Dueling reports

by James A. Bacon

How do citizens know whom to believe in the debate over the Atlantic Coast Pipeline (ACP), a proposed 550-mile natural gas pipeline between West Virginia gas fields and markets in Virginia and North Carolina?

Dominion, managing partner of ACP, has commissioned studies from Fairfax-based ICF International, a technology and management consulting firm, and Chmura Economics & Analytics, a Richmond econometrics firm, to analyze the pipeline’s economic impact. Both  reports buttressed the utility’s case that the project would be overwhelmingly beneficial.

In “The Economic Impact of the Atlantic Coast Pipeline,” ICF concluded that over the next 20 years Virginia and North Carolina could expect to gain $377 million a year in energy cost savings,  2,200 permanent full-time jobs, $131 million in annual labor income, and $218 million in annual gross state product. Likewise, in “The Economic Impact of the Atlantic Coast Pipeline in West Virginia, Virginia, and North Carolina,” Chmura said the project would inject $456 million annually into the three-state economy between 2014 and 2019 and support 2,873 jobs.

Yesterday the Southern Environmental Law Center (SELC) and the Allegheny-Blue Ridge, which oppose the pipeline, released its own report. That document, “Atlantic Coast Pipeline Benefits Review,” prepared by Synapse Energy Economics Inc., out of Cambridge, Mass., contends that the alleged pipeline benefits are “overstated, lack sufficient supporting data, and fail to account for environmental and societal costs.”

The Synapse report doesn’t make any economic forecasts of its own; rather, the authors point out limitations and weaknesses in the Dominion-sponsored reports and enumerates negative impacts that those reports did not take into consideration. Among the criticisms:

  • Assumed differential in gas prices. ICF argues that gas from Marcellus shale in West Virginia and neighboring states, to be transported by the ACP, will be cheaper than so-called Henry Hub gas from the Gulf Coast, which Virginia and North Carolina consume now. But Synapse questions whether that price differential will last.
  • Assumed savings to electric customers. ICF assumes that cheaper natural gas prices will be passed to Virginia consumers as lower electricity prices. But due to the nature of inter-regional power sharing, Synapse says is it unclear whether those savings would be passed on to Virginia consumers or shared regionally.
  • Assumed job creation. ICF assumes that Virginia consumers will spend that energy savings, stimulating local economic activity. But “the study did not provide any underlying data to support this claim,” says Synapse. “Critical inputs and assumptions — such as the assumed direct energy savings by sector — are necessary to satisfactorily review this finding.”
  • Are permanent jobs really permanent? The ICF study estimates that 2,225 jobs will be supported over 20 years (for 44,600 total job years). But the study doesn’t break down the impact year by year, so it is impossible to know if the jobs are sustained over time or if they start strong and dribble out over time.

Synapse also argued that ICF and Chmura failed to take into account negatives such as the pipeline impact on property values, damage to wildlife habitat and clean water, and the risk of accidents.

The SELC report holds ICF and Chmura to a high standard — it insists that  consultants provide sufficient detail in their data and assumptions to allow third-party review and verification, and that studies be more transparent with their numbers. “In an economic jobs and benefits analysis,” Symapse says, “a complete set of modeling assumptions, inputs, and outputs” typically would be included.

ICF stated that it based its analysis upon years of experience in North American natural gas and “proprietary software tools and databases,” including its Gas Market Model and Integrated Planning Model to model the North American gas and electric markets with and without ACP.

Dominion stands by the ICF and Chmura numbers. Unlike Synapse or SELC,the company has skin in the game. It seeks the best forecasts it can find because it bases business decisions on the data. The utility uses ICF’s commodity price forecast for the Dominion Virginia Power Integrated Resource Plan and other regulatory filings. The company also uses ICF for its own internal business deliberations, says Jim Norvelle, director-media relations for Dominion. “It is safe to say there are significant business decisions made using the ICF International forecast.”

“ICF International and Chmura are internationally known and respected firms,” says Norvelle. “Their findings quantify what is obvious and undeniable: the Atlantic Coast Pipeline will bring significant financial and other benefits to the residents and businesses of Virginia, West Virginia and North Carolina. It is Economics 101. More natural gas supplies mean lower prices, more money available for investment, better reliability and cleaner air. Just plain common sense.”

Bacon’s bottom line: Synapse makes a good point: Consultant studies should be fully transparent, providing sufficient data and articulating their assumptions for third parties to critique them. But what’s sauce for the goose is sauce for the gander. When SELC and pipeline opponents make assertions about the pipeline’s economic and environmental effects, they need to abide by the same standards they demand of Dominion. They, too, need to lay out their facts and assumptions for public scrutiny.

