DIRECT TESTIMONY

Dr. Hyde Merrill provides expert testimony challenging the technical necessity of the $1.8 billion PATH transmission project. He argues that PJM Interconnection's reliability claims are based on flawed planning, inaccurate extrapolations, and undocumented changes in assumptions. Specifically, he asserts that alleged voltage issues could be resolved with capacitors costing $40 million, and that thermal violations on lower-voltage lines could be fixed for approximately $66 million. He further claims that 500-kV thermal violations are speculative, based on unreliable extrapolation rather than contingency analysis, and ignore available generation and demand-side management resources. Merrill concludes that the project would increase reliance on remote coal-fired power and recommends a strategic shift toward local renewables and gas-fired plants.

• The alleged widespread voltage collapse issues identified by PJM in April 2009 could be resolved by installing approximately 2,000 Mvars of capacitors at a cost of $40 million, making the $1.8 billion PATH project unnecessary for this purpose.
• The sudden appearance of voltage problems in the April 2009 study is attributed to undocumented and potentially erroneous changes in technical assumptions compared to the 2008 RTEP study, including an unjustified increase in reactive load and the removal of capacitors and transmission circuits from the model.
• Six alleged thermal violations on 230-kV and 345-kV facilities identified in 2014 could be addressed through routine, low-cost upgrades such as replacing transformers or reconductoring, with an estimated high-end cost of $66 million.
• PJM's claims of 500-kV thermal violations beyond 2014 are based on unreliable extrapolation of 2014 data rather than required NERC contingency or deliverability analyses.
• PJM's planning failed to include a 1,640-MW generator at Calvert Cliffs with a signed Interconnected Service Agreement (ISA) and Construction Service Agreement (CSA), which would reduce alleged overloads and postpone the date they would exceed 100% capacity until 2021.
• Incorporating demand-side management (DSM) resources from the 2009 RPM auction, specifically 1,033 MW of additional demand response and energy efficiency in the BGE and PEPCO areas, would further reduce flows and eliminate the claimed 2015 overload on the Mt Storm-Doubs line.
• PJM's planning process is criticized for neglecting environmental and economic impacts, with a word search of the 2008 RTEP report showing that reliability terms appear far more frequently than environmental or economic terms.
• The document argues that the regional power system should move away from long transmission lines serving coal-fired plants and instead develop local renewables, gas-fired plants, and demand-side resources.

APA

Merrill, H. M. (2009). DIRECT TESTIMONY. Earthjustice. https://earthjustice.org/wp-content/uploads/merrill-testimony.pdf

Chicago

Merrill, Hyde M. DIRECT TESTIMONY. Earthjustice, 2009. https://earthjustice.org/wp-content/uploads/merrill-testimony.pdf.

Wikipedia

{{cite report |last1=Merrill |first1=Hyde M. |title=DIRECT TESTIMONY |publisher=Earthjustice |date=23 October 2009 |url=https://earthjustice.org/wp-content/uploads/merrill-testimony.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{merrill2009direct, author = {Merrill, Hyde M.}, title = {{DIRECT TESTIMONY}}, institution = {Earthjustice}, year = {2009}, month = oct, url = {https://earthjustice.org/wp-content/uploads/merrill-testimony.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }