The only viable alternative to overhead HVAC transmission lines that would preserve the value of private property, conservation easements, and national and state parks faced with the MARL/Gore-Doubs-Goose Creek and Valley Link transmission projects would be underground high-voltage direct current (HVDC).
It is feasible , it was proposed as an alternative to the PATH 765kV transmission line, in 2009, by Black & Vetch.
The cost for Underground HVDC has come done significantly since then and the installation space needed is even smaller. It can be installed underground along existing transmission easements or highway easements and has been used in multiple projects in the US.Read more about Underground HVDC here .
The mitigation costs of undergrounding these projects using HVDC could be paid for by data center taxes, data center impact fees or through new rate structures for large energy users such as data centers.
Help us get the word out by posting our petition on social media!
Download our flyer about these two projects and our proposed HVDC underground alternative and hand it out to your neighbours and friends in Loudoun, Frederick and Clarke counties in Virginia and encourage them to sign our petition!
HVDC underground is applicable to all of the proposed 500kV and 765kV projects in Virginia.
If underground HVDC technology is adapted it will save thousands of private property owners across Virginia form eminent domain easement takings for transmission lines to provide energy for data centers!
Individuals can intervene "Pro Se" at the Virginia SCC to represent themselves. You do not need a lawyer! You also do not have to travel to Richmond for the Hearing you can participate remotely.
If you have not already requested a Virginia SCC efiling account please do so ASAP so you will be ready to file as soon as the docket is filed!.
Instructions, templates and drafts from the PATH case as well as examples from recent cases have been posted!
For now, just get your account setup and verify you can login once you receive your VA SCC eFiling account.
Submit an opinion or letter to the editor on the data center energy issue or the MARL/Gore-Doubs-GooseCreek and Valley Link Lines to one of the Loudoun County Newspapers. Be Sure To Mention Our Petition!
Submit an opinion or letter to the editor on the data center energy issue or the MARL/Gore-Doubs-GooseCreek and Valley Link Lines and the Woodside substation to one of the Frederick County Newspapers. Be Sure To Mention Our Petition!
West Virginian's Against Transmission Line Injustice is leading the fight in West Virginia to oppose both the MARL/Gore-Doubs-Goose-Creek transmission line and the Valley Link transmission line. Two counties in West Virginia - Hampshire and Jefferson are impacted by both transmission lines . If both lines are approved, 17 Counties through West Virginia will be impacted by these HVAC transmission lines. Both lines require new 200' easements through West Virginia more than 6,000 acres of property would be taken to host these transmission lines, while West Virginian's receive no benefit at all.
First Energy filed a Notice of Intent to file an application for the Gore-Doubs-Goose Creek transmission line through Jefferson County, WV. at the West Virginia PSC yesterday !
West VA PSC Docket Number: NOIE Potomac Edison 25C
West Virginia Code Sec. 24-2-11a(c) says at least 30 business days before the deadline to intervene, the applicant must serve notice by certified mail to all owners of property within the preferred corridor.
First Energy's open house in Jefferson County was August 14 - just 10 days ago!
If you are in West Virginia, you can file comments with the PSC for that specific docket NOIE Potomac Edison 25C
Per StopPATHWv: "If you are in Jefferson County you may want to start with... has there been sufficient notice and public engagement? Do you feel you have enough details about this project? Did they show you what a 185 ft. tower would look like? Did they give you full details about their construction practices and what to expect?" If you are in West Virginia, you can file comments with the PSC for that specific docket
You don't need to have a lawyer to intervene at the West VA PSC - in fact once the application has been filed you can intervene pro - se at the start and join with other impacted property owners to have a lawyer represent you all later in the case ! You must intervene to protect your property rights!
ACTION: Deadline Midnight, March 14, 2025 to Appeal Loudoun County Property Tax Real Estate Assessment
If there is a transmission line on your property or in your view shed you may want to consider appealing your Loudoun County property tax assessment.
The impact on property valuations due to the view shed impediment on a 6.5 mile 500kV/230kV transmission line along Route 7 in Data Center Alley was estimated to be between -1.0% and -19.2% of the current assessment.
According to the expert witness hired by Loudoun County, the valuation of the properties in this area, will decrease by a combined $252,025,000 in the set of properties within the mass appraisal study area, where the differential reflects the damages that will be done by the installation of the 500kV/230kV transmission lines!
For the Aspen-Golden 500kV/230kVtransmission line, no easements were sited on residential private property and the majority of the transmission line was sited along the Route 7 highway - the projected decrease in valuation is entirely due to the view shed impediment.
For Loudoun County, Virginia the Real Estate Assessment Appeal application must be submitted no later than Midnight, March 14, 2025 :
See: https://www.loudoun.gov/6138/Appealing-a-Real-Estate-Assessment
The Loudoun County online Real Estate Review form to be submitted is available here: https://interwapp22.loudoun.gov/reaa/reviewForm.aspx
Note: In Loudoun County, on the online Real Estate Review form enter the Parcel ID from the Real Estate Assessment Notice for tax year 2025 for your property as the PIN.
Below you will find:
1) Highlighted Direct Testimony Of William C. Harvey On Behalf Of Loudoun County, Virginia VA SCC Case Nos. Pur-2024-00032 And Pur-2024-00044
Aspen - Golden Substations And 500kv / 230kv Transmission Lines
2) Citations from the testimony that can be used in the "Applicant Remarks" section of the or uploaded
*** ALERT ACTION NEEDED : DEADLINE: Email and Letters must be received by PJM By Monday, February 17, 2025
New Proposed Project 262 (Transsource #708: Amos - Welton Springs - Rocky Point 765kV)
On January 7, PJM’s Transmission Expansion Advisory Committee (TEAC) stated they would recommend approval of transmission Project 262 to PJM’s Board of Managers. This project includes a 261-mile, 765kV transmission line from the John Amos power station in Putnam County, WV WV through 14 counties in West Virginia (Putnam, Kanawha, Roane, Calhoun, Braxton, Lewis, Upshur, Barbour, Tucker, Preston, Grant, Hardy, Hampshire and Jefferson) through Frederick, Clarke and Loudoun counties in Virginia to a new substation in Frederick County, MD, to be built by 2029. This proposal is nearly identical to the Potomac-Appalachian Transmission Highline (PATH) project that we defeated in 2012. This will cross Loudoun County for about 15 miles and will take a new 200 ft. wide easement parallel to the existing transmission lines - approximately 365 acres of property in Loudoun County alone! This is the same area in Western Loudoun County that is the target of another new 500kV transmission line that was approved by PJM’s Board of Managers in August of 2024, which if built will also require taking additional easements. Again, this new transmission project is for the sole purpose of powering new data centers in Eastern Loudoun. This is for the data center's business expansion but we will be expected to sacrifice our land and perhaps our very homes and on top of that we will be paying for this line in our electric bills! .
Write a letter to the PJM Board of Managers then either forward it electronically or mail it.
=> Tell the Board of Managers your reasons for opposing the project. Include the reasons (see list below) and tell PJM’s Board your own story - impacts to your property and/or home and community, your quality of life and enjoyment of the state and national parks that would be effected. What would it mean to you if your home is seized and razed to make way for this data center extension cord.
=> Most Important Ask the Board of Managers to REJECT Project 262 (Transsource #708: Amos - Welton Springs - Rocky Point 765kV) Tell PJM to find a solution that does not destroy private property across Western Loudoun County as well as the Harper's Ferry National Park, the Appalachian Trail, the C&O Canal National Park and the view shed all along the Potomac River!
=> Address Letters to: The PJM Board of Managers, Mark Takahashi, Chairman and
Manu Asthana, PJM President and CEO PJM Interconnection L.L.C.
=> Mail Letters to:
The PJM Board of Managers
Mark Takahashi, Chairman and
Manu Asthana, PJM President and CEO PJM Interconnection L.L.C.
2750 Monroe Boulevard
Audubon, Pennsylvania 19403
=> Email:
• Use Subject: Opposition to Project 262 / 708 2024 Window 1 – 765kV 261-mile transmission line
• Send your letter as an email attachment to: David.Anders@pjm.com. (Do not address your letter to
Mr. Anders, he has no decision-making authority he only delivers the mail)
Reasons why PJM’s Board of Managers should NOT approve Project 262:
1) The project was not competitively bid or awarded. PJM utilities FirstEnergy, American Electric Power and Dominion made a joint proposal in order to thwart competition and fix prices. The utilities did not have to compete with each other to propose a project that was "cost effective" for ratepayers, and the project bid did not include any cost caps. Even then, project is under bid as it is based on "cheaper" Guyed V-lattice tower construction which will not work due to terrain. Guyed V-lattice towers are possibly the foulest, most land use restrictive, intensive and invasive electric infrastructure available!