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  1. LarrytheG Avatar

    Why would ANYONE believe ANY “study” paid for by the organization that wants the pipeline to start with?

    It’s an inherent conflict and as SELC points out – full of issues .. which should not shock anyone.

    If Dominion wanted to really impress me – they would FUND an INDEPENDENT Study done by an unaffiliated third party… and the process would INCLUDE – answering questions posed by the public and SELC.

    Such a study would also have – for the unknowns – the best case AND the worst case scenarios… so folks know the scope and range.

    One might ask why this approach is not the standard required by the SCC and FERC to start with.

    You know – SELC – is more often than not – simply about honest disclosure of costs and benefits.. that’s their primary objection whether it’s PPTA or Pipelines – they want MORE disclosure, MORE transparency and HONEST analyses…

    Dominion has choices on how to proceed – one of those options is to do something along the lines of what the SELC is advocating.

    I’d be much more supportive of the proposal if Dominion chose the Honest Abe path and when they don’t .. oh well.. disappointed but not shocked.

    1. LarrytheG Avatar

      yep. I no longer consider Chmura a truly independent and objective player – either.

      My perception, like Peter’s is that she’s a little too cozy with her clients.

      1. Cville Resident Avatar
        Cville Resident

        Absolutely. I don’t trust any Chmura report.

        1. LarrytheG Avatar

          I think SELC is asking legitimate questions and I think those questions can be legitimately address by a 3rd party expert – and I think it is incumbent in the public interest that it be done – pro-forma.

          In my view, Dominion makes it’s own problems some times. They could do a better job of earning the trust – of those who have questions.

          You know who they remind me of – VDOT… same posture…

  2. Steve Haner Avatar
    Steve Haner

    If you are looking for an independent review, well, that is what the Federal Energy Regulatory Commission (FERC) is supposed to provide, and I assume will. If this were purely inside VA, it would be the State Corporation Commission. I would be confident the SCC would stick to the facts and do their own analysis (or hire that independent expert). I don’t know much about FERC.

    In both cases, the economist studies are for public relations purposes. Right now the pipeline has a public relations problem – the engineering either works or it doesn’t. I’m sure both firms are highly honest and reputable and answered the questions they were asked, and it is still true if you laid every economist end to end you could not reach a conclusion.

    But the bottom line is pretty simple and does reflect Econ 101 – more supply translates into either stable or lower prices, and certainly translates into, well, more supply. So if some mega industry coming to an area served by the pipeline needs a major feed line, it can be done. Coal is dead. Burning oil for power is dead. Nukes scare the beejeesus out of the uninformed masses and are pricey. Solar and wind remain subject to the unpredictable weather. Natural gas is the path of least resistance.

    1. TooManyTaxes Avatar

      You also need some public/interest group access to the review/hearing. In the old days, there would be an actual evidentiary hearing before a hearing examiner or administrative law judge. Parties would have access to some discovery (generally on paper only); the right to put on their own witnesses; and to cross-examine other parties’ witnesses. But even in a “paper hearing,” it’s possible to probe, challenge and rebut the other side’s positions.

      A hearing doesn’t guarantee anyone will necessarily win, but it does test the arguments made by everyone.

    2. LarrytheG Avatar

      I guess I still feel that supply/demand projects acquire right-of-way via willing seller/willing buyer.

      once you cross the line into eminent domain – you’re left the pure supply/demand world and entered the public necessity and convenience world.

      You apparently do not agree.. as not sure I’ve ever heard you directly rebut or agree…

      have you a view?

      1. TooManyTaxes Avatar

        Larry, as I’ve said many times, a pipeline that directly or indirectly serves all reachable customers in a service territory is a public utility operation that has access to (and should have access to) eminent domain. A pipeline that is used for private purposes, including export, should not have the ability to condemn property. I don’t see what this has to do with the importance of testing all evidence with some type of hearing before the VSCC or FERC as appropriate.

        1. LarrytheG Avatar

          TMT – who is presenting the extraneous evidence to start with? Isn’t Dominion the one claiming it’s economic benefits – without, as far as I can tell, disclosing if none of it will be sold for profit?

          I think SELC weighed in – in response to Dominion, no?

