The Atlantic Grid Holding Company’s (AGHC) right-of-way application for the Atlantic Wind Connection project is premature, given that the project has not been approved by the PJM Interconnection for inclusion in its transmission planning process nor gone through FERC rate proceedings, Dominion Resources (NYSE:D) said Feb. 21.
The Virginia-based utility said the Bureau of Ocean Energy Management (BOEM) should delay AGHC’s application pending the PJM Interconnection’s regional transmission expansion program (RTEP).
Dominion filed comments in response to the BOEM’s request for competitive interest (RFCI) in lease blocks requested by AGHC (Docket No. BOEM-2011-0023).
A person briefed on the situation told TransmissionHub the reply comments to BOEM’s request will be posted to www.regulations.gov after the agency conducts an initial review of the comments. Expressions of interest will be available on the BOEM’s website “in the coming week,” the person said.
Dominion argued that until the leasing process is complete, it will not have sufficient information “to consider applicable project easement or transmission right-of-way (ROW) needs for delivery of offshore power to the main transmission grid onshore to be able to identify their competitive interests in the blocks subject to this RFCI.”
For the Atlantic Wind Connection project to move forward, it needs to be included in PJM’s RTEP, which would involve approval for incentive rate treatment and a cost-of-service formula, and go through rate proceedings at FERC, which “could affect the proposed financing and design of the AWC project, as well as its timing,” Dominion said.
The company added that the potential effect of FERC Order 1000 on PJM’s RTEP, in addition to the development of a cost allocation methodology, could further affect timing, making it unlikely AGHC would begin the first phase of construction in 2013, Dominion said.
“AGHC’s application for a ROW is the proverbial cart before the horse,” Dominion said in the filing. “Based on its current understanding, Dominion is unclear how the AWC project will satisfy current planning drivers and receive approval in RTEP.”
AGHC is proposing the construction of the Atlantic Wind Connection as an integrated transmission system of 790 statute miles of transmission facilities and 300 blocks on the Outer Continental Shelf of New York, New Jersey, Delaware, Maryland and Virginia.
The request for competitive interest is particularly premature for those blocks associated with Phase D and Phase E of the AWC project, which fall off the Virginia coast, Dominion said. Phase D would include 175 statute miles of facilities from Maryland south to Virginia and Phase E would include 165 statute miles of facilities from Delaware south to Virginia.