2) PJM’s Constructability and Financial Analysis of the project was not performed as required. PJM’s stated process for the analysis required a review of land use mapping that identified residences within both 100 feet and 250 feet of the proposed line, along with identification of conservation easements, public land, and historic structures and districts in acres and the count as well as a Public Lands mapping review with types, acreage and counts (etc). PJM did not perform this analysis at all.
3) PJM’s maps of the project claim the project will be built on existing easements when PJM has stated that it will require a new easement for its entire 261-mile length. The proposed route crosses 15 miles of private property and conservation easements in Western Loudoun County that would be subject to eminent domain taking for a new 200' easement. This is another @365 acres of private property just in Loudoun to be taken to support data center expansion. This will have a devastating effect on property owners all along the route.
4)The project will cross the Monongahela National Forest, Appalachian National Scenic Trail, Chesapeake & Ohio Canal National Historical Park, Harpers Ferry National Historical Park,Potomac Heritage National Scenic Trail and it will run parallel down the view shed of the Potomac River and will severely impact / destroy the scenic and historic value of these assets.
5) Project 262 was rated the most risky project for its In-Service Date of 2029 due to both schedule and constructability risks. PJM’s Reliability Report states that PJM is attempting to manage this risk by extending the In Service Date to 2032.
6)The project is another extension cord to export coal-fired electric resources from West Virginia's aging coal generation plants (in this case John Amos built in 1971) into Virginia.
7) Project 262 is NOT the only solution for transmission nor is transmission the only solution for the data center expansion / projected energy load in Loudoun County, Virginia.
ASK PJM BOARD TO REJECT PROJECT 262 (#708: Amos - Welton Springs - Rocky Point 765kV) ACTION: We need YOU to write a letter to PJM’s Board of Managers asking them to deny approval of Project 262!
Post this to your social media accounts and ask friends, relatives, co-workers and any other groups you are a part of to send emails as well!
Loudoun County Send an email to our BOS : bos@loudoun.gov
Address Letters to: The PJM Board of Managers, Mark Takahashi, Chairman and
Manu Asthana, PJM President and CEO PJM Interconnection L.L.C.
Mail Letters to: The PJM Board of Managers, Mark Takahashi, Chairman and Manu Asthana, PJM President and CEO PJM Interconnection L.L.C.
2750 Monroe Boulevard
Audubon, Pennsylvania 19403
Email: Send your letter as an email attachment to: David.Anders@pjm.com (Don't address the letter to Mr. Anders, he has no decision making authority he only delivers the mail)
2025_PJM_BoardLetter_OpposeProject262_708_765kV (docx)
DownloadIntervene By April 4, 2025 - Send Comments by @ May 12, 2025
FERC has set a comment and intervention deadline of April 4. However, FERC will not be deciding on this matter until at least May 14, so if you are not intervening feel free to continue to send your comments until @May 12, 2025.
Valley Link has recently filed a request for a rate template, financial incentives, and an 11.4% rate of return .
The CWIP in Ratebase incentive combined with the Hypothetical Capital Structure incentive will allow Valley Link to earn extra cash for its project before it is even constructed, all at consumer expense! Adding insult to injury, Valley Link is asking the Commission to make consumers “the bank” by loaning Valley Link money during the construction period. Valley Link also requests that the Commission make consumers “the insurer of last resort” by granting the Abandoned Plant incentive that will charge consumers for Valley Link’s investment in the project even if it is never built!
Adding to its jackpot of consumer money from high electric bills, Valley Link requests a 10.9% return on equity plus an additional .5% for its new membership in PJM Interconnection, for a total interest rate of 11.4%. The project’s $3B cost is slowly depreciated over perhaps four decades and during that time consumers will pay 11.4% on the remaining balance every year, making the final cost to ratepayers double or triple Valley Link’s actual cost to build. We simply can’t afford it!
Write your letter
While FERC has no permitting authority for the transmission line, it does have authority over its rates, which end up in our electric bills.
Filling Your Comment
Files Below Include
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