          1. TooManyTaxes Avatar

            People and entities can and do say anything for the media. What counts is what is presented to the permitting authority(ies). If Dominion’s allegations are questioned, they should be challenged before that/those body(ies). Challengers can often file their own studies, expert testimony in opposition.

            It’s like a cell tower. People whine and whine, but if you have permissible reasons to challenge it, you need to go before the Planning Commission and BoS/City Council.

          2. LarrytheG Avatar

            I guess we agree TMT – than any parties to a proposed action should be able to submit information for the record – and that would included challenging other info submitted… and yes.. they’ll play in front of the public court of opinion also.

            Every time the EPA proposes a rule – it’s wide open to all parties to participate – and the reality is – over the years and decades – most proposals – do get modified but they also do go forward.

            I think people forget – take for granted – all the rules that have been implemented that people not only don’t have a problem with – they actually are glad the rules is in place… for air and water quality, toxics, pesticides, etc.

            Most serious challenges to the rules – often come from organizations who basically question the basic purpose of EPA – to exist as a regulatory body – and they basically want to use the proposed rules as a political cudgel to damage the EPA to be able to perform it’s basic mission.

            This is why you hear over-the-top dialogue about closing them down, abolishing them, their “anti-human” goals.. etc.

            and this did not start with the CPP .. it’s been going on for all the years the EPA has been in existence.. whether they were talking about lead in gasoline, or banning pesticides, or Superfund or CSOs, there have always been critics who question their authority.

            If the EPA went away – this country would revert to 3rd world environmental conditions.. there is no doubt… people would again start dumping toxics in the air and water.. people would be dumping motor oil in storm drains… etc.. everything you see done in 3rd world countries and China would start back here.

  3. Peter Galuszka Avatar
    Peter Galuszka

    In the ned, product pricing will likely be the deciding factor. That’s what killed a proposal to mine uranium in Southside. Uranium prices globally were just too low to make it work.

    1. Interestingly enough, in comments submitted to the EPA, SELC refers to research it commissioned from…. ICF. From those comments:

      “SELC contracted with ICF Resources, L.L.C. (“ICF”) to provide analytic support to illustrate and quantify some of the potential impacts of the CPP proposal in Virginia. ICF reliedvon the proposal itself and the technical supporting documents published by EPA to evaluate the following impacts: compliance costs, carbon reduction benefits, ancillary emission reduction
      benefits, rate and bill impacts, and economic and employment impacts.”

      1. LarrytheG Avatar

        I would assert that for ANY – proposed rule from the EPA – that we all – WANT other parties – ALL Parties – to provide analyses..that will then be added to the body of knowledge for the proposal – to sort out contradictions and inconsistencies of the propose rule – as well as some of the competing analyses.


        I prefer this to politics of demonization and arbitrary decisions with no basis in facts no matter who is running the govt.

        1. TooManyTaxes Avatar

          Under the Administrative Procedure Act, any agency that proposes new rules must provide notice and opportunity for public comment (informal rulemaking). If the underlying statute requires rules to be made on a record, a hearing must also be provided. A agency that plans to change its position, including making stricter rules, must clearly explain why it is changing directions and why changed facts (not a different view of the law) necessitate such a change.

          While it’s not alone, the EPA sometimes skirts these obligations. Right now the Enforcement Bureau of the FCC is regularly skirting the law. But it looks as if AT&T is going to mattresses to challenge (what I think) is lawless action by the Bureau.

          The APA is designed to protect against an agency setting itself above the law and protecting citizens against arbitrary action.

          1. LarrytheG Avatar

            well judging over the years – it appears that EPA usually proposes a rule and has a formal process for receiving and responding to comments, challenges, etc.

            I do not see any agency that occasionally gets successfully pushed back – as any more “lawless” than industry that also pushes the limits of what they are allowed by regulation. It’s an inherently adversarial process that ends up with the govt trying to get what they feel is needed and industry trying to evade as much as they can.

            Given all the damaging impacts to the environment we have seen in the years since the inception of the EPA, more than a few claim the EPA has actually failed to keep the environment from being damaged.. in some cases irretrievably… note the Superfund sites that are not only taken off the tax roles but taxpayers have to spend billions to remediate .

            Some folks are pre-disposed against the EPA from the get go as they consider any/all regulation as harmful to economic interests and they oppose any/all regulation no matter what.

            You’ve said EPA got rebuffed on storm water in Fairfax – and yohu’re correct although – from a common sense point of view pollutants in stormwater or really no different than pollutants in other water.. but so be it.

            but I’d bet you’d be the first to complain if the EPA was not regulating wastewater or drinking water… or toxic emissions that affected your neighborhood… etc..

