December 4, 2023
VIA ELECTRONIC MAIL
The PJM Board of Managers
Mark Takahashi, Chairman
Manu Asthana, PJM President and CEO
PJM Interconnection L.L.C.
2750 Monroe Boulevard
Audubon, Pennsylvania 19408
RE: PJM 2022 Window 3
I request the PJM Board of Managers reject the entire RTEP 2022 Window 3 TEAC recommendation for the reasons listed below.
- COST – $5 BILLION UNFAIR AND UNBEARABLE IMPACT TO CITIZEN RATEPAYERS ACROSS THE PJM REGION
- This project will cause higher utility rates for all citizen PJM ratepayers. In Virginia, Dominion Energy projects a 100% increase in ratepayer electricity bills by 2035. It is not known whether all the costs of the proposed PJM data center grid expansion is factored into this projection. It is also projected, if there are no significant changes to their current model, that AI data centers will require 5-8% more power than today’s data centers. This overwhelming trajectory is putting all PJM ratepayers into debt.
- Residential and commercial power requirements are flat, in spite of population growth, because homes and businesses have invested their own money into improvements over the years to achieve energy efficiency and thus reduced power costs. The data center industry should be required to do the same.
- The “If you build it, we will bring you the power” model with data centers is simply not sustainable.
- Costs of this electric power infrastructure should be shifted solely onto the data center industry, which is the only entity requiring and benefitting from the power being demanded. Socializing the outsized power demands of the data center industry to all ratepayers is simply unequitable. The richest corporations in the world run the data centers of the world. THEY will be more careful with THEIR power usage if THEY are required to pay for THEIR gargantuan and outrageous demands.
- NEGATIVE AND UNFAIR IMPACTS TO AGRICULTURAL, COMMERCIAL, AND RESIDENTIAL COMMUNITIES; ENVIRONMENTAL RESOURCES; HISTORICAL RESOURCES; NATURAL RESOURCES; AND OVERALL QUALITY OF LIFE
- PJM’s plan for data centers’ power will add an additional damaging spider web of transmission lines and substations coursing through communities, farms, parks, and sensitive environmental and historic sites throughout Virginia, West Virginia, Maryland and Pennsylvania.
- This massive project will adversely affect all of the following irreplaceable assets. There are even more that I could not determine because only redacted information was provided to the public, and many proposals redacted this information with statements such as: “An investigation to further identify and evaluate historic properties will be conducted to determine the presence of archaeologically or historically significant resources.” I personally cannot list all Virginia, West Virginia, Maryland, and Pennsylvania impacts, but include here what was called out in the selected proposals:Potomac River, North River, Capon Chapel, Appalachian Mountains, Shenandoah River, Millville Dam, Appalachian Trail, Waterford Historic District, Belmont & Ashburn Presbyterian Church, Monongahela River, Cheat Lake, Youghiogheny state scenic River, C&O Canal National Park, Monongahela National Forest and State Park Land, Dickerson Conservation Park, Monocacy River, historic Hamilton, Goose Creek, Cedar Run, Broad Run, Bull Run. Rivanna River, Matta River, Po River, Ni River, unforeseen streams and wetlands
- PATHWAY TO OPPOSITION AND FAILURE – UNLIKELY TO BE COMPLETED
- It is unfair of PJM to import fossil-fuel generated power into Virginia across and through West Virginia, Maryland, and Pennsylvania – ratepayers who are not deriving any benefit from transmission lines and substations tearing through their communities to serve data centers.
- PJM is going to encounter significant opposition and roadblocks against every cluster of this recommendation: West, South, East, Northern Virginia/Doubs. You are facing high constructability risk, with continuous and persistent brick walls to deal with in every region. This is going to extend construction timelines and increase costs. Some, or all, of this proposed “solution” may never be completed, which will be another waste of money for PJM ratepayers.
- PJM MODEL, PROCESS AND TRAJECTORY ARE NOT SUSTAINABLE
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- PJM will be transmitting power generated by fossil fuels. This will prevent Virginia, West Virginia, Maryland, and Pennsylvania from meeting their climate goals. Why would PJM pursue this path?
- In PJM’s model, public citizens ratepayers are subsidizing the private data center industry’s power need. If the data center industry gets a $5 BILLION fix for their power needs, why shouldn’t any other power-hungry industry expect and receive the same treatment? How just is the way in which PJM is operating? And how sustainable will it be for PJM, and for the PJM ratepayers, to continue this ballooning model?
- Data center technology is changing faster than the PJM model and process. There is a very high likelihood that PJM will be facing stranded transmission lines and substations, in addition to overbuilt transmission lines and substations connected to abandoned data center buildings within 10 years.
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I am not going to spend time in this message arguing against specifics of any of the recommended paths or routes – they are all wrong. I am sure you have received many articulate messages from individuals across the region who are against what this plan will bring and are prepared to do what is necessary to oppose what PJM and the data center industry are trying to do.
I value the beauty and integrity of my home in Virginia, as well as all of the assets in the rest of the region we share with West Virginia, Maryland and Pennsylvania. None of us and our families deserve the devastation, upheaval, and cost that this proposed project will bring. Not only is every recommended path being put forward full of inequities and a bad option; the entire submission and model upon which it is based is flawed, wrong, bad for people, bad for the environment, bad for our livelihoods, and just not good business practice.
We cannot continue to operate in this way.
I have attended every single PJM TEAC monthly meeting for the last 6 months. I have reviewed all prior related PJM documentation, as well as the last three published Dominion Energy IRPs. The truth of the situation cannot be ignored.
Both PJM and Dominion Energy have made it abundantly clear, time and again, in all of the meetings and in all of the documentation, that the driver and the recipient for this proposed power transmission is the data center industry. That data center industry – and PJM – must determine a more realistic and sustainable way to address the data center industry’s insatiable demand without adversely affecting PJM ratepayers and families across Virginia, West Virginia, Maryland, and Pennsylvania.
This is a bad solution and would do a disservice to PJM’s effectiveness and reputation, as well as a disservice to all 65 million PJM ratepayers.
Reject the recommendation and force the data center industry, the TOs, and the TEAC to go back to the drawing board.
Karen Sheehan
Haymarket, Virginia
Director, Coalition to Protect Prince William County