We, the people who live, work, visit, and own property in Hardy County, oppose the proposed Valley Link transmission lines and associated substations. We petition the WV Public Service Commission in accordance with their authority under WV Code §24-2-11a and the Commission’s regulations governing high-voltage line transmission line applications. Further, we request that our county commissions and representatives in the WV legislature support our petition.

We all appreciate reliable electricity, but Valley Link places disproportionate burdens on West Virginia families, farmers, landowners, and communities while offering no benefits to Hardy County and few to West Virginia. The proposed transmission lines fail to satisfy the statutory criteria required for approval and, therefore, should be denied by the PSC in the exercise of its lawful authority to protect the interests of WV customers and citizens.

The PSC may only approve a transmission line if it finds that the proposed project satisfies three statutory criteria. Specifically, these are that the proposed transmission line:

1. Will economically, adequately, and reliably contribute to meeting the present and anticipated requirements for electric power of the customers served by the applicant or is necessary and desirable for present and anticipated reliability of service for electric power for its service area or region;
2. Will be in the best interest of West Virginia customers and its citizens; and
3. Will result in an acceptable balance between reasonable power needs and reasonable environmental factors.

These requirements are mandatory, and the burden of proof rests squarely upon the applicant to establish that the public convenience and necessity exist.

1.     The Proposed Transmission Lines Do Not Serve WV Customers or the WV Service Area

The proposed transmission lines are designed to serve energy consumption in Virginia – not West Virginia.

West Virginia customers already enjoy adequate and reliable electric service, and Valley Link does not enhance this service; it only serves as an extension cord to satisfy out-of-state demand caused by Virginia’s reckless power choices that closed many reliable power generation facilities, while allowing nearly unchecked growth of data centers. Virginia is home to approximately 600 to 700 active or planned data centers. As of 2023, data centers accounted for 26% of Viginia’s total electricity consumption.

Transmission lines that bypass West Virginia customers to serve Virginia data center demands do not meet the statutory requirement that they serve the West Virginia service area. As such, the PSC should reject the Valley Link application when it is received, refusing to condemn West Virginia property and impose costs on local ratepayers for a project that provides us with no benefit.

2.     The Proposed Transmission Lines Are Not in the Best Interest of West Virginia Customers and Citizens

Far from being in the best interest of West Virginia citizens, the proposed Valley Link