            In other words – as you criticize the EPA – you’re also depending on them.

            that’s where I speak from – somewhere in the middle where I do recognize that important protections that we all value are the result of the EPA – even as some of us think they’re going too far.

            and let me also point out that 10, 20, 30 years ago – we had the same conundrum – people were saying that the EPA had no businesses messing with CSO… that there was no way to reasonably fix them and EPA was costing people billions of dollars. The same thing with unleaded gas, DDT, Dioxin, urban air quality, etc.

            but I also had one more question for you on hearings… of the BOS kind.

            do you know which decisions require hearings and which don’t in terms of general criteria? I’ve asked around including the County Lawyer and I get the impression they’re not entirely sure… they cite no codes.. any ideas?

            why – for instance – do rezones require hearings?

  4. LifeOnTheFallLine Avatar

    “The Synapse report doesn’t make any economic forecasts of its own…”

    “When SELC and pipeline opponents make assertions about the pipeline’s economic and environmental effects…”

    Since they didn’t do that, what’s your point here?

    “Dominion stands by the ICF and Chmura numbers. Unlike Synapse or SELC,the company has skin in the game.”

    The past decade of corporate malfeasance has proved that “skin in the game” is no longer a proxy for anything useful. Plenty of people had “skin in the game” when it came time to build and operate I-895 and they still looked at the numbers they wanted to see and it still ended up being a miserable failure.

    1. LarrytheG Avatar

      I don’t think the opponents primary opposition is that it won’t deliver as much economic benefit as promised.. they’re opposed to the way that Dominion has gone about doing it and now Dominion is using an old traditional tactic to essentially say the opponents are holding up progress.

      That’s what they paid for in the analysis.

      The opponents are questioning the way Dominion has gone about laying out the route – and their treatment of landowners and people who have questioned their approach to doing that.

      And it’s as if Dominion (and the GA who wrote the enabling law) – never heard about Kelo….

      Dominion feels that they are free to lay out the route – it’s their prerogative and that people and landowners who oppose them “don’t know the law” that Dominion is “entitled” to use.

      Remember this is report is also after they compiled a huge list of “supporters” – also – again ignoring the central complaint.

      Dominion feels they do not have to justify where they want to put the pipeline – whether it uses existing rights of ways – where it truly can or just rely on eminent domain where it cannot.

      I think Dominion would have been a whole lot better off if they had paid a company that specializes in finding the least objectionable route and had a goal of 90% voluntary acquisition where there was conflict.

      “skin in the game” is an odd characterization… this is not like Dominion or it’s hired guns are themselves only ancillary parties to an action by others.

      they are the primary actors… of course they have skin in the game. Why would anyone view them as some kind of interested third party “with skin in the game”?

      If this pipeline is not solely for the public necessity and convenience – then the folks whose land it goes over might feel as essentially unwilling investors – being divested of their assets.

      We’ve had this whole big political tumult over “property rights” the last few years and it’s like no one remembers.

      Right now – in Charlottesville – VDOT is being sued over right-of-way acquisition for Rt 29. In Norfolk – a College is condemning a businesses next door to it…

      This is a loser of an issue for Dominion – there did not need to be this level of controversy… We have dozens of existing pipelines that have been built and who can remember this level of controversy when they were built?

  5. I’m late to this party but there’s one thing here that should not go unchallenged. The Synapse study plainly misunderstands PJM’s energy market and therefore misunderstands the benefit to Virginia customers. Synapse’s entire discussion of this point follows:

    “The study’s method of allocating electric savings to Virginia customers from the ACP is inadequately explained and seems unlikely given PJM market dynamics. ICF estimates projected natural gas savings for direct gas customers and pass‐through savings to electricity customers due to lower natural gas plant generating costs. ICF appears to assume that lower natural gas prices would mean that Virginia utilities’ cheaper electricity would—due to the state’s membership in the PJM capacity and energy markets—suppress energy prices throughout the PJM region by $0.94/MWh over the analysis period. [fn8] ICF expected price suppression would seem to require that Virginia natural gas plants are on the margin in PJM (i.e. set the regional wholesale electric price) for a significant share of hours in a year. PJM includes part or all of 13 states and the District of Columbia. A reduction in generating costs for natural gas power plants in Virginia may have a small impact on wholesale costs for the entire region to the extent that the marginal price of energy is reduced. However, since Virginia generators are serving load throughout the PJM region, any price suppression would affect the region at large, and not be captured by Virginia customers alone. It is unclear if ICF allocated savings across the PJM region or assumed that any savings in Virginia power generation would only affect Virginia customers. If it is the latter, the study’s economic impacts on Virginia are significantly overstated—even after assuming that ICF’s price spread materializes.”

