Did They Just Split Joshua Falls–Yeat Into Pieces?

PJM’s own 2024 Window 1 Constructibility & Financial Analysis noted that expansion at the existing Joshua Falls 765 kV substation is constrained by mountainous terrain, and that any expansion to permit new line terminations would require significant civil work and costs.

PJM’s original 2024 Window 1 approval showed Joshua Falls–Yeat as a 156-mile line with roughly 69 miles in AEP territory and 87 miles in Dominion territory. By the May 2026 TEAC scope-change materials, the AEP portion is listed at only 1 mile.

Now Dominion’s own map appears to distinguish the existing Joshua Falls substation from a separate “Joshua Falls Proposed Relocation.” If the 2024 W1 approval was based on expanding the existing Joshua Falls substation, but the project now uses a relocated terminal site on a different parcel, then that raises a basic question: why is this not also being evaluated as a material scope change?

The May 2026 TEAC materials still state: “Add (2) 765kV breakers at Joshua Falls substation. Substation expansion is required to add the additional breakers. (b4000.359) $99.19M.” But if the terminal configuration has effectively shifted to a noncontiguous parcel to avoid the difficult expansion constraints at the existing Joshua Falls site, that appears to be more than a simple substation expansion.

Now we know more. Dominion states: “Due to space constraints, the existing Joshua Falls Station is proposed to be relocated. The relocation and associated work will be completed under a separate Appalachian Power project with a separate filing to be submitted to the SCC.”

That is a major issue. Now is the time to engage the Campbell County Board of Supervisors and the PJM Board.

PJM is already evaluating the proposed Yeat relocation and scope change. The PJM Board should also evaluate whether the starting point of this line has materially changed, and what that means for constructability, cost, feasibility, land acquisition, and the claimed 2029 in-service date.

If Joshua Falls requires a separate SCC filing, then how can PJM evaluate Joshua Falls–Yeat as one feasible project without fully accounting for both required SCC proceedings? How does one end of the project proceed if the other end is delayed, challenged, modified, or rejected?

We may now have “floating” substation questions at both ends of this line, with every county in the middle left holding its breath. This is critically important, as the Culpeper Board of Supervisors has already passed a resolution opposing the Joshua Falls–Yeat line and the siting of Yeat within Culpeper County. Does the Campbell County Board of Supervisors understand that this may involve a new or relocated terminal facility on a separate parcel, with real impacts to their citizens?

As these projects move forward, the public should be getting more clarity, not less. Instead, the start point appears to be shifting and unsettled, the endpoint appears to be shifting and unsettled, the mileage changes dramatically, and the project keeps being repackaged.

People should not have to guess what is actually being built. Now is the time to contact the PJM Board before it votes in July on the scope change. Ask PJM how it can approve a project that appears materially different from what was approved in the 2024 Window 1 RTEP and increasingly unlikely to meet the required 2029 in-service date. Ask why PJM is not evaluating scope changes for both the Joshua Falls substation and the Yeat substation. Ask how PJM assesses the risk if Campbell County responds negatively to a new or relocated substation.

Comments to the PJM Board can be submitted through PJM’s Board communication process. Ask that your comment be provided to the PJM Board of Managers before the expected July vote on the Joshua Falls–Yeat scope change.

PJM has authority to approve, change, defer, or remove RTEP projects. Therefore, the Board is not forced to rubber-stamp a scope change when material feasibility, constructability, endpoint, land acquisition, local opposition, and in-service-date risks are already known before the vote.

If PJM approves the scope change without addressing these issues, the record should reflect that these concerns were not newly discovered later. They were raised before approval, while PJM still had the opportunity to require further review, clarification, or disapproval of the revised project. If an application is filed with the SCC, then the public comments documented in the PJM process will be difficult to dismiss.

Comments should be addressed to the PJM Board of Managers and submitted through PJM’s Board communication process.

Email: david.anders@pjm.com (David Anders serves as Secretary for the PJM Members Committee and facilitates Board communications. Comments should be directed to the PJM Board, not personally to Mr. Anders.)

Suggested subject line: Comment on Scope Change – Joshua Falls–Yeat (2024 RTEP Window 1)

OR

Send comments via the mailing address:

PJM Board of Managers

PJM Interconnection L.L.C.

2750 Monroe Boulevard

Audubon, PA 19403

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