>>SIERRA CLUB NEW MATTER FORM [revised 5/99] Subject: In the DESCRIPTIVE MEMO >>SIERRA CLUB NEW MATTER FORM [revised 5/99] Subject: in the last paragraph of B, "intervenore" should be "intervenors", and the last paragraph of C needs a period.  In A where it says:

>>SIERRA CLUB NEW MATTER FORM [revised 5/99] Subject:
"The alleged purpose of the line is to relieve transmission congestion and bottlenecks between power plants in the Ohio Valley and Midwest states and consumers in East Coast markets. However, we believe that the line’s primary purpose is to increase sales of electricity from underused coal-fired power plants owned by Allegheny Energy, and displace electricity from more expensive, but potentially cleaner power plants nearer to those markets."

I'd like to make a comment, and maybe a suggest a rewording, though I'm leaving that up to you, it's probably good as it is.  However, according to the "Draft National Corridor Designations Key Findings and Conclusions" at http://nietc.anl.gov/documents/docs/FindingsAndConclusions.pdf  under the "Principal Findings and Conclusions Concerning the Draft Mid-Atlantic Areas National Corridor Designation", one finding is that "high-production-cost generators in eastern PJM are used extensively, while generating capacity at lower-production-cost generators in western PJM are inaccessible with additional costs passed on to electricity consumers."  Allegheny Power is definitely taking advantage of that finding so it's not an issue of us believing that this may be the case.

One of my favorite findings of the DOE Findings is the one that talks about the Mid-Atlantic Critical Congestion Area, and then goes on to mention "the large number of military and other facilities in this area that are extremely important to the national defense and homeland security" and how "any deterioration of the electric reliability would constitute a serious risk to the well-being of the Nation."  Now explain to me how building a new transmission line, that is easily vulnerable to a terrorist attack, is going to accomplish this?  The DOE should be pushing decentralized energy solutions like the one Alan Tweedle talks about in his previous email.  It can be further argued that for the DOE to encourage increased energy usage via non-renewable energy production and by establishing Corridors to facilitate this production, would mean that the DOE, itself, is a threat to the National Security it hopes to protect.  Why?  Because Global Warming poses a serious threat to the stability of the world.  Probably everyone has read this - http://www.cnn.com/2007/US/04/15/warming.military.ap/index.html .  Anyways, what I'm saying here about this finding wouldn't fit into the Matter Form, however, if you can find a place for it in the handout that will be passed out Wednesday night, it may turn some heads.

Jonathan


James Kotcon wrote: 
Attached is a draft version of a New Matter Form for the Chapter to intervene before the Public Service Commission in the proposed Allegheny Transmission line case.  The initial intervention is relatively low cost, but if expert witnesses are needed, the costs could escalate.  There is significant potential to share costs with other citizens/groups along the proposed route, but firm commitments have not yet been made.

No scheduling Order or deadline for intervention has yet been set, but one is expected soon and we would have at most 30 days to get approval to intervene in order to preserve our ability to participate fully in the proceedings.

The Energy Committee approved this (in principle) on Friday night, with the goal of presenting it to the ExCom for approval at the Tuesday night conference call, and then submittal to the National Litigation Committee in San Francisco.

Jim Kotcon

P.S.  Any suggestions for additional language or editting would be appreciated.