    The wholesale PJM electric energy market is priced moment-to-moment at the locational marginal price — that is to say, roughly speaking, at the operating cost or “running rate” of the marginal generating unit operating in PJM for its energy output. Buyers pay that rate, and sellers are paid at that rate, adjusted slightly for locational losses. Synapse is correct that the “small impact” on market prices in the PJM energy market from any Dominion natural gas units operating at lower cost due to ACL pipeline gas supplies would “affect the [PJM] region at large and not be captured by Virginia customers alone.” But Synapse ignores the biggest impact on Dominion’s customers, which is, they would receive the difference between PJM’s region-wide energy market clearing price and the lower cost to Dominion to operate these units. Dominion is not just a market buyer for its customers but also a market seller as the owner of its generation, and as the seller of cheap energy from these natural gas-fired units, Dominion would make a profit on the sales that would go directly to all Dominion customers through Dominion’s Fuel Rider. True, this would go to all Dominion customers not just those located in Virginia, but that’s still a small subset of PJM’s total customer load. In short, energy price suppression across the entire PJM region is just a small part of the ACL line’s benefit to Dominion’s customers here.

    1. LarrytheG Avatar

      ON the PJM aspect. If power plant operators in other states that feed PJM also have frack gas generation plants – and they are closer to the shale gas – would they not be able to supply cheaper electricity to PJM than Dominion which has significant pipeline transportation costs?

      I’ve been wondering all along why Dominion or any other utility would not locate their generating plants close to where the gas is extracted?

      why would Dominion move that gas several hundred miles to a plant in Southern Va – to then potentially generate electricity to send elsewhere – perhaps to locations back toward where the gas came from or at the least to locations themselves closer to where the gas originates and can be used for generation?

      Dominion really is going to move gas hundreds of miles to generate power that goes into PJM?

  6. That’s a very good observation. You can, of course, move the gas, move the power plant, and/or move the electricity, any or all of which will get the customer delivered electric energy from Marcellus Shale. That is in effect what Amazon is doing by generating from solar in Accomack, delivering (via PJM and Dominion) to Loudoun, and claiming that its data centers around Ashburn are therefore “green powered.”

    Dominion in fact already owns generation as well as big electric transmission lines in the Shale region. So why build new gas fired generation in eastern VA and NC rather than simply transmit the electricity from the Shale fields? I can’t speak for Dominion of course, but I suspect it’s a reliability issue. You see the electric grid is unstable unless you have OPERATING generation widely dispersed across all parts of the grid, particularly near where the electric load is concentrated. Dominion, for example, has a few antique, high-cost coal plants in Hampton Roads that are its only source of generation down there, and even though they are higher cost to operate than the PJM market price, Dominion tells PJM to “must run” these units when needed for system reliability/stability reasons. Now the EPA wants to shut them down completely, or let them run only at such a higher cost that it isn’t worth it. This is one of those infrastructure things where the obvious long range solution has been clearly identified for some time, build more-modern, efficient generation near Hampton Roads, and the existence of those old coal units has allowed Dominion to put that solution off, but now it’s ‘times-up.’

    Now I’m not saying that is the sole driver of this gas pipeline project, which appears to offer a number of other, very different economic opportunities, but this could explain why Dominion needs the new gas-fired generation now in that particular portion of Virginia. They may also figure, as you have surmised also, that with the forecast development of solar and wind power in the flat-lands and coastal areas of the mid-Atlantic they need NGCC (natural-gas-combined-cycle) units in the eastern part of the Dominion system in particular to provide relatively quick-start, relatively economical-to-run generating units to back up all that ‘renewables’ power when it’s not available due to the weather etc. Coal couldn’t fill that bill even if the EPA wasn’t a factor. Take a look at where the renewables gen. already announced is going to be located: http://www.pjm.com/renewables/default.html [NB: map does not load in IE, only Firefox for some reason, and may take a long time to load at all].

    1. LarrytheG Avatar

      Thanks.. it don’t want to load in chrome either.. and still waiting on Firefox but it does show the PJM region of what only a small part of NC is part of… curious… and the rest of NC is not a member of any regional transmission organization.

