilized for large or long-term
renem-able and cogeneration projects and where appropriate and authorized.
Ratepayer Incentives. Incentives such as ratepa>.er supported rebates from
public benefit funds or utilities should be utilized at every opportuniv to enhance
energy reduction.
Retention of Funds. Retention of unused appropriated funds directly related to
energy and water cost savings by all agencies can be used for reinyestment in
energ) or nater consen-ation and sustainable building requirements.
.- 3UI.I.I\-~,.._L_W.IW1_I --.,
,_..._yi
'"*
(2) Distributed Generation. Where life-cTcle cost effective: each agenq shall
'%*.
implement distributed generation systems in new construction or retrofit projects.
/' including reneu-able systems such as solar electric, solar lighting: geo (or ground
i coupled) thermal, small wind turbines, as well as other seneration systems such as fuel :
!%, cell, cogeneration. or highly efficient alternatives. In addition, agencies are encouraged /i
':~ to use distributed generation systems when a substantial contnbution is made toumd ,I'
',.; enhancing energy reliability or secunty.
1 ,- ...,
Fe,.*;'+@"-3s%&
(3) Metering. To the maximum extent practicable, agencies should install
metering devices that measure consumption of potable water: electricity, and thermal
enerp in Federal buildings and other facilities and grounds. Data collected shall be
incorporated into Federal tracking systems and be made available to Federal faciliomanagers.
Agencies should consider inclusion of metering requirements in all ESPCs and
UESCs, as appropriate.
(4) Auditing Agencies should conduct energy and nater audits of at least 10
percent of facility square footage annuall? and conduct ne& audits at least e\ ec 10 \ ears.
thereafter This audit requirement can be met by audits done in conjunction nith ESPC
or UESC projects
(5) Ener.q. Star:Q Tools. For applicable facilities, agencies should meet Energ.
StarE: Building critena, and score the energ performance of buildings using the Enerq. u-
Starg Portfolio Manager rating tool as part of comprehensive facility audits. Agencies
ma!. use the Energ Star Portfolio Manager rating tool to track energy and water use in
all facilities.
(6) Labs21, Agencies should explore efficiency opportunities in applicable
facilities and programs such as the Labs21 partnership to encourage the development of
sustainable, high performance, and loi+--enera laboratories nationmide.
.__
--,
'....
'. +
13

(7) Energy Purchasing. Agencies should purchase electncity and thermal energy
from sources that use high efficienq- and low-carbon generating technologies in order to
reduce greenhouse gas intensity to the extent possible.
(8) Water Efficient Products. Where applicable, agencies should purchase
Watersense (SM) labeled products and choose irrigation contractors u.ho are certified
through a Watersense labeled program.2
B. Exclusions
The goals set forth in section 2(a) and 2(b) of E.O. 13423 are subject to the exclusions set
forth in Section 102(c), (d), and (e) of EPAct 2005 and the DOE Guidelines Establishing
Criteria for Excluding Buildings from the Energy Performance Requirements of Section
533 of the National Energ. Conservation Poli? Act, as amended by EPAct 2005, issued
on January 27.2006.
C. Additional Guidance
(1) Enera- efficiencv. Within 90 days of issuance of these instructions, DOE, in
consultation with the Interagency Energy Management Task Force, shall issue or update
guidance on:
0 Long term planning and strategies for achieving energy goals.
e The rene1vable energ goal and use of renewable energy credlts.
0 Use of alternatively financed projects such as ESPCs and UESCs
0 Use of and investment in renewable energy generation.
0 Calculating and validating fkds available for retention in accordance \.\ ith
Section 102(f) of EPAct 2005.
DOE guidance should clarie that each agency shall begin reporting performance toward
the reduction goal for FY 2007. which for that year requires a 6 percent reduction,
relative to the FY 2003 baseline, in order to be considered on track to meet 30 percent
reduction goal in 2015.
(2) Life-c\xle costs. Guidance on measuring life-cycle costs IS prowded in 10
CFR 336. Subpart A. Additional gidance on measuring cost-effectik eness is provided in
10 CFR 436.1S(a), (b), and (c), 434.20, and 434.21.
(3) Water consenation. By September 30,2007. DOE. in coordination with EPA,
shall issue guidance with respect to a 2007 baseline for potable, landscape. and other
jvater consumption intensih and meeting the water conservation goal of Section 2(c) of
the EO.
EPA‘s WaterSense program is a voluntary public-private partnership that identifies and promotes hghperformance
products and programs that help preserve the nation-s water supply. More information can be
found at “~~~:,e~.~.e.
14

The Transmission system was buil? over the past 1 QG years bv verticaliv integra:&
uriiriies
that produced and transmitted elect,rici?y localiy. Srnaii i!mco:lnections betweefi neighboring
utilities existed, but they were crea?ed to increase reiiabiiity and share excess generarion. Over
the past 10 years! ive have introdi;ced corngetition into iljhoi@s& electricity inarketj tc ioi;fe:
cosis to consumers by spiirrina needed investments in generation and increasing the ef.:iciei?cY
of operatms. Today, our transmission s!:stem acts as an imrmte highlay system for whcksale
e! W.:i
c
< lt\i C~IV in e rce .
- y___.-a-.mi^. -,,~,.
..... ,. . ,
There is growing evidence that the U.5. transmission system is in I;rgeiit need of noderniza-
----.---CI~r.".~--.~,"-.-----
tioii. The system has become csng~sted tecause growth ic electricity demand a
--u 7.
io new generation faciiities have nor been matched by irivemien: in new transrrticsion faciiiriei.
Transmission ~foblems have been compounded by the incomplete transition io fair arrd effl:;ent
competitive whdesaie electricity markets, Because the existing crammission system was not
designed :o meet present demand, daily traixmission consmints or "battlenecks'. increase eiec-
uicq costs to co~sumcrs and increase th? risk of blacknu?s.
Eliminating transmission csnstraints or boxienecks is ejjenrial ti; ensuring reliable and
affordable eiectricity now and ig the Future. 'The Depamrnt of Energy (DOE) c~?nduct:i! an inde
pendent assessment of the U.S. electricity transmiSsion system and found that:
* Qur $.S. transmission system facilirates h iejde eiectxity markets that lower ionsurners'
electricity bills ky. nezrly $1 3 billion annuail)).

PjM, New York, and New England) aione couid save consumers about $500 miliio~ annu-
ally. Savings could be even greater because DOE’S analysis does nor capture ail of the
----
factors, such as impacts on teiiability, that result from bottlenecks.
_-- -\
mission technologies and improved operating practices, 12,.,
siting generation closer to areas where electricity is needed, and reducing electricity use
through targeted energy efficiency and distributed generation could all help reduce
transmission congestion.
@ Better utilizing existing facilities can help delay the need for new transmission facilities,
cannot avoid construction of new transmission facilities entirely.
---7--
’
Much work is needed to address transmission bottlenecks and modernize our nation’s
transmission systems. As a percentage of total energy use, electricity use is growing.2 This
reflects the transformation of our economy to an increasingly sophisticated, information-based
economy, one that relies on electricity. Electricity, though, is not a commodity that can be
stored easily. Our transmission infrastructure is at the heart of our economic well-being.
Imagine an interstate highway system without storage depots or warehouses, where traffic
congestion would mean not just a loss of time in delivering a commodity, but a loss of the
commodity itself. This is the nature of the transmission infrastructure. That is why bottlenecks
are so important to remove and why an efficient transmission infrastructure is so important to
maintain and develop.
This report outlines 51 recommendations that will help ensure a robust and reliable trans-
mission grid for the 21 st century. The following are six general recommendations:
0 First, we must increase regulatory certainty by completing the transition to competitive
regional wholesale markets.
% Second, we need to develop a process for identifying and addressing national-interest
transmission bottlenecks.
*,>
‘xi,+,
i
. . . . . . . . . . . . . . . . . , , . , . . . . . . . . . . , , , , . . . . . . . . . . . . . .
‘In 1970, eiectricity accounted for 8 percent of totai US. energy use. In 2000, electricity accounted for
16 percent of total US. energy use. Source: Energy Information Administration. Annual Energy Outlook 2002.
Download from http://w.eia.doe.gov

mission system operations and fully utilizing our existing facilities. Regional planning
processes must consider transmission and non.transmlsslon alternatives when trying to
e Fourth, opportunities for customers to reduce their electricity demands voluntarily, and
targeted energy-efficiency and distributed generation, should be coordinated within
regional markets.
Fifth, ensuring mandatory compliance with reliability rules must include enforceable penal
ties for non-comrsliance that are commensurate with the risks that the violations create.
88 Sixth, DOE will take an increased leadership role in transmission R&D and policy by creat
ing a new Office of Electricity Transmission and Distribution.
Action is needed now to put this study’s recommendations in place. Private industry and federal,
state, and local governments must work together to ensure that our electricity transmission
system will meet the nation’s needs for reliable and affordable electricity in the 2lst century,

Department of Defense
Fiscal Year 2007
Energy Management
Implementation Plan
USD (AT&L)
January 2007
Deparmwnt of Defense
1

Deportment ofDefense
FI* 2007 Energy A4anagernent Implementation Plan
Table of Contents
I. INTRODUCTION ......... ........................................ ............................................... 3
11. MANAGEMENT AND IN1 STFMTION ...............
A. Energy Management Infrastructure ................... .......................................................... 5
1. Senior Agency Official ....................................
2. Ageno- Enere Team ......................................
B. Management Tools ...........................
1, Atyards (Employee Incentive
1. Performance Evaluations .......
2. Training and Education ...............
3. Shon'case Facilities.. ..............
111. Implement at i on Strategies ........ ................................. ........................... 16
A. Life-Cycle Cost Analysis (LCC
................................................ 17
B. Facilie Energy Audits ....................................................
........................... 19
C. Financing Mechanisms .............
D. Energ.-StarE' and Energy -Effi
E. ENERGY STAR' Buildings ..... ................................................
F. Sustainable Building Design ...
G. Energy Efficiency in Lease Provisions ..........................
.............................. 30
H. Industrial Facility Efficiency Improvements ................
........................ 31
I. Highly Efficient S!-stems .........................................
...........................
11
33
J.
K.
M
Distributed Generation.. ..
Electrical Load Reduction Measures ...................
Water Conservation .....
...................................... 35
2

I. INTRODUCTION
The Department of Defense (DoD) is comrmtted to achiei ing the energ reduction goals set forth
in the Energy Polic? Act of 2005 (EPAct 2005) and Executir e Order (EO) 13123. "Greening the
Go! emment through Efficient Energ Management" In accordance nith the EO 13 123. all
Federal agencies prepare an Annual Implementation Plan that outlines specific plans to make
progress ton ard those goals This document represents the DoD Implementatlon Plan for Fiscal
Year (FY) 2007
This implementation plan proyides a detailed account of the strategic approaches that will be
employed department-\side. It ivas developed using plans submttted by each of the Defense
Components. The organization of thls document follo\vs that of the Annual Energ, Management
Repon.
This introduction sen es to demonstrate DoD's understanding of EPAct 2005 and EO 13123
requirements and to smrnanze the department's integrated approach to ach1e.c e the goals The
remainder of the document consists of tu0 chapters Section 11 pro7 ides details concerning the
department's energq management and admnistratij e structure Section I11 presents the
department's specific FY 2007 implementation strategies. planned projects. and goals
Federal Facilities Energ? Program Goals are summarized below:
Green House Gas
Enere Efficient!.
Bui1din.g Metering
30 percent reduction by 2010 from 1990 (EO)
Standard Buildings - 35 percent Btuift'reduction by 2010 from 1985 (EO)
Industrial Buildings - 25 percent BhY'ft' reduction by 2010 from 1990 (EO)
All Buildings - 20 percent Btdft' reduction by 2015 from 2003 (EPAct)
Excluded Buildings - no goal, but ener.g use must be reported (EPAct)
Faciliq Audits - 10 percentiyear (can count alt financing) (EO)
Appl!. Sustainable Principles - (EO and EPAct)
Model Lease Provisions Supporting Sustainable Design - (EO)
Nerv Buildings LCCE - energ. usage 30 percent below ASHRAE (EPAct)
Meter all buildings by 2012 to the extent maximum practicable (EPAct)
EnerD Efficient Products
Include the procurement of Energy Star and DOE designated equipment in
all contracts n-herever possible (EPAct)
Renew able Enerv
Install 200.000 solar energ systems by 201 0 (EO)
Obtm 3 percent of electric enere from renen able 2007-2009 (EPAct)
Obtain 5 percent of electnc energ from renenable 201 0-201 2 (EPAct)
Obtain 7 5 percent of electric energ. from renenable after 201 3 (EPAct )
~- ~-
Deparhiietit of Defense 3

Deparfment of Defensr
FI' 2007 Enera, Aianagement bnplementation Plan
Petroleum
Source Ener.0
Financing
Training and
Education
Reduce usage (EO)
Reduce Usage (EO)
Accomplish ail projects that are life cycle cost effective (EO)
Assure that all appropriate personnel receive training (EO)
Designate exemplary new and existing facilities as energ?: and renem able
showcases (EO)
Water Conservation Implement Best Management Practices
- 30 percent of facilities by 2006 (EO)
- 50 percent of facilities by 2008 (EO)
- 80 percent of facilities by 2010 (EO)
Vehicles
Federal alternative fueled vehicles must Use alternative fuels (EPAct)
EO - Executive Order 1323
EPAct - Energy Policy Act ofAugust 8, 2005, Public Lnw 109-18
Energ. conservation is a high priority for the Department. Reduction in energy consumption can
create substantial dollar savings and reduce greenhouse gas emissions. DoD intends to meet the
gods of this order b!- implementing the folloning broad strategies:
0 Implement cost-effecti1.e energy conservation projects ivith direct appropriations and
alternative financing through Utili$)- Energ Service Contracts (UESG) and Enera Savings
Performance Contracts (ESPC), and by procuring energ-efficient products and senices.
0 Implement water consenation best management practices to achieve water efficiency.
4 Promote renenable eners technology by purchasing renewable power and implementing
renenable energy projects when cost-effective based on life-cycle analysis.
D~pari~eiit of Defense 4

_ .I._.
Back to the previous pa
....................
News from Inside the Pentagon
provided by the InsideDefense NewsStand
DSB task force report wrapping up
VULNERABLE ELECTRIC GRID PROMPTS CALL FOR ENERGY-
INDEPENDENT BASES
Dat?: Siaq’ 31.2007
An influential advisory panel to Defense Secretary Robert Gates will soon recommend the Pentagon
protect critical domestic military installations by making them energy independent, a move intended to
wean the U.S. military from America’s electrical grid which the panel believes is vulnerable to tenorist
attack and natural disaster.
James Schlesinger, a former defense and energy secretary, is concluding a yearlong Defense Science
Board task force he is leading that proposes the Pentagon prepare for failures of the electrical grid -- on
which U. S. facilities heavily rely -- by “islanding,” a concept that envisions installations generatins their
own power, according to sources familiar with the report.
“The grid is fragile,” said one source familiar with the panel’s deliberations. “So there was some
concern in the task force about DOD’s ability to operate in the event of a grid failure for an extended
period of time.”
In iZugust 2003, a massive blackout hit huge swaths of the Northeast, Midwest and Ontario, Canada.
affecting tens of millions of people. This power outage was traced, in part, to overgown trees in Ohio
that touched high-voltage electrical lines, setting in motion sequential blackouts that eventually knocked
more than 100 power plants offline
Susceptibility to deliberate attack is also a concern.
”They had a variety of scenarios that they were very concerned about,” said the source, who declined to
discuss any of the particular scenarios.
The panel -- which Pentagon acquisition executive Kenneth Krieg commissioned to examine a wide
range of issues, including “opportunities for DOD to produce energy for its own use” -- will recommend
that domestic bases shift from the electric grid to renewable energy sources such as wind and solar
energy and possibly by small-scale nuclear power plants, the sources said.
The “Task Force on DOD Energy Strategy” is also set to recommend the Defense Department establish
a senior executive responsible for energy leadership, although it is expected to stop short of calling for
an “energy czar.” as some members of the task force had proposed.
On the issue of carbon-based fuels, the DSB is not expected to advance any far-reaching
recommendations. The panel is expected to endorse many steps the Defense Department has taken over
the last year to bring greater attention to energy efficiency both at facilities and across its fleet of
weapon systems.
Last month, Krieg established a pilot program that requires three next-generation weapon system
programs to consider energy efficiency as a key part of their designs, a significant step that could pave
the way for economic fuel consumption to play a prominent role in planning for future U.S. combat
capabilities.

The InsideDefense Newsstand Page 2 of 2
-‘Effective immediately, it is DOD policy to include the fully burdened cost of delivered energy in tradeoff
analyses conducted for all tactical systems with end items that create a demand for energy and to
improve the energy efficiency of those systems, consistent with missions and requirements and cost
effectiveness,” Kneg wrote in an April 10 memo.
The three programs tapped for this project are the Air Force’s future long-range strike aircraft, the Army
and Marine Corps Joint Light Tactical Vehicle and the Navy’s next-generation cruiser, CG(X).
The DSB is also expected to endorse a number of other recommendations of an internal Defense
Department Energy Security Task Force which last September produced what oficials involved in the
effort say is a comprehensive roadmap to platform efficiency, establishing alternative fuels programs
and accelerating initiatives to make defense installations more energy emcient.
As a result of these efforts, the Pentagon last fall added $13 1 million to its fiscal year 2008 to 2013
spending plan for research and development of energy-efficiency technologies, according to Pentagon
officials.
Among the research projects slated for additional investments, according to Pentagon officials, are: a
lightweight ground vehicle fuel efficiency demonstrator designed to facilitate a 30 percent decrease in
fuel consumption and work on lightweight transmissions and enhanced efficiency engines; the
Transportable Hybrid Electric Power system, an effort to utilize renewable energy sources to power
forward-deployed units in order to reduce the number of resupply convoys that have been vulnerable to
attack in places such as Iraq; and the Highly Efficient Embedded Turbine Engine, which developers
hope will provide a 25 percent decrease in fuel consumption for aircraft by revisiting the core
geometries and temperatures of turbine engines. - Jason Sherman
PENTAGON-23-22- 14
0 2005 Inside Washington Publishers
Reproduction or redistribution forbidden without express permission of the publishers
http://defense.iwpnewsstand.com

THE STATE ENERGY EFFICIENCY SCORECARD FOR 2006
Maggie Eldridge, Bill Prindle, Dan York, and
Steve Nadel
June 2007
Report Number E075
OAmerican Council for an Energy-Efficient Economy
1001 Connecticut Avenue, N.W., Suite 801, Washington, D.C. 20036
(202) 429-8873 phone, (202) 429-2248 fax, htt~e:/iaceee.org

The State Energy Efficiency Scorecard for 2006. ACEEE
EXECUTIVE SUMMARY
More and more states are turning to enera effciencJ- as the "first fuel'' in the race for clean
and secure energy resources. In their commitments to advance energy efficiency policies and
programs, they are outpacing the federal go\;emment by a ividening margin. States now
spend about three times as much on energy efficiency programs as the federal goi.emment.
and are leading the way on appliance standards, building codes. energy efficiency resource
standards. and other lie!. policies that drive energy efficiency investment. In this era of state
pre-eminence? it is important to document best practices and recopize leadership among the
states, so that other states follow, and to encourage federal action to catch up. Toward that
end. ACEEE developed this report as a comprehensive ranking of state energ. efficient!.
policies and identified exemplary programs and policies n-ithin each polic?. categon.. The
report ranks states based on their progress in eight energ efficiency policy categones:
1. Spending on Utilih and Public Benefits Enera Efficiency Programs
2. Energ Efficiency Resource Standards (EERS)
3. Combined Heat and Pokver (CHP)
4. Building Energ? Codes
5. Transportation Policies
6. Appliance and Equipment Efficiency Standards
7. Tas 1ncentii.es
8. State Lead b! Example and Research & Deyelopment
Summaiy of Rmkings
Table ES-1 contains a summan. ranking of the states on the eight policy categories included
in this study. The "top ten'' states. based on their combined scores. are:
1. Vermont, Connecticut, and California (tie)
4. Massachusetts
5. Oregon
6. Washington
7. New York
8. Nen- Jerse!.
9. Rhode Island. Minnesota (tie)
The top ten states earn scores between 20 and 33 out of a possible 44 points, and the next
fifteen states' scores trail fsurly moderately behind all score more than 10 points, up to 17 5
points The bottom 26 states. howe5er. senousl) lag behind the other states. scoring betlieen
0 5 and 10 points
..,
111

The State Energ) Efficiency Scorecard for 2006, ACEEE

The State Energ! Efficient! Scorecard for 2006. ACEEE
I
Iowa* 0
s 0 3
Wisconsin e 0 0
I 2.5
I
Connecticut 1 I a I 0
Illinois e 0
1
1
49

The State Energy Efficiencx Scorecard for 2006. ACEEE
* States nith etemplarq iimo\atn e finance mechamsms \?ere giyen an evtra pomt
Research and Development
In 1990, several state energy R&D institutions established the Association of State Energ
Research and Technology Transfer Institutions (ASERTTI)” in response to the increasing
need for state initiatives in R&D. In addition to providing a variety of services to promote
the creation, development, and commercialization of new technologies for enera efficiency,
state R&D efforts can address a number of market failures that persist in the enere services
marketplace (Pye and Nadel 1997). State-level institutions have the advantage of focusing
on regional needs and opportunities that are not addressed by national programs. State
institutions can also coordinate a range of resources from across the state.
Other Policies
Iiznovcrrive.finnizcing. States are developing a wide range of innovative financing mechanisms
to finance programs to implement energy efficiency improvements in existing buildings and
ne\\- state facilities, including revolving loan funds, tax-esempt master lease-purchase
agreements, lease revenue bonds, pension funds, and performance contracting. These
mechanisms are usually administered by the state energy office or other lead agency, which
coordinates the program across multiple state agencies.
1oil.a has been a leader in state financing for public facilities. Legislation passed in the 1980s
established the Iotl-a Energy Bank, which allows state agencies to use lease-purchase
financing and loans for energy-management improvements, and the State Facilities Program
(EPA 2006d). The Tesas LomSTAR program ivhich was initiated by the Texas Energ,
Office in 1988? uses a revoll-ing loan fund mechanism that is funded at about $100 million.
As of April 2006, LoanSTAR funded a total of 187 loans of which 17 were to state agencies,
46 to institutions of higher education, 36 to local governments, 78 to independent school
districts, and 10 to counp hospitals (SECO 2007).
50

constraints.‘ Similarly. ISOs and RTOs estimate the
degree to which congestion in specific areas would
bs alleviated by transmission upgrades, because
major reductions in congestion mean bill savings
for electricity customers.’ Congestion also occurs in
areas where thc grid is managed by individual integated
utilities rather than by regional grid operators:
however, since transmission, generation and
redispatch costs are less visible in these areas, the
costs of congestion are not as readily identifiable.
As the tenn is used here, reliability refers to the delivery
of electricity to customers in the amounts desired
and within accepted standards for the frequency,
duration, and magnitude of outages and
other adverse conditions or e\*ents. Loadpockets are
created when a major load center (such as a large
city llke San Francisco or New York) has too little
local generation relative to load and must import
much of its electricity via transmission from neighbo+iing
regions. For example, most of California is
currently a generation-short load pocket; by contrast,
transmission constraints cause Maine, which
has far more generation than load, to be generation-rich.
Because it is frequently difficult to site
and build efficient new generation within a city, or
to build additional transmission into a city, the resulting
load pocket will often experience congestion-meaning
it cannot import as much low-cost
energy as it would like, and the city’s electricity
provider(s) must operate one or iiiore existing
power plants inside the city more intensively to ensure
that all customer needs are met, although at
higher cost. If electricity demand inside the load
pocket grows quickly without being checked by energy
efficiency and demand response, the load
I
pocket may face a looming reliability problem, vi ith
too little supply (local generation plus transmission-eilabled
imports) relative to demand-whether
in actual ternis or according to accepted rules for
safe grid operation. In such cases. it is necessary for
the transmission owner(s) serving the load pocket to
resolve the reliability problem as quickly as possible.
7,
e case of a load pocket, thcre arc three primary 1
ways to deal with a long-teim congestion problem:
1.
Build new central-station generation within the
load pocket;
2. Build ncw or upgrade transmission capacity
(some combination of lines and other equipment
such as transfomiers and capacitors) to cnable
distant generators to senre a portion of the
area’s load; or
3. Reduce electricity demand (and net import
needs) within the load pocket, through some
combination of energy efficiency. demand response.
and distributed generation.
The three options can be used singly or in combination
to solve a transmission constraint problcni
flexibly and cost-effectively. Generation and transmission,
however, are costly, time-consuming solutions
that often face opposition. Demand-side options
tend to be under-utilized because they have
high transaction costs with results that may be less
certain and less controllable. It should also be noted
that there are a variety of transmission-only solutions
to any specific transmission problem; not cyery
transmission project (or cornbination of projects)
will provide equal congestion relief, nor will
it provide equal reliability or economic benefits to
one in the affected region.
\-p.o.-^------ -
‘See, for example. PJM’s statement that congestion costs resulting from constraints in the Allegheny Mountain area azotaled S747 million in 1005.
with another $464 million on the Delaware River path that year. Se
.Int~rest-L.ansinissioc-iomci~r-s pdi^ for additional detail. Organized
to protect themselves irnd prevent the full cost of congestion from driving up their total deljvered electticity costs.
‘It is important to note that the purpose of this study was to identifj areas experiencins significant congestion, as opposed 10 estimating the net
value of actions to address thc congcstion. See, for example., the CAISO’s estimate that transmission upgrades and operatianal impravcnienrs
czonioleted in 2005 reduced summer congestion costs by more than $54 million in just two months (IIIPJ: ,ww,..2aiso cc.m.docs:
, and that three newly approsed transmission project
bonknecks and maintaining ackquate generalion for local rzliability by $30 million per year”
4 US. Department of Energy I National Electric Transmission Congestion Study ‘ 2006

and achievable cosi effective potential.
Cahlations based on sthldies in other
states sh

. , . .
.. .

I
. ---
...............................................................
.........................................
............................. , ...............................
..........................................................................
..... ,.:,. . .....

age 1 of 2
North Anna Power Station
Pdoith Anna is located in Louisa
county if? central Virginia,
northwest Of Richmond.
The facility was rramed alter the North Aniia River, which was dammed tc Form the 9,61313-acre Lake Amh?
I-eser-voii- and the 3,400-acre ;ni'aste Heat Trcatrnent Facility, used to prwide ci;o!ing water fcr the station.
Domi?iiiion annotimed :3t: Noit. 28, 2Oci7, that I: has filed an application with the U.5. ~uciear Feguiatory
Cornmissior? Cor .f;. iicetse tu build and cperate 3 ~ i nuclear e ~ reactor at its North Anria Power Station in central
Virgirria. If hililt, the new reactor would add to Dominron's position as one of the nation's top nuclear
operators. The appiication filed with the NRC is for a Combined Operating License [COij for North ~ nna unit
3. The CCn7pagji has not committed to build the aeiv uniti but xants to maintair, the ~ption ttt dc sc to n?eet
]nro:ected skyrncketing dcmnd For electricity i!: Virginia in the next decade,

North Anna Power Station Page 2 of 2
t Waste Heat Treatment Facility (WHTF)
Emergency Preparedness
Read our information on emergency planning efforts.
If you wouid like to learn more about nuclear energy, we invite you to visit the N:xtt? Am6 Niiclcar
7 -
ir:ror:natiar: Cer!ler. The center welcomes visitors including individuals having specid needs. To assist us in
accon?modating any special requirements or needs, we ask that you c~ntact us in advance of yorir visit. To
arr~inge a visit or for other jnforrnatjon, call (540) 894-2029 or 21328.

age 1 of 2
THE FREE LANCE-STAR ENTERTAlNMENT CON
4I?vB$TLhE - Alcr:a - linm~ - b ~~tle - .u,oe* YZ - Thu. Oct 11, 2007
TAT€ CLASSIFIEDS IOBS WHEELS STAR DIRECTORY SHOPPING
63arrw'*w.cuw.,
*C*
School High School Schaol Here
Dominion to move toward third reactor
NRC tc review process for expected Dominion
a pitcatton to 5UilP new reactor at North Anna plants
By RUSR DENNEN
Sometime this fall, Dominion power is expected to tak the
neZ step in plans for a thlrd nuclear reactor at North Anna
sower Station
P?e utility will apply for a combined operating license that, if
approved, would allow it to build Unit 3 at the Louisa County
3lant on Lake Anna.
The Nuclear Regciatory Commission will hold a public meeting
act. 2A at 7 p.m. at Louisa County Middle School to review the
-c-c application orocess , . ~ __u____^_~_ .,-. I.
The YRC IS ready to review this applicatioc and t'?e others we're expecting over the next couple of years
i Cormunities pear these sites ?eed to know whats ahead, said David Matthews, director of the Division of New
Reactor Licensing
t
\ Pie review includes safety and environmental assessments, as well as how the public can take part in the
t process A combined operating license wmld a l b Dominion to build and, with conditions, operate Unit 3
Baltimo-e Gas & Electric's Calvert Cliffs plant on the Chesapeake Bay in Calvert County, Md , ~ a the 5 first to apply
for a combined operating license, though nearly a dozen utilities are prepanng them
!
1
Meanwhile, Domimops early site permit application-the first step in the review process-is wendlng its way
tirough the regulatory process The NRC is expected to make a decision on that by early next year
1
i
lhe early site Oermit allows Dominion to envi-onmental and safety issues, and :o complete orelimiqary
n officials say they have not yet decided whether to build a new reactor at North Anna, out that they want
if the aarly-site permit and the combined operating-license applications are approved, construction
as early as 2015
-8-
me applications are opposed by several envimnmentai groups. They say another reactor is unnecessary at E! time
ihen utilities should be exploring alternative energy sources, and would present a new target for terronsts
4 citizens group on the lake has expressed conceris about increased water temperatures ard how that would
affect aquatic life and recreational use
Dornlnion plans to use a 1,600-megawatt General Electnc Economic Simplified Boiling Water Reactor for Unit 3
me NRC IS reviewing thar: design
The 'Lake Anna area, where the North Anna Power Station is situated, is in Fredencksburg's backyard, and is
bordered by Spotsylvanra, Louisa and Orange counties. Surrounded by thousands of homes, it is a recreational
draw in central Virginia.
For more information, nrc gov/reactors/new-wactor-iicenslng.html Qusty Dennen: 5401374-5431
Email, ;~:zrrocn$t: ~(.i.)i):.Cs:d:.i:bn:
'6
i
i
i
i
:
September 2003- Dominion power applies for early Site $emit
=all 2007--Dominion to apply for combined operating license
Early 2008--Nuclear Regulatory Commission to decide on early site permit
,. .- .

Fredericksburg.com - Dominion to move toward third reactor
Page 2 of 2
Early 2011--NRC to aecide on combined operating-license application.
Source: Nuclear Regulatory Commission
What do you think?
Enter your FreaTalk usemame and pasSWOid to pmt e c~mmen! on !his stor/. lfyGu are registered on FrwTalk or anather part of this Slte. use that Iogln
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Today's Popdar Stories:
. ~ bnui LOOO .IL:hlq
(Thuwday, 00.37, The Free Lance-Star)
e After a y&ar. !rrgarW'j?.icome Ceci~i

age I
OT z
g J
12
News Features:
South west Vi rg i n i a
e a desiyi? is make it carbo:?-capture csmpatible, mezniny t h~i tec$noiogy to
captwe carbon dioxide COuld Se added LO the stme!-i when iC becomes
commerciaiiy avaiiatie. Dominion is sponsoring research at Virgin:a Tsch ta see
if it is jjo5sible tc seqwster carbon dioxide !r: csai seams iE Sciirhwest j:iigrnia.
ff posibif, greenhouse gaSse-5 froni the pcwei stetivn could eventzaiiy be
sequestered. Carion capttire teciPm!ogy is entrtied to em-a i.?cei-ttvs przn?iun?s
u ri der Vi ry i c? i a 's reg ti i acwj f r a mew u rk ,

Dominion Seeks Approval for Power Station in Southwest Virginia Page 2 of 2
B The possiDle beneficial I-ecycling of combustion isy,-products for t:ne
rnazufacturi3g of cament,
7-&- , , ,'; ~brnpany
-_I 3ke IS ccrrnrnitted to ;-esci?ing a goal of havin~ 12 Zercsnt of its electricity
CG;?X from miewable rescurces by 2022 and to helping ths conimonwea!ti ce;.eicp a
comprehensive iong-term energy ccnservation pian as d~recred by tlie Gened
Assernbi y.
The station wiil be mated cn 2 1,XC-acre site near 5t. Paul in Wise County. 3 would
prob*;ide eriougn power to serve 145,000 residentiai custonws. Ui;c;e:' a state iaw
encwraging the construction of the station, it vicsi3 be powered by Virgnia CG~:. The
srarion would en?pioy up to 8CO workers during constrdction. Once con-@&e, :ne
station wouici i?2ve 75 full-Wne employees, and it ako would create about 350 rr!ii:iny
jobs ir: the area.

A proposed Wise County, Va., 'clean coal' power plant could be among
Virginia's Top I O polluters
httn:~~~~f~~.tricities. corn/tristafe/tri!news. Pri ntView .-content-a rticles-TR f -2007- 10-21 -0025, htm I
Sunday, Oct 21,2007 - 02:OO AM
By Rex Bowman, Media General News Setvice
A $1.6 billion coal-fired power plant proposed for Wise County is touted by the
utility company that wants to build it as an eco-friendly "clean coal" model of
environmental design.
But if built to the company's specifications, it would be one of the biggest air
polluters in Virginia, according to documents filed with the state.
The plant would give Dominion Virginia Power an extra 585 megawatts of power.
enough to support 146,000 new homes.
The proposed Virginia City Hybrid Energy Center would be allowed to pump
more than 12,500 tons - or 25 million pounds - of pollution into the air each year
if Dominion Virginia Power goes through with its plans. The pollutants include
nitrogen oxides, an ingredient of smog; sulfur dioxide, a major cause of acid rain:
and carbon monoxide, which can pose serious breathing problems for those with
respiratory ailments.
The emissions are in addition to the 5.3 million tons of carbon dioxide the plant
could discharge annually, according to company officials. Carbon dioxide, though
recognized by the U.S. Environmental Protection Agency as a greenhouse gas,
is not regulated as a pollutant.
Dominion Virginia Power points out, however, that the Wise facility would pollute
less than do older plants. The utility is allowed to call the power plant a "clean
coal" operation under rules laid down by the U.S. Department of Energy, which is
encouraging utilities to use certain coal technologies by giving the technologies
the envi ronmen ta 1 I y-friendly sticker.
But environmentalists fighting to stop state approval of the power plant say the
"clean coal" label, though sanctioned by the federal government, is a deceptive
marketing practice that could dampen opposition to the plant even though its
construction could spell disaster for the ecosystem of Appalachian Virginia,
If approved by the State Corporation Commission, the plant would join other
coal-fired power plants at the top of the list of roughly 2,000 polluters monitored
by the Virginia Department of Environmental Quality.
"Any time the utility industry adopts a really effective messaging strategy, it
makes our lives more difficult," said Matt Wasson of Appalachian Voices, one of
several groups opposing the power plant. "The label of clean coal is, in my

opinion, a focus group's phrase, and a very effective one, to justify all these
planned coal-fired plants."
James K. Martin, a senior vice president at Dominion Virginia Power, defends the
use of the term as accurate, illustrating that the proposed plant can be seen two
ways. While environmentalists view the plant as a setback in the context of
nationwide efforts to curb pollution, power industry officials such as Martin see
the plant as a step forward in the context of evolving energy technology because
it pollutes less than older plants.
For instance, while Dominion Virginia Power is asking for permission to annually
emit more than 12,500 tons of pollutants in Virginia City, the company's
Chesterfield County power station - the state's biggest air polluter - released
more than 76,800 tons of pollutants into the atmosphere last year.
Furthermore, said Dominion Virginia Power spokesman Dan Genest, a plant the
size of the one planned for Virginia City potentially could emit more than 167,000
tons of nitrogen oxides and sulfur dioxide into the air each year if none of the
state-of-the-art technological controls were in place. With controls, the amount is
projected at about 5,340 tons per year.
"We think it's an exciting technology," Martin said of the proposed plant's
cleaning system. He also noted that the plant likely would operate at 90 percent
of capacity, meaning emissions would never hit the 12,500-ton mark.
Dominion Virginia Power wants to build the power plant on 1,700 acres of
abandoned strip mine just west of the town of St. Paul and fuel it with Virginia
coal and waste wood products.
The company, which hopes to win approval from the State Corporation
Commission by April and have the plant up and running by 2012, says the
electricity is necessary to help it meet an anticipated 4,000-megawatt jump in
demand from Dominion Virginia Power customers by 201 7.
The General Assembly gave its blessing to the plant in 2004, when it decreed as
a public good any power station in Southwest Virginia that used only Virginia
coal. Sen. William C. Wampler Jr., R-Bristol, pushed for the measure, and he
recently said he still supports the plant.
"We have to have it as part of the mix to power Virginia,'' he said, adding that the
state should also look at using more nuclear power.
The federal Energy Department regards the proposed Virginia City plant as a
potential "clean coal" operation because it would use a process known as
"circulating fluidized bed combustion technology," or CFB. The process involves

310 ANNUAL REPORT
CASE NO. 9003
APPALACHIAN POWER COMPANY.
a corporation.
Application for a Certificate of
Convenience and Necessit), to Construct
a 765 kV Transmission Line
in Mason, Putnam and Cabell Counties.
PROCEDURE
ORDER: Entered Mag 18. 2979
On May 9. 1977, Appalachian Power Company ("Appalachian". "APCQ"
or "company") filed an appiication for a certific2te of convenience and
necessity to consrrucl a 765 kV transmission line south from an inter-connection
in Mason County with the existing 765 kV Amos-Gavin line to Appalachian's
Culloden Station in Cabell County, covering 2 distance of approximately
33 miles. This line will hereinafter be referred to as the proposed
Culioden-Gavin 765 kV transmission line.
Appalachian filed with its appijcarion a 74 page bookiet entitled "Environmental
Analysis for the Culloden-Gavin 765 kV Transmzssion Line.
Foilowing the filing of its application. Appalachiar? published the norice
required by W.Va. Code 24-2-1 la. which stated that the Commission could
approve the application unless within fifteen (15) days after completion of
pubIiCatlOn a written request for a hraring thereon had been received by
the Commission from a person or persons alleging the proposed transmission
iine or its location to be against the public interest. No written requests
were made to the Commission for a hearing on rhe application during the
period.
By order entered on July 18. fY77 this matter was set for hearing to
be held in the Commission's Hearing Room at the Capitol in the City of
Charleston on the 3ist day of August. 1977 at which time and place
Appalachian was ordered to appear and prosecute its application and anyone
interested was inviled to appear and make objection thereto. Leave was
granted to anyone interested to file objection to the application with the
Commission at any time on or before the 31s day of August. 1977.
Appaiachian was also ordered to give notice of the fiiing of Its application
and of the time and place of hearing by publishing a copy of the
Commission's order once a week for two successive weeks. the first publication
to be made nol more than thirty days nor less than fifteen days prior
to the 31st day of August. 1977 in a newspaper published and of genera!
circulation in each of the Counties of Mason. Putnam and Cabell and to
make due return to the Commission on or before the day of hearing.
Appalachian published the Commission's order of Jul) IS, 1977 in
accordance with the requirements of that order. The hearing was held ,4ugust

wy_Jc-
f
W. Va.
19791 PUBLlC SERViCE COMMISSION ?!P
nos 3445-138 kV transformer
daliszewski Reb. Ex. G, 11,
of the Amos-Hanging Rock
andy No. 2 and Amos No. 2
,timated 1980-8 1 winter peak
nos operating at about 118%
of its normal raring (Id,, 2).
is-Gavin 765 kV circuit with
service and Big Sandy No. t
5 k\’ circuit is loaded above
jbove cases the overload con-
[re in the system resulting in
3.
: that the operation of transould
result in the immediate
.ge which could cause failure
ing within normal capabilities
jence that the proposed line
:@ >. (Maliszewski Reb.
.
\
centration of generating capacity in one area, the fact remains that the
New Haven plant was certificated in 1974, is now nearing completion and
clearly the .4PCO Reliability Studies S1 - SI2 are of some significance as
justification for the proposed line. In addition. the load flow studies A1 - A30
demonstrate that serious power flow and overloading problems will exist,
not necessarily leading to transient stability problems. but which could. nonetheless.
result in system outages due to transformers and other facilities operat-
ing at or above their winter emergency ratings in the near future.
.-Pi IS--*-
_’**.-**.- 4.:.*-> ,,..,-‘r*i*i__:
~ . . ~ ~
rd is seriously deficient in that it does not contain studies ’\
reflecting the probability of each required element of outage and units ’1,
operating at full load simultaneously, there is, we believe, a sufficient basis
\i
in the record for a finding that the proposed line is essential for the New \
Haven plant to be properly and reliably integrated into the AEP System :.
without violating the basic ECAR criteria. Particularly, there is evidence
that single and double contingency outages have occurred a number of times
on the AEP transmission system (Reb. Maliszewski Ex. G. 31. The difficulty
i ’
we have experienced in attempting to evaluate the probabilities of the oc- ;
currences which must take place in the computer sirnilation studies lead us to ;
the conclusion, however, that future certification cases presented in this
jurisdiction should be accompanied by evidence concerning such probabilities i’
c-
w-EIPq;*ryr. -
hich could occur undei tran-
hed this conclusion concern-
?stem under stress. The fact
tvels were within acceptablc
#ties operatbg normalby. The
nber 7. I977 memo assume
-he staff does recognize that
:m in the stead), mode of
ce (Tr. 1576).
is opinion that the proposed
no; take into account an)’
and that his opinion was
tTr. 1416). Alrhou,oh Dr.
are an essential aspect of
did noi have the capability
ve itself violated the first
voidance of excessive con-
!
B. EVIDENCE ADDRESSXNG APPLICANT’S CONSIDERATION OF
ALTERNAIIES TO THE PROPOSED LINE
APCO has asserted that the proposed line will remedy the problems
discussed above and that there is no viable alternative to the construction of
the line. Intervenors assert. however. that there are numerous alternatives
both in terms of additional equipment and in terms of system management
which could achieve with less environmenta! impact the stability and reinforcement
AEP professes to desire.
The chief alternative to the proposed line is to tie both the New Haven
and Gavin Plant into the existing 345 LV system. APCO admitted that this
alternative would provide transient stability for the New Haven and Gavin
Plants. but objected to it because it would no1 reinforce the svstem as adequately,
would require a new 345 kV transmission Iine from Sporn to
Culloden following essentially the same route as the proposed line. and
would he more expensive (Maiiszewski Ex. A. 21. 22: Maliszewski Reb. Ex.
I to IS). The majority of the cost estimated for this alternative consisted of
the construction of 345 kV lines to carry the same amount of ioad as the
765 kL’ line. (lnt. Maiiszewski Exh. 7).
A second alternative mentioned by the applicant would be the constriiction
of a 765 kV line from Gavin to North Proctorville. This configuration
solves the stability problem but AEP tesrified ir does nothing IO soive the
overload problems (Tr. 673-674; 1637).

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Page 2 of 5
such as waste water effluent discharges from large manufacturing plants. These
sources are generally pipelines or ditches that are carrying wastewater discharge
to streams and waterways, and their quality can be easily monitored. One
portion of the CWA mandated that best available technology be used to control
point source pollution. The Sierra Club has called this regulation "one of the most
successful environmental laws in our nation's history."
Unfortunately, the story of non-point source pollution regulation is much more
dismal. Currently, the bay receives a whopping 41% of its nitrogen from
agriculture alone, as compared to 21% from all point sources, both industrial and
municipal. This nitrogen pollution's origination sources can be seen in figure 1,
below.
While some
atteinpts at
stemming this non- "Total Nitrogen from
point source
pollution have
been made,
success has been
severely limited by
a lack of funding
and political
unwillingness to
regulate
agricultural runoff.
Instead, many
lawmakers have
opted to
implement
incentive programs
to reduce water
pollution, but these
are habitually
under-funded and
under-staffed. One
Virginia program
aimed at reducing
animal waste
pollution
attempted to
provide up to 75%
of the cost of
waste
management, but
requests for
participation Figure 1: Total nitrogen from agriculture reaching
exceeded available Chesapeake Bay Tributaries. Source: "Saving a National
funds by $2 2 Treasure" Blue Ribbon Financing Panel 2004.
billion in 2004
alone. In Maryland a program to subsidize cover crop application could have
spent between $12 and $17 million, but its budget was only $8 3 million.
,f Additionally, sprawl around the urban centers in the Chesapeake Bay has further
fueled nutrient runoff, Often, sprawl takes place on virgin land, clearing acres of %
trees and farmland in favor of housing developments. Even though farms are
sources of nutrient pollution, increasingly housing developments are becoming
even greater sources of runoff and nutrient pollution. While farms can be
managed to reduce their pollution, many housing developments give little
thought to the nutrient runoff in their storm water Many scientists believe rapid
rates of sprawl in the watershed are the reason the bay's situation isn't
improving While concerted efforts have been made to manage nutrient
pollution, rapid sprawl is offsetting these gains.
'%I
- " .d
-*.. .. --*C1--*--"z-r
1
And so the cause of the problem IS evident. As the beloved Pogo once remarked
"we have met the enemy and he is us".
I
If there is any hope of achieving the 2010 goal significant investment
consideration must be made, not only on how to reduce pollution, but also where

,
I ayc 3 UI i,
we can get the greatest reduction for our limited financial resources. As with any
pollution management program, the greatest clean-up gains per dollar spent are
made from initial regulation. lust by implementing accountability standards and
establishing management programs, great pollution reductions are achieved in
the initial stages of poilution management, It is the later stages, generally those
that are working to virtually eliminate pollution from a particular source, that are
overwhelmingly costly. In the case of clean water, point source regulation has
been ongoing since the 1972 CWA, but non-point regulation has been severely
lacking and thus presents the greatest opportunity for pollution reduction,
Investing in Clean Water
A 2004 report by the Chesapeake Bay Commission identified six least-cost
options to clean up the bay. Five of them focused on agriculture and non-point
sources, indicating just how underdeveloped such programs are. The remaining
suggestion is just what the Harrisonburg-Rockingham Sewer Authority is doing,
upgrading its plant to the limit of present technology. They estimated that these
six options, if implemented, could achieve 75% of the reduction goal for Nitrogen
at the relatively low cost of $623 million total for all the bay states, but each
come with their own individual cost. As seen in figure 2 below, while water
treatment facility upgrades have great potential for reducing nitrogen loads, they
are the most expensive reductions to achieve per pound,
NITROGEN
PHOSPHORUS
SEDIMENT
Measures M. Ibs. $/lb.
Waste Treatment 35.0 8,56
Upgrades
Diet and Feed
Changes
Nutrient
Management
Enhanced Nutrient
Mgmt.
13.6 1.66
23.7 4.41
Conservation Tilage 12.0 1.57
CoverCrops 23.3 3.13
M. Ibs. $/lb. M. Ibs. $/lb.
3.0 74.00 na
0.22 0.00 na
0.80 28.26 na
0.80 95.79 na
2.59 1.68
0.44 0.22
na=Not applicable - = No additional cos
t
Implications
Total potential reductions for nonpoint
sources (2-6) at the edge of the field*
Totai potential reductions for nonpoint
sources (2-6) delivered to the Bay**
Total potential reductions for ail six
practices (1-6) delivered to the Bay**
Bay Agreement reduction goal (2002-
2010)
NITROGEN PHOSPHORUS SEDIMENT
53.6m lbs. 2.93m Ibs. 1.35m tons
45.4m Ibs. 1.99m Ibs. 0.90m tons
80.4m lbs. 4.99m ibs. 0.90m tons
103m ibs. 6.7m Ibs. 0.90m tons
* The reductions attributed to each agricultural practice ae less when
combinedwith outer practices on the same land. Therefore, the expected ttoal
reduction from combing agricultural practices is less than their sum.
** Agricultural reductions are measured at edge of field, and are reduced by
the time they reach the bay; this results in totla reductions in loadings from
those six practices as indicated. Waste treatment plant reductions estimates
are as delivered to the bay.
Figure 2: Nutrient reduction by cost. Source: Chesapeake Bay commission
"Cost-Effective strategies for nutrient and sediment reduction" 2004
Why then, did the state choose to promote this reduction above the others
suggested in the report? Primarily, point source reductions are the most
convenient to enforce, A monitoring structure is already in place for point source
reduction, and there is great potential for reduction in this category. Additionally,