      I keep getting different viewpoints of how much gas there is -.. how long it’s expected to last – and in turn the predictability of cost – but I am truly amazed at just how much a modern combined cycle unit costs – a billion here and a billion there and we talking about real money!

  7. I’m no expert in electric grids, but my sense is (a) Dominion can’t just purchase large volumes of electricity off the PJM grid; it has to contribute electricity as well, so it’s not off the hook for building new capacity; and (b) if Dominion is buying and selling large volumes of electricity off the PJM grid, it has to build the capacity for wheeling the electricity — in other words it has to build or expand electric transmission lines. As much as people hate gas pipelines, they hate electric transmission lines more.

    1. LarrytheG Avatar

      I don’t think people hate pipelines per se. If you look at any map of Virginia or the US for that matter – including the Rockies Express Pipeline a 1600 mile pipeline built less than 10 years ago – what kind of controversy did we hear?

      I think if you build the pipeline/power line without relying primarily on eminent domain – there is a lot less controversy… there will be some hold-outs but you won’t end up with the whole thing turning into something perceived as David vs Goliath..that draws even people not directly affected into the issue.

      here’s how the 1500 mile Rocky Mountain Express pipeline fared o right-of-way:

      ” Acquisition of all rights of
      way was accomplished within the project timeline allowed
      for construction to take place with no land-related delays.
      The project was accomplished within budget and with
      nearly 100% voluntary acquisition. For REX West, voluntary
      acquisition was 99.7% successful. While REX East proved to
      be a more difficult area to acquire and the acquisition costs
      were somewhat higher, CLS still accomplished voluntary
      acquisition at the rate of 99.2%. The use of condemnation
      was extraordinarily low for a project of this size traversing
      such a large and difficult area.”

      page 23

      so NC is largely not a part of PJM… so I’m not sure how Dominion would handle reliability that far away from PJM … .. without having new plants in Southside Va – but it would also appear that they’d need a new gas plant in Hampton to supplement Surry for peak power..demands.. seems like even when their coal plant was operating there – they were having reliability issues during peak power demands.

  8. A couple of quick points:

    First — Only NC’s Dominion service area is in PJM. Duke and CP&L (now merged with others) did not want to join when they had the opportunity and the NCUC wasn’t that convinced it was a good idea anyway. Not sure Dominion was that happy at the time about the loss of autonomy to PJM either but the VSCC pressured them to get with an RTO.

    Second, Jim you are correct — for a utility serving retail load to join PJM, it has to bring with it sufficient generating capacity resources to “serve” that load (including reserves). That capacity doesn’t have to be on its own system or owned by it as long as it’s under contract to deliver whenever PJM calls for it (i.e., “dispatchable”). Non-dispatchable generation, such as wind and solar, is discounted in capacity value. Moreover, that utility serving retail load has to arrange for a reliable transmission and distribution path to reach the load. Again, arrangements may include contracting with others (which is what most of the electric cooperatives and municipal utilities do). This delivery responsibility is bifurcated due to the crazy regulatory laws we have: the local utility has responsibility for constructing, planning, operating and maintaining the “distribution,” which falls under State regulation; meanwhile PJM has responsibility for operating and planning changes to the “transmission” system, under FERC regulation, and the transmission owner has responsibility for constructing and maintaining the transmission, also under FERC regulation. In most cases the transmission owner in Virginia is the same formerly-integrated utility that handles the distribution (e.g. Dominion), but that’s often not the case further north. What this means in practice is, the transmission owners identify reliability problems on their part of the grid, they work with PJM to come up with solutions (which frequently involve new generation as well as transmission fixes), and PJM takes the lead getting this through the regulatory maze. The SCC still gets involved in electric transmission planning in a big way because the SCC must approve the route, any condemnation, etc.; but in the case of a gas pipeline, the COPN is issued by FERC; and FERC also has a strange sort of override authority in case a State simply refused to allow a “needed” regional transmission upgrade.

    Third, yes LG, a new NGCC unit is horribly expensive but the alternatives are worse. While the ACL certainly is motived by customers wanting access to Shale gas, you have to notice that it will cross the Transco and Columbia and TETCo and other existing lines from SW to NE and if the Marcellus supply is someday exhausted, alternative supplies from Oklahoma etc. could be tapped. The better question is how long we’ll be burning natural gas for boiler fuel at all; it’s hardly an infinite supply and it is, after all, a carbon-based fuel generating CO2 emissions and it is highly desirable stuff for manufacturing plastics and chemicals.

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