Virginia Business Magazine: Virginia iaeas, I ne LnesapeaKe tray
raye 4 UI a
the reduction amounts are virtually guaranteed if the technology is properly
implemented. Even so, I would argue that greater per-dollar reduction could
have been achieved by shifting this investment by the state and locality to nonpoint
source controls,
The Commission's five other strategies are ail plans that are viable and currently
in practice on small scales, or are simply under-funded. I am not arguing that
the capacity increase for the regional sewer authority is unwarranted, but if this
spending is aimed primarily at cleaning up the bay, there are other options that
could be more cost effective and achieve greater reductions. In total all six
investments are only projected to meet three quarters of the reductions needed.
Litigation
While the state has largely ignored the significant water pollution associated with
agricultural systems, environmental groups have started questioning the legality
of their continued high rates of pollution. Three environmental groups have
joined forces and threatened a federal suit against two corporations for
overwhelming the SIL wastewater facility in Timberville, Virginia. The waste in
question is primarily poultry and meat processing waste, and its overproduction
is allegedly causing the facility to pollute substantially beyond their permitted
discharge. This case is claiming violations under the CWA, challenging the
corporations' argument that once their waste reaches the SIL treatment facility
they are no longer liable for its release as pollution. While the wastewater facility
is considered a traditional point source and has discharge permits under the
CWA, this allegation is unique in that it is attempting to shift liability from the
permitted facility onto the producers of the waste.
This pending case is similar to the federal Concerned Area Residents for the
Environment v. Southview Farm case. In this case the courts held that some
forms of large industrial agriculture, which are often considered the biggest nonpoint
source polluters, can be classified as point sources due to their
concentration of nutrient pollution into collection ponds and ditches. This
designation called for Southview Farms, a dairy and crop farm, to be subject to
the same best management practice standards and permitting process as
contained animal feed operations (feedlots), which are regulated as point
sources under the Clean Water Act. Initially the Southview case followed the
same 60 day notice of CWA violations as have been given in the pending Virginia
case. If this new case follows the course of Southview and the violations are not
addressed, the next step will be for a Judge to find that the processing
companies are alleging continuing violations of the CWA. This finding will be
sufficient grounds for the environmental groups to bring a citizens suit, as
decided in Gwaltney of Smithfield v. Chesapeake Bay Foundation.
This litigation can be seen as a barometer for public opinion. Citizens are calling
for non-point source polluters to take responsibility for the damage they are
causing to the Bay. Such regulation fits into the action plan the Chesapeake Bay
Foundation has been calling for, and there is some promise for help on the
federal level. The farm bill, due for renewal in September, could contain
provisions quadrupling federal aid to the Chesapeake Bay watershed, totaling
$262.5 million, which would then be matched by the states. One proposal calls
for this funding to be managed by a regional authority, and under this direction
real progress could be made in regulating non-point source pollution in the Bay's
watershed. Unfortunately our legislatures national, state and local have done
very little to help the matter in the past. The Bays' problems have been clearly
evident for decades, but the legislators do not seem at all interested funding a
real solution, rather they have been putting it off by long speeches, studies and
generally finessing it until after the next election.
Saving the Bay
In the long term, several changes must be made if we are to elevate the
Chesapeake from its current classification of "dangerously out of balance" with
its score of 29 by the Chesapeake Bay Foundation to "saved," a score of at least
70. Both point and non-point sources must be rigorously managed, and this
management must extend even beyond the agricultural controls that many are
considering. Land use shifts from agriculture to development have incurred high
water pollution in sprawling regions of the Bay's watershed. Removing forests
that naturally clean runoff and remove nutrients and replacing them with
landscapes that are at susceptible to high amounts of erosion is a trend that
must stop. Future developments must be mandated to manage runoff and

I
uyL. 4 VI J
contain any nutrient pollution.
Additionally, homeowners that aren't connected to water treatment networks are
sources of nutrient pollution. Generally they rely on individual septic systems,
many of which will fail and leak over their lifetime. These systems typically have
had no, or very limited maintenance and some are several decades old.
Currently private septic tanks are estimated at contributing 4% of the nutrient
pollution found in the bay. An inspection program should be implemented, with
graduated upgrades required, to ensure these systems aren't leaking and are
adequately neutralizing their nutrient pollution.
Finally, private lawn fertilization also contributes to water pollution. One way to
raise clean-up funds while reducing water pollution could be a fertilizer tax. This
tax could be levied against all fertilizers based on concentrations of nitrogen and
phosphorus per pound equal to an estimated clean up cost, both for commercial
farms and private homeowners. The proceeds of this tax could be used to further
fund non-point source reductions and improve public awareness of the myriad of
factors that have changed the bay from one of the most productive ecosystems
in America to an estuary that is struggling to survive.
Saving the Bay will require a concerted effort on behalf of policymakers,
industries, farmers, and citizens across the watershed, but the return on this
investment will be substantial. The Clean Air Act has reportedly returned 4 times
its implementation cost, and the bay could see such high returns as well. These
returns will come from increased, sustainable harvests of fish and shellfish as the
bay's populations recover, increased tourism to rehabilitated areas, and the
inherent value of an ecosystem in balance. While these returns show great
potential, we must be willing to make a real investment now for the future health
of the Bay.
Mr. Logan is a first year law student at the University of Virginia. Mr. Litten is a
Harrisonburg attorney.
y i i ? bsmess Oril ne j Conta:: IJS 'debmaster
Vtrg!niaBus!ness.com is part of the Catewayda network
@ 2007, M&a General Operations lrc , publisher of Virginia Business
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Komr US. Business Worid Entertainment Sports Tech Politics Elections Scieiire Health Most Popular
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Group gives Potomac River a D-plus
kssoGi&& pirtss
SCIENCE VIDEO
Over the Moon
\p-
_-
- The fast-paced development of the Washington region and increased
are now the biggest threats to the long-struggling Potomac River, according to
,' i\U new5 video
Baby Seal Walks *--wm%..-....-- rnvvvalrrr,
Mile On Land To The Potomac.Con ---Gar--------
Animal Shelter Silver Sprmg, Md., river a
,BS :3 C\'" 31
grade of 0-plus in its first "State of the Nation's River" report
ELSEWHERE ON THE WEB
Tirne.com: Making the Case for .----_--.---L.I-M*-.~~~,,.
Va cci na:ior,
USATODAY.corn: A first: Stem
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A.SSI%?.i?.IENT EARTH
>'.
Beginning in the 1960% the river made a remarkable comeback from years of contamination
by raw sewage and industrial pollutants. But more paved surfaces, rooftops and the loss of
forests in the Potomac watershed are now straining the health of the waterway, which
supplies nearly 90 percent of the Washington region's drinking water.
,, , ,
.-..
-.,
point the cause of one of the clearest signs that something is '.,
sex" fish, which have both male and female attributes. Possible
mica1 pesticides, animal hormones in manure or human hormones in //
_i_.~~,._., ..,. -_-i-.----~------'-
.*XYL.. , __-.
~ .
Previously, studies had found that male bass in Dist~~ct.of.Co!umbia waters were growing
eggs. Recently, females Caught near the Blue Plains sewage treatment plant in southwest
D.C. have been found with what seem to be abnormally low levels of estrogen, researcher
Vicki Blazer of the UtS..Geolo.~!gjca!.Su.~e~ said. . . .. . I
'Ianet Profi'ed
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( - z n z x intersex fish, as well as high lev of sediment, nitroiii'
s could be shortlived, -..-.--.
.~.>,: ?_,,
L_ ...,C,I._..l-.l. -1 I+'--
"We've plateaued," said Hedrick Belin, president of the conservancy. "The improvements that
we've made, the progress, has stalled out."
In 1965, President Lyndon B. Johnson called the Potomac a "national disgrace." At the time, it
had been fouled by centuries of contamination by raw sewage and industrial pollutants.
Major improvements at wastewater treatment plants since then helped the Potomac become
clean enough to support numerous bald eagles and a stock of smallmouth and largemouth
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otornac, where it feeds algae
-,-------y4W---
Closer to Washington, forests have bee
rainwater carries pollutants into streams without being filtered by soil and plant roots.
"More people means more rooftops and more roads," Belin said. And that, he said, "leads to
greater contaminated runoff, coming off those hard surfaces."

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The streams and creeks that form the South Branch of the
Columbia - in the
watershed Sixteen million
people live, work, and play
Allegheny Plateau around Franklin and Petersburg, West
Vtrginia, while the Potomac forms the dividing line between
the Mountain State and Maryland from the North Branch east
into the rolling land of the Panhandle around Martinsburg,
Shepherdstown, Charles Town, and Harpers Ferry, where the
Shenandoah meets the Potomac. This beautiful area IS well-
approximately 11,684 miles
of shoreline. Fifty major
tributaries pour water into
the Chesapeake every day.
for tributaries like The Trough (a spectacular gorge on the
South Branch), the Lost River, and the Cacapon River.
While tourism is a major contributor to this part of West
Virginia, agriculture has grown tremendously in recent years,
Chesapeake Bay provides
food, water, cover, and
nesting or nursery areas to
more than 3,000 migratory
and resident wlidlife species.
the already-pressured Potomac downstream. For more information, call CBF's Virginia
http://www.cbf.org/site/PageServer?pagenarne=state main wv &orinter frienriIv=I 13/117nn7

u- ' -.-
FRIENDS 3,
&FOREST
abut us i contact
Neb% Horne
News Archive
June 10: 2006
Global Warming Attributable to Human Activities
Giobai V'riarmins refers to the !ncreaSes i
temperature of the Earth's atmosphere a
which iiave been observed iii recent decades
According to the National Academy of Scleixes be
Eaflh's surface temperatilre has risen by aboiii ,I
degree Fahrenheit in the oast cenkq wirb
9 during the pas: !WO decades
There is new and stronger evidence that most of the wamiing ever rhe last 50 yeais 1s attriouta5le
to numan activities. Air travel. household vehicles, appliances and hea!ing:cooiing units create
buridup of greenhouse gases - primarily carbon dioxide. methane. and nitrous oxide The Energy
Informatiorl Administration (Department of Energy) estiinates thar iii the U S the average annual
cx$oiT dioxide emissions per person is 20 metric ions
Ways to Reduce Carbon Dioxide Emissions
There are two oradical ways to reduce carbon dioxide emissions.
e Mod:Q iiiirnan activities that add more carbon dioxide to the atnmphere. and/or
?!an! ww trees and preserve existing trees and piant cornniunilies that sequeste: :s;b3?
Saturai!y
---.--.---"*,.---
---.,-.___
-----T
Carbon sequeslraiion is
(c
the process through which agricultural and focestw practices reiwvi.
carbon
d
dioxide (C02) fror the atmosphere. Preseiviqg an average acre of Fcresi :he Uni:ed
Slates keeps mere than 26O;OOO pounds OT carbon dioxide obi of the atniosnher'e (Source
EPAIGiobal Environment and Technology Foundation.)
----
-LI
..-..- _.. -P-
Forest PracWOffsSft Global Warming
Foiestrg practices periormed evey day by our consewatioi? parrners-repianting trees :em:vinij
invasive wecies that affect forest habitat. and reducing the tma: of fifes and fuel loads--prov;de
a positive influence on the global warming trend.
fake Actlot: to Reduce Your Carbon "Fetotprini"
Contributing to healthy forests offers Friends ofthe Fores! the unique CppQKUnity to offset tAee!r
carbon "footprint" by neutralizing their effect on global c!imate change Ycur finaiwal conPibutioand
volunteer efforts wiii help us complete more forest projects. and in turn will help yoc iediicr
vosr net contribution to Gtobal Warming. Hsb today'
'he stor$ begs the question if preserving an acre of forest keeps 260 000 ibs of C02 out ~f the
abrosphere that apparently is a 'steady state ' rfow much C02 does a healthy forest
seqiiester (many forests are adding fiber volume) Goes a forest at climax sequester as much
C92 as a growing forest? Climax forests likely are adding carbon io tne sot' but not necessariiy
.: Back fr h.Jei$s -owe ' ~ c ~ y < $?:I- ~ $
mhtml:file://C:\Documents and Settings\Kathy\My Documents\powerline\Evidenc. .
1 113317nn7

i
Keduce CjioDai vvarming
raye L VI L
;o the volume of carbon above ground.
27 Szpiemer 7 20 Edward Webb said ...
l belive as a 8 yr old boy that global warming will not effect our generation but will1 effect
generations to come and that IS the issue I belive we should press to the governient of today
after all the children ) are our future
4 ;),..:orer ':3 '4 ,Me Lee said ...
i love that most environmentalisis try to help the atmosphere
ithink that envirorneniaiists are awsorne people who do all that they can and are widley thank
enogh
So Thank You So Very Much
I like to help the enviroment but it's icinda hard 2 do all the time
Your Name i
I' ' " ' '
@
0 2007 Friends of the Forest - becorneafriend org - 1 L' o'liabl

Entertainment: Calendar I Travel
-+ confact us qco SubaicrZbe Discover Culpeper I VA Vineyards
Terremark Worldwide Inc. has
begun to move the mud for Its
new data center campus in
Culpeper, located on Technology
Drive off McDevitt Drive and
The Miami-based company
creates Internet networks and IS
a global provider of managed
Information Technology (IT)
infrastructure solutions for
LIFESTYLE
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e campus will consist of five
,000-square-foot independent
data center structures and one
72,000-square-foot office
building, according to its Web
site.
,\ :qT2- > VZ" -
Spmesman Xavier Gonzalez said the first ohase of the facility consists of 50,000
?.&,< I, r, * --, ,.
square feet.
L* 5-y
"We're moving along as scheduled and everything is going well," Gonzalez said.
"We're still on schedule for a June 2008 opening for the first phase of the facility and
customers will be deployed as that opens "
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FOR IMMEDIATE RELEASE
TUESDAY, OCTOBER 9,2007
WWV\I.USDOJ.GOV
Fact Sheet: United States Et 1. VS. ~~~~~~~~
Overview
ENRD
(202) 514-2007
TDD (202) 514-1888
Electric Power
On October 9, 2007, the United States, eight states, and thirteen citizen groups announced a settlement
agreement with American Electric Power (AEP) under the Clean Air Act's (Act) New Source Review (NSR)
provisions that obtains relief at sixteen (16) of AEP's coal-fired power plants (46 units) located in Indiana.
Kentucky, Ohio, Virginia, and West Virginia.
By several measures this is the single largest environmental enforcement settlement. It is the largest
environmental settlement as measured in terms of injunctive relief. As described in more detail below, it is
estimated that AEP will spend more than $4.6 billion to comply with the consent decree. The settlement also
is the largest as measured in terms of pollution reductions obtained from the owner or operator of a Clean
Air Act stationary source(s). Upon full implementation, the settlement will secure at least 813,000 tons per
year of air pollution reductions from AEP's 16 power plants.
In 2006, nitrogen oxide (NOx) emissions at these 16 plants totaled 231,000 tons per year. By 2016,
these AEP emissions will be reduced to 72,000 tons per year, continuing in perpetuity. In 2006, sulfur
dioxide (S02) emissions at these 16 plants totaled 828,000 tons per year. By 201 8, these AEP emissions
will be reduced to 174,000 tons per year, continuing in perpetuity. This SO2 reduction -- from a single
settlement -- is more than the SO2 emitted from most states (45 out of 50). This reduction in emissions is
one of the largest percentage decreases achieved in any of the United States' prior settlements with coalfired
electric utilities, and it reflects a multibillion dollar investment by AEP.
The settlement requires the installation and continuous operation of pollution control technology such as
selective catalytic reduction devices (SCRs) for the control of NOx and flue gas desulfurization equipment
(FGD), also known as scrubbers, for the control of SO2 emissions,
In addition to the significant reductions of SO2 and NOx, AEP will pay a $15 million penalty, the highest
penalty paid by any electric utility in settlement of a New Source Review case. Under the settlement, AEP
also committed $60 million to perform or finance environmental mitigation projects.
The Defendant
AEP ranks among the nation's largest generators of electricity. This settlement includes 16 plants
located in Indiana, Kentucky, Ohio, Virginia, and West Virginia, which, combined, generate over 20,000
megawatts.
Power Plants Enforcement Effort
The Department of Justice, at EPA's request, has filed lawsuits against several coal-fired electric
http://www. usdoj.gov/apa/pr/2007/0ctober/O7~enrd~798. htm I 11/29/2007

#07-798: 10-09-07 Fact Sheet: United States Et AI. vs. American Electric Power Page 2 of 3
utilities for alleged violations of the Clean Air Act. This series of cases seeks to bring the power plant
industry into full compliance with the NSR and Prevention of Significant Deterioration (PSD) requirements of
the Clean Air Act. This settlement with AEP represents the fourteenth judicial settlement under the power
plants enforcement effort. EPA has reached similar settlements with Alabama Power, Illinois Power
Company and Dynegy Midwest Generation, Alcoa Rockdale, TX, facility, PSEG Fossil, Southern Carolina
Public Service Authority, Southern Indiana Gas and Electric Company Culley Station, Tampa Electric
Company, Virginia Electric Power Company, Wisconsin Electric Power Company, First Energy, Minnkota
Power Cooperative and Square Butte Power Cooperative: East Kentucky Power Cooperative: and Nevada
Power Company.
Clean Air Act Violations
The United States, states, and citizens groups alleged that AEP made physical and operational
changes at nine of its plants that constituted “major modifications” without first undergoing PSD review or
Non-attainment New Source Review (NNSR), obtaining required permits, and installing and operating Best
Available Control Technology and/or technology reflecting the Lowest Achievable Emission Rate (MER) to
reduce air pollution.
Environmental Benefits
Harmful Pollutants Addressed by This Settlement
Nitrogen oxides: NOx cause a variety of health problems and adverse environmental impacts, such as
ground-level ozone, acid rain, PM, global warming, water quality deterioration, and visual impairment. NOx
play a major role, along with volatile organic chemicals, in the atmospheric reactions that produce ozone.
Sulfur dioxide: High concentrations of sulfur dioxide affect breathing and may aggravate existing
respiratory and cardiovascular disease. Sensitive populations include asthmatics, individuals with bronchitis
or emphysema, children, and the elderly. Sulfur dioxide is also a primary contributor to acid deposition, or
acid rain.
”“ ._-..- -”
P’
i Health Benefits
I
’
1
Once AEP has fully installed the pollution control equipment required by the settlement, the United
States estimates that the annual benefits to public health will include approximately $32 billion per year
. saved in avoided health-related costs associated with respiratory and cardiopulmonary
-. ,asthma and heart attacks.
,.
.I _I
Civil Penalties
..
AEP will pay a civil penalty in the amount of $1 5 million.
Mitigation Projects
-------------
AEP is required to spend $60 million to perform and finance environmental mitigation projects to
address the impacts of past emissions; the total amount will be split 60%/40% between the United States
and the various settling states. The $36 million federal share of mitigation projects will be spent on projects
to acquire and restore ecologically sensitive land in eastern states downwind of AEP’s plants; restore or
improve watersheds and forests in national parks adversely affected by past emissions; reduce nitrogen
loading to Chesapeake Bay through actions such as the acquisition of buffer zones; and additional projects
to reduce emissions from mobile sources, such as diesel barge tugs and conventionally powered trucks in
AEP’s fleet. The remaining $24 million for environmental projects will be allocated among the states that
joined the settlement.
.
Other Plaintiffs

The following eight states joined as plaintiffs in the case: New York, New Jersey, Massachusetts,
Vermont, Connecticut, New Hampshire, Maryland, and Rhode Island.
The following citizen groups also joined as plaintiffs: Natural Resources Defense Council, National
Wildlife Federation, Sierra Club, United States Public Interest Research Group, lzaak Walton League of
America, Ohio Citizen Action, Citizens Action Coalition of Indiana, Hoosier Environmental Council, Ohio
Valley Environmental Coalition, West Virginia Environmental Council, Clean Air Council, Indiana Wildlife
Federation, and the League of Ohio Sportsmen.
07-798
http:Ilwww. usdoj~gov~opa/pr/2007/0ctoberl07 enrd 798 html
I I 17n13nn7

I -
I -
t:)-Tn
Electric and Magnetic Fields (EMF) Radiation
from Power Lines
Electric and magnetic fields (EMF) are invisible lines of force
that surround any electrical device that is plugged in and
turned on. EMF are made up of waves of electric and magnetic
energy moving together (radiating) through space. Electric
fields are produced by electric charges and magnetic fields are
produced by the flow of current through wires or electrical
devices.
EMF is commonly associated with power lines. A person
standing directly under a high-voltage transmission line may
feel a mild shock when touching something that conducts
electricity. These sensations are caused by the strong electric
fields from the high-voltage electricity in the lines. They occur
only at close range because the electric fields rapidly become
weaker as the distance from the line increases.
Many people are concerned about potential adverse health
effects. Much of the research about power lines and potential
health effects is inconclusive. Despite more than two decades
of research to determine whether elevated EMF exposure,
principally to magnetic fields, is related to an increased risk of
childhood leukemia, there is still no definitive answer. The
general scientific consensus is that, thus far, the evidence
available is weak and is not sufficient to establish a definitive
cause-effect relationship.
-I-Ic -x-__I- *--I-. .
-. ._^I
~a~~~~~ USA Topics
Personal Exposure:
* Airport Security Scanning
* Cosmic Radiation During
Fl ig h ts
* CTScans
* Dental X-ray
@
Diagnostic Nuclear
Medicine
* Electric and Magnetic
Fields (EMF) Radiation
from Power Lines
* Lasers
* Mammography
* Medical X-Rays
* Microwave Ovens
* Radioactive Materials in
Antiques
Radiation in Tobacco
* Radiation Therapy -
External Beam
* Radon in Homes and
Buildings
* Sun Exposure
* UV Tanning Equipment
Wireless Technology
* more topics., .
Pr i Bf tcr Friend I ”rr v* TS i 0 H1
EMF (PDF)
(IPP, 128Kb)
[about pdf format]
- -r -_I-.-
---\
1998, an expert working group, organized by the National Institute of Health’s Nationar‘--.,
/ Institute of Environmental Health Sciences (NIEHS), assessed the health effects of exposure *..,
,‘ to extremely low frequency EMF, the type found in homes near power lines. Based on studies ‘\,
; about the incidence of childhood
--
leukemia involving a large number of households, NIEHS
-*-..*.._*C”P.---------s. .” ~ -E --.- *.- .r-_ ”_.-___
f found that power line magnetic
--
fields -,-. -..
are a ible cause of cancer, 7T-Z Wo-rXTnrg group also
i ~
4
- +
i c ~ ~ ~ ~ FeSuTrS ~ of ~ EM F ~ a n ima f I, c i % F, and - mechanistic (process) studies do not
confirm or refute the finding of the human studies. The International Agency for Research on
I
__ - *----
Cancer (WHO) reached a similar conclusion.
rr-3-Y-- I _I”_ - - _-- -*.c.w*c
-.a_.. ___-~__ __ I
Who is protecting you
---- ”^. 111 *_.-...-- nX^Z--^ .-a-
--.----)-c-.-L------=
__
# -- ^._..I
-*c
In the U.S., there are no federal standards limiting occupational or residential exposure to
power line EMF.
[I\\
http://www.epa .gov/radtown/power-lines. html

Electric And Magnetic Field (tMk) Kaaiation Trom rower Lines I
K ~ I U uwri uw
... raye L UI L
About seven states set standards for the width of right-of-ways under high-voltage
transmission lines because of potential for electric shock.
What you can do to protect yourself
People concerned about possible health risks from power lines can reduce their exposure by:
* Increasing the distance between you and the source - The greater the distance
between you and the power lines the more you reduce your exposure.
Limiting the time spent around the source - Limit the time you spend near power
lines to reduce your exposure.
Resources
Ca I ifor n i_a_ Electric grid Ma netkc. Fields Pros ra m EF!T@is;c@iw
2006 - California Department of Health Services.
This page is about find a rational and fair approach to dealing with the potential risks, if
any, of exposure to EMF.
(-
-
E I e ct ro m agn e t ic Fi ell&
2006 - World Health Organization (WHO)
This page provides information about electromagnetic fields, answers to frequent
questions, international research projects, and links to additional resources.
EMF QuestBns a.nd Answers
2002 - U.S. National Institutes of Health, National Institute of Environmental Health
Sciences
This document provides basic information about electromagnetic fields, health effects
research, existing national and international standards and recommendations, and
answers to frequent questions, and related links.

California Independent
System Operator Corporatior
FOR IMMEDIATE RELEASE
August 1,2006
Contact: Stephanie McCorkle
Director of Communications
1 (888) 51 6-NEWS
i
Conservation, Teamwork and Planning Helped California Grid
Weather the Historic Heat Wave of July 2006
Heartfiilt "Thank You" Extended
(Folsom. CA) The California high-voltage power grid is cooling off this week after handling
record peak demand last week when the mercun climbed above 110 degrees for three da!.s in a rom
throughout much of interior part of the state. The all time record peak demand on Monday. Jd:, 24 11 as
50.270 megawatts-an abnormally high demand at levels not expected until fi1.e years from noq. The
California Independent System Operator (California ISO) reports that electricity demand dropped this
u,eek to n.pical summer conditions. now that temperatures have moderated
The California IS0 extends a formal "thank you" to California for the impressive
conservation levels that helped keep the lights on and wholesale prices low during the historic heat
crisis of last week,
"We plan operations for extreme scenarios for a I-in-10 year heat tvave, but this \vas a 1 -in-SO
!.ear heat storm" said California IS0 President and CEO Yakout Mansour. "The public, joining tvith
business, was phenomenal in helping to reduce the strain on the power grid. Consenation pla>.ed a
critical role in maintaining stability of the grid and we want consumers, large and small. to understand
the importance of their contributions."
-.-". -\
------ ivlansour says the muscle that Governor Arnold Schwarzenegger put into championing 1.
/ \<
conservation helped the state achieve a conservation rate of at least 1.500 megawatts, lvhich included
general conservation, state water pump load reduction as well as a 25 percent reduction in potver usage
i
.')
-MORE-
SM/GF/08-01-06
Media Hotline: 888 516-NEWS

“43
HEAT STORM THANKS-2-2-2
The Fles Your Power organization was instrumental in moving the conservation message swiftly
and effectively via television and radio airwaves. Commercial customers that voluntarily reduce
demand on hgh demand days also did their part. Compensated for their curtailments, these customers
shed an estimated 855 megawatts just as California was setting the new sky-high record demand for
electricity on July 24. Additional business customers in the California ISO‘s Snve-A- Watt: Voluntary
Load Reduction Program also made a difference, producing about 50 megabFatts in power savings
lj\-ithout any form of compensation.
Despite the 100 degrees temperatures for more than 10 days in a row in the inland regions and
records broken along the coast, the California IS0 transmission system experienced not a single power
outage or blackout during the extraordinary heat.
Mansour noted that cooperation, communication and coordination among all sectors of the
energ industry helped the IS0 handle demand. “We planned this year for the worst scenario by holding
estensive summer training that brought the industry together to drill, drill and drill some more. Little
did ive kno\\-, the weather would be worse than the worst case scenario,” said Mansour. ”Fortunately:
Lvorst case weather did not translate into worst case results. Power plant owners responded to the
challenge tvell ahead of the season and prepared their fleet to withstand difficult conditions. In fact, u.e
saw the lowest summer outage rate ever last week. Utilities worked closely with us on load forecasting
and resource adequacy requirements and every energy agency in the state stood ready to assist us. We
n-ant to thank them all for the team spirit that was sho~i.”
The California IS0 is a not-for-profit public benefit corporation charged with managing the flow
of electricih along California‘s open-market wholesale power grid. The mission of the California IS0 is
to safeguard the reliable delivery of electricity, and ensure equal access to 25,000 circuit miles of
“electron highway.“ As the impartial operator of the wholesale power grid in the state, the California
IS0 conducts a small portion of the bulk power markets. These markets are used to allocate space on the
transmission lines, maintain operating reserves and match supply with demand in real time.
######
SMICM0801-06
Media Hotline: 888 516-HoFIs

Save Energy Now!
FOR IMMEDIATE RELEASE
Contact Stephanie McCorkle
(SSS) 5lWEWS
Rem a rka b le Conservation Effort
Callforria IS0 asks consumers Lo conserve one more cia? dunng the late
aftcmoon peak demand penod tomonon as thc heat wave concludes on Fnda?
"Regional hot temperatures drol c lug11 energ! deimnd in man! parts of
the West." according to IS0 Vice President Operations Jim Detmers Toda! 's
strong conservation efforts not oillj helped California avoid an electiical
eniergencj , we were also able to pro\ ide liniited emergenc) assistance to
ncighbonng control areas coping with high demand .'
The Callforria IS0 is esteiiding its declaration of a Flev Alert into
Fndq . August 31,2007 and is requesting that Callforrims continue to
conserve energj Energy conservation tips can bc found ar
Set thermostat at
78 degrees or
higher
Cool with fans
Draw the drapes
Turn off
unnecessary lights
and appliances
Use big appliances
in early morning or
late at night
24-Hour Ahead Outlook for Friday, August 31
California 1SO Declares a Fles Meiz Day
High temperatures are forecast to continue throughout the state and region. The
California IS0 is not anticipating an)- shortages: but demand is expected to be
high and Californians are urged to reduce energy usage. particularly during the
afternoon hours.
e Stage 1: possible Stage 2: uillikely Stage 3 unlikelj
Forecast peak demand: 47,950 megawatts around 1:OO pm.
Please monitor the California IS0 tvehsitc at ~ W Y ~ ~ . C ~ ~ for W . updated C ~ I
infomiation about the electricity supply. The Systems Co/7t/irin?7 page pro\*ides
the cunent demand onk Gnd and an bwby-lxmrfow of the day's elecirid
qludsb&fd is avadabt in Todq :s olltLw,-.

FLEX
ALERT
Save Energy Now!
‘M
bKis hr mclaim

A Decade of Underinvestment
15,000
13,000
rn
T3
a
11,000
.-
E 7,000
5,000
'90 '91 '92 '93 '94 '95 '96 '97 '98 '99 '00 '01 '02 '03 '04 '05
-Source: NERC Reliability Assessment RePorts *230-kV & Above
2

R&D Critical Needs
Dynamic modeling, simulation &
analytical tools
Devices to maximize the capacity of
the existing grid
The ability to control & direct the flow
of electricity
Hybrid DC & materials science
advances to expand the grid
7

PMUs Offer Wide-Area Visibility

R&D Top I00 in the World
SuperVAR

Proposed ORNL Superconductor
vs
Power Flow -+
vf?
e New cable designs, in conjunction with a 5%
Phase Angle Regulator (PAR), allows operators
to change power flows across a network
Power is controllable in both directions
e Lower-cost alternative to DC systems ,,
.. ....
10

From Silicon to Diamonds
Chemical Vapor Deposition of
Diamond (CVD) devices can
Carry 10 times more current
Conduct heat 4 times better than copper
Carry IO to 30 times the DC voltage
Operate at much higher frequencies
m
. I . than
conventional devices
11

New Designs for Existing ROW
u*.”omn* L.,
51 40 I
- :ii-- 6!
problems
DC allows much higher power
transfers over longer distances
with fewer losses
Hybrid designs have complex
problems - studies are
con t i n u i ng
Built over existing AC lines --very
little new right-of-way needed
-- -- -
- .
12

U.S. appetite for electricity is = Currently, the grid
steadily growing
Overburdened
P Driven by the internet and the
Too congested
proliferation of electronic devices
Antiquated
P Global demand for electricity is
The result is incre
growing at a multiple of the US. rate blackouts
As a result, new generation
investments have been on
the rise since the early 1990s
Meanwhile, our power grid
has been severely neglected
New aeneratina cawcitv
1930 1940 1950 1960 1970 1980 1990 2000
NARUC Conf. 2007

Half as thick as 1G & 2G wire made by other companies
- Total wire thickness is only 0.095 mm; twice the enginee *
Uses patented surround copper stabilizer
- No sharp corners - valuable for high voltage applications
Uses high-strength, non-magnetic, highly-resistive Hastell
- Better mechanical properties & lower h ac losses
0.1 mm 0
NARUC Conf. 2007

' AOOx power density of copper 1
lox transfer capacity of copper
cables
m
Green Technology
- More efficient
- Significantly reduced
transmission losses
Safer - no fires, explosions
Smaller footprint
Lighter
Security benefits
- Below grade
- Inside buildings
Aesthetics
Enhanced relia
Life cycle econo
B endofdeca
e x ective replacement for
copper!
NARUC Conf. 2007

v 2006 National Electricity Delivery Forum
Regional Transmission Organizations Part I

Buckeye Power, Inc.
Non-profit generation cooperative owned by
Ohio’s distribution cooperatives

m
BUCKEY
I - - 4
Demand Response
Ohio's cooperatives have 30+ years of experience with direct
load control. We can interrupt 30% of our residential
consumers' water heaters.

Demand Response

Transmission Expansion Analysis
Andrew Ott
PJM Vice President, Markets
May 31, 2007

Transmission Expansion Drivers
Expansion ordered by PJM because of
Reliability Violation
Expansion recommended by PJM based
on economics
Voluntary Investment
- Merchant generation interconnection
- Financial transmission rights
- Other property rights

Annual market simulations
Economic Expansion Analysis
Study Assumptions and Parameters
Base input assumptions regarding generating
unit characteristics, fuel costs, emissions costs,
load forecasts, etc.
Sensitivity analysis:
Metrics:
- High/Low fuel prices - Total Production “cost”
- High/Low - Transmission
demand
Congestion Cost
- High/Low future
- Load Payments
generation
(energy)
- High/Low - Generation Revenue
- Transmission Los

Economic Expansion Metric
1. Economic metrics are not as definitive as
reliability metrics
2. Provide Information to Market
Stake holders
3. Transparent Review of Results and
Assumptions
4. Stakeholder Discussion
5. Recommendation to Board
6. Recommendation to FERC

.
System Production Cost Savings
sociated with 502 Junction-Meadowbrook-Loudoun 500 kV Line
600.0
-Base
- -.~.
Assumptions
500.0
. ~
.
. . .. . -~ -. .....-. .- .
-. . . . . -. - . . ... . -
-High
Fuel Cost
- & = Low Fuel Cost
400.0
*High
Load
n
v)
c
0
I 300.0
.-
z
3
200.0
100.0
-.tHigh
Emissions
- r) - LowEmissions
-Base Assumptions -
GI
- + - Base Assumptions -
G2
- Base Assumptions -
G3
0.0
2012 2014 201 6 2018 2020 2022

System Congestion Cost Savings
sociated with 502 Junction-Meadowbrook-Loudoun 500 kV Line
1600.4
1400.C
+Base
-High
-_ - -
Assumptions I
Fuel Cost
I
1200.0
1000.0
/
... -. ..... .
.
. .- ..... - .
- . ... .......
I
L t- - - - - I
~- .~._ --
-+
600.0
c
0LL";L --. c
'Y c
' - - - m I m
c
..... ._-
-w
c
c
............. ..... . ..... -
-
-High
Emissions
= - LowEmissions
400.0
-+-Base
GI
Assumptions
200.0
+ Base Assumptions
G3
0.0 - I
I
I
I
i
Q1 Carbon Wder

PRODUCTION COST METRIC
8% Discount Rate 10% Discount Rate 12O/0 Qscount Rate
myear NPV Benefit 2,866.9 2,269.5 1,842.3
30-year NPV Cost (2,251.6) /I,885.4) /I,611.O)
myear Net Benefit 615.4 384 1 231.3
2C-year NPV Benefit 2,210.7 1,855.0 1,577.6
20-year NPV Cost (1,963.6) 11,702.7) (1,493.9
Byear Net Benefit 247.1 152.3 83.7
IC-year NPV Benefit 1,215.6 1,101.2 1,002.2
IO-year NW Cost 11,342.01 JI ,228.9) (1,130.0)
IC-year Net Eknefit (126 4) (127 7> (127.8)
Benefit NPV vs Cost NPV
(Energy
_ _
Market Benefits Only)
CONGESTION COST METRlC
8% ascount Rate IOYO Discount Rate 12% Discount Rate
13,386.2 10,732.9 8,818.9
12,251.6) /I,sSs.4) (1,611.0)
11,1M6 8,847.5 7,2078
10,622.3 8,986.0 7,702.7
JlS3.6) 11,702.7) 11 ,493.9)
8,658.7 7,283.3 6,208.8
6,188.8 5,623.8 5,133.3
11,342.0) il,Z8.9) /1,130.0)
4,8468 4,394.9 4,003 3
LOAD PAYMENT METRIC
8% Discount Rate 10% Discount Rate 12% Discount Rate
30-year NPV Benefit 19,306.0 14,858.8 11,731.3
30-year NPV Cost (2,251.6) /I,885.4) (1,611.0)
30-year Net Benefit 17.054.5 12.9i3.4 10,1203
20-year NPV Benefit 13,938.8 11,471.6 9,570.3
20-year NPV Cost (1,963.6) /'I, 702.7) (1,493.9)
Byear Net Benefit 11,975 1 9 768 9 8,0764
1 C-year NPV Benefit 6,562.5 5,896.2 5,323.5
10-year NPV Cost /1,342.0) (1,228.9) {I, 130.0)
1 &year Ne1 Benefit 5,220.5 4.c37.3 4,193.4
GUUERAllON REVENUE METRIC
8% Discount Rate 10% Discount Rate 12% Discount Rate
5,919.8 4,125.8 2,912.4
12,251.6) 11,885.4) /1,611,0)
3,6682 2,2404 1,3014
3,316.4 2,485.6 1,867.7
/I,963.6) 11,702.7) 11,493.9)
1,352.8 782.9 313. a
373.6 272.4 190.1
11,342.0) 11,228.9) I1,130.0)
(968.4) (9% 5) (9399)

Potential Beneficiaries
Relative benefit depends on location
Load - No Benefit
Constrained Transmission
I
Corridor
Generation -
No Benefit
Generation - Benefit
Transmission
Upgrade
Load - Benefit

" 2 6 "
& % 2
Large Scale Example
Market simulation made using GE MAPS model
Simulation of hourly security-constrained generation
dispatch over an annual period
Simulations made with and without an actual
Transmission upgrade
Cost of Transmission upgrade allocated based on
zonal power distribution factor for load beneficiaries
Change in Load Payments compared to cost
allocation
- ... .

-
Change in Zonal Load Payment due to R EP Upgrade
Simulation Results
+$
increase
in i- I
I
0
1
- .
-. .
.... - . ~ ~. - - .~
.... - .... - ... _.- -
- - -- ...........
. . . .. ........ ... .. ......... ..-- -- ~
~- ~
.- - . _- -..
- --- - -
--1-
ne9 Zone Zone Zone Zone Zone Zone Zone I
- _ _ 10
11 12 13 14 15 16
..... -- - - - ~ . .
- ...... ................
..............................
I
.- . - - - . - .. - - - - .- - - ..
. .-
-$
decrease
in
payment
t
J
..... . - .
. . . . . . . . . . . . . . . . . . . . . .
..........
-.
.-
....... -I

......................
~ -~
in %
50.0
Simulation Results (cont.)
Zonal Share of Total Savings (%)
vs -
Zonal Share -_ ~-- of I
x. ."
-
45.0
. - ...........
~
... __
40.0
. . . . .... .........
35.0
30.0
25.0
- - . . _ - - - -
__
_
_.
Note:
-(I) Zone 12 showed an increase in energy payment but
was assigned a small share of upgrade cost
(2) five other zones showed an increase in energy
payment but were not assigned share of upgrade cost
20.0
- .. - __ -
-- ___
15.0
-_ .-
10.0
- -_ -
5.0
. ...... ....... - ................ -
0.0
Zone 1 Zone2 Zone3 Zone4 Zone5 Zone6 Zone7 Zone8 Zone9 Zone 10 Zone 12
8% of Total Energy Payment Decrease .%of
Upgrade Cost]

0 bse rvations
Difficult to justify large scale upgrades based
solely on economic benefits
Economic metric will evolve as validation
andlor reason to advance reliability upgrades
PJM economic expansion metric likely
reduces merchant incentives
Incremental Rights created by upgrades
should be allocated to customers or zones in
proportion to cost allocation
1
I

Demand Response:
The Other Side of the Market
2006 N ional Ele ricity Delivery Forum
gton, DC
February 16, 2006
Richard E. Morgan
Commissioner
Public Service Commission
of the District of Columbia

A few thoughts on
demand response
r
i
55
50
45
0 DR is an essential
Qnandry
component of a
competitive electricity market
0 A challenge to traditional utilitv
regulation - both retail and wholesale
0 A little DR goes a long way
0 An idea whose time has come!
Q 10 20 30 40 50 60 70 80 90

Potential benefits of demand
response
Operational savings
U Reduced generat
market
U Lower arket prices
Reduc price volatility
Improved grid reliability
Improved customer options
0 Provision of ancillary services
Positive environmental benefits

Barriers to
0 Traditional retail rate
designs that blend
costs & dampen price signa
0 “Fractured value chain” in unbundled
competitive markets

September 10,2007
Incentives Prove Powerful
As summer enters its final phase, programs that push for, and
increasingly reward, reduced electricity use by companies and other
users are showing results.
Utilities and grid operators are reporting a surge in participation in
programs that encourage customers to turn off inessential
equipment, shift schedules or take other steps toward greater energy
efficiency. That is especially the case in states that have made
conservation a central pillar of energy policies aimed at controlling
greenhouse-gas emissions and restraining energy costs. The success
could result in an expansion of such programs in a time of
tightening electricity suppl~es.inSQme.-pl.a~~~, though an especially
. _-CY.
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hot su- coming years could provide a teit:- **-+ -r-.
-.*\
-.-
Name
/

...--... I. VY, ,““Y I uvvcIllul - V V ~ d . L U I I I Page 2 of 3
or utilities and help them automatically go into energy-saver mode. EnerNOC Inc. of Boston,
which went public in May, had 1,852 locations signed as of June 30, more than triple the number
the prior year, giving EnerNOC 756 megawatts of customer load under management, up from 234
megawatts.
One participant is Stop & Shop Supermarket Co., a unit of Netherlands supermarket giant Ahold
NV. The chain is able to cut energy use by 40 megawatts when asked, an amount of power equal
to the output of what is known as a peaker plant ”. that otherwise might be fired up to meet high
demand, through various measures.
. --
/-
*I At Exelon Corp.5 Commonwealth Edison Co., Chicago, 2,173 business locations have signed up
f
for utility programs this year in which they, collectively, are paid to cut use by 647 megawatts.
That compares with 22 sites totaling 25 megawatts last year. Customers decide when to cut energy
’
use. not utility or grid officials, and it is often based on the market price of power they will
L e c e . */+c
~-~---.--“~,..~*.-,~.-~-nl_-g-
_-
___c__~L_ II_ nrnl
.)_ *,.“.-.-,e-
I- ---e@--
Some firms shift production to times when power costs are lower or ratchet back lighting and air
conditioning.
“Customers are becoming much more energy conscious,’’ says Sharon Hillman, vice president of
marketing and environmental programs at ComEd that soon will have one of the largest “demand
response” programs outside of California.
In the Midwest and mid-Atlantic states, a slew of programs has attracted the participation of
scores of firms with the promise of rewards. Big energy users cut electricity usage by nearly 2,000
megawatts on Aug. 8, a day when supplies were stretched thin in the multistate area where power
flows are managed by PJM Interconnection LLC.
The conservation effect in California looks like the strongest since 200 1, when the state had
rolling blackouts because of power shortages and illegal market activity. In the aftermath of that
crisis, the state encouraged construction of more gas-fired power plants and renewable energy
resources. That effort has been superceded by a policy that seeks to offset market growth by
giving consumers tools to cut use, in some cases by replacing inefficient older equipment,
installing smart controllers or changing patterns of use.
The ability to change usage, typically away from high-priced or grid-stressed periods, is called
“demand response,” and it is especially important because California is introducing a new method
for pricing wholesale electricity in April 2008, capping an eight-year market-overhaul effort. The
Federal Energy Regulatory Commission, which oversees wholesale electricity markets, has urged
state officials to help users gain influence in the market, not just as consumers but as those who
can put off or eliminate consumption.
Grid officials are finding that it pays to have a variety of programs in the field. The California
Independent System Operator, which runs most transmission lines in the state and reports to
FERC, has arrangements in place that give it 2,300 megawatts worth of customer demand it can
call upon in an emergency. But it wants to develop a capability to tap an even larger universe of
companies and not just when there are emergencies but as a counterweight to high prices.
The Cal-IS0 has set up a Demand Response Lab to study the best technologies available. It would
like to have a vast cadre of energy users able to cut consumption as easily and quickly as

006?
Energy demand continues to grow
0 Higher energy prices than seen for
decades
0 High energy expenditures
0 Reliability issues
0 Capital expenses for generation,
transmission and congestion relief
Investment risk associated with
climate change
0 Security concerns
I) Energy Efficiency is a costcompetitive
solution
More than 10 years of experience
Stable price
Have not reached diminishing returns
Total Energy Consumption by
End-Use Sector 1949-2004
m 40
25
/ Commercial
1949 1959 1969 1979 1989 1999
Year
Growth in U.S. Electricity and Natural
Gas Consumption, 1949-2004
-
9 20 Natural Gas
t
-
U) 15-
e 10-
B
E lectr ioity
1949 1959 1969 1979 1989 1999
Year
Sources: EIA Annual Energy Review 2004
I I
4
E
(P
2

Economic Benefits for Energy Efficiency
0 Lower cost compared to new generation and transmission
e Downward pressure on natural gas prices and volatility
Lower wholesale electricity prices
Improved local economy and service to low income and seniors
Utility System Benefits
Near-term fix with persistent, long-term benefits
Improved security of electricity and gas systems
Improved resilience due to lower reliance on fossil fuels
Lower baseload and peak demand
Reduce need for “hard to site” G&T assets
a Targeted, modular, manageable
0 Environmental Benefits
Lower greenhouse gas emissions and criteria pollutants
Lower water use
0 Risk Management Benefits
Diversifies utility resource portfolios
3

ector Contributes a Third of
missions
0 Energy efficiency provides substantial environmental
benefits while creating economic benefits for customers.
US. Greenhouse Gas Emissions by Sector in 2002
(Total = 6,888 MMTCOZE)
Residential
5.6% 1 Pgriculture
8%
U.S. Greenhouse Gas Emissions by Sector
with Electricity-Related Emissions Distributed
in 2002 (Total = 6,888 MMTC02E)
Trans portation
27.0%
Sout-r- U.S. Greenhouse Gas Emissions and Sinks: I v ~ - 2002, Tables 2-6 and 2-8
27%
4

Established energy efficiency as reliable, low-cost resource
* Real programs with real results
0 Programs delivering efficiency at 2 to 4 cents / kWh
Established large potential to meet new demand
Regionally, nationally
* Real programs
Can help control load growth by 50% or more
Established measurement and verification procedures
Savings are real, persistent
0 Integrated into resource planning
0 Established model energy efficiency delivery programs for key
customer classes
0 Residential -- commercial - industrial
0 Low income
Gas / electric
New I mature
5

~~
iency is Cost Competitive
loo PI--
80 - ~
i Y 5
60
Capital Costs
Variable Costs (incl Fuel)
----
I Fixed Costs
1ncr.Transmission Costs
40
20
0
1
Natural Gas
Sources: EIA 2004 “CEEE 2004
6

-
i'ciency Can Help Control
rowth
U.S. Electricity Consumption Projections
c 5,m
X
c 5,000
0
E
- AEO 2005 Reference Case
-
ill Half Growth Scenario
5 Labs Study
111 ACEEE median achievable
--3 szI?W-7IPu
NV Study
NEEP Study
[avg. annual growth l.8Yo]
(1 7% reduction by 2025) [avg. annual growth 0.9O/0]
(18% reduction by 2020) [avg. annual growth 0.6O/0]
(24% reduction in 20 years) [avg. annual growth 0.5?40]
(22% reduction by 2020) [avg. annual growth 0.3Y0]
(17% reduction by 2013) [avg. annual growth ~ 0.1 YO]
Sources: EIA AEO 2005, ACEEE, SWEEP, NEEP
7

-
ciency Funding Has
er Last Decade
A nnual Spendin Utility Sector Energy
Efficiency rams 1992-2002
005 dollars)
- ~
__-----__ _-_ __lll__II-___
v)
5
= $2.0
0
U
v)
R
-
g $1.5
L
v)
.- 0"
-
.-
E $1.0
.c)
S
4d E"
- 2
$0.5
$0.0
1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Year
Sourco: Data from ACEEE 2005 Scorecard adjusted for inflation using
US. Department of Labor Bureau of Labor Statistics lnflatior e Tlculator
8

Energy Efficiency
Z2r
* Utility financial incentives
Throughput charges create direct disincentives for utilities to sell less
e Utilities do not earn the same rate of return on energy efficiency like
generation, transmission, and distribution
0 Utilities may not be ensured cost recovery or shareholder incentives
Customer rate structures provide delayed reaction by customers
Company policies
Employees rewarded based on capital investment
Resource planning
Planning does not incorporate demand-side resources
0 Misperception that energy is not a reliable resource
Full value of efficiency not considered, including reliability, environmental,
risk management and economic benefits
0 Lack of awareness on program best practices
9

Issues
0 Traditional end-user barriers
Lack of information
Competing vendor claims
Split incentives
State decision-makers
Lack of good documentation on
clean energy policies
Little integration of air / energy
issues
Utility barriers
Existing electricity regulations /
market rules incentivize supply-side
resources
0 View that ener y efficiency is not a
reliable, cost e 9 fective resource
Concern that energy efficiency will
raise rates
Lack of good documentation and
education on demand-side programs
0
0
0
0
EPA Efforts
Engage interested PUCs in
innovative policies
EPA - NARUC Projects
AR, CT, DC, HI, MN,
NJ, NM
Engage utility, PUC, and
related stakeholder leaders
under the Energy Efficiency
Action Plan

Y STAR
0 ENERGY STAR is a cost-effective platform
Helps lower program administration costs
Reduces start-up time
Provide valuable lessons learned 1
Provide access to a network of partners
I
0 Partnering with Key Market Players I
Major Manufacturers and retailers
Utilities / system benefits charge administrators
States -- 30 partners
0 Broad national platform for EE
Residential - Commercial
- products - 40+ products
- existing home retrofit existing buildings
- new homes new buildings
National recognition -- 60% of public
h ~ tp://w~~. en erg ys fa r. go v
11

0 Goal
cy Action Plan
0
To create a sustainable, aggressive national commitment to energy
efficiency through gas and electric utilities, utility regulators, and partner
organizations.
Leadership Group
Utilities, regulators, energy directors, consumer advocates, NGO’s,
industrials, and others
OOEIEPA facilitated
0 Expected Outcomes
Documenting business practices / solutions for overcoming barriers limiting
utility investment in energy efficiency
- Removing disincentives / providing incentives
- lntegrating EE into utility planning
- Examples of EE programs that work
- Tactics that help EE succeed
Communication strategy for spreading practices / solutions
A network of experts and resource materials on energy efficiency practices
http://www. epa. gov/cleanp wrgy/eeactionplan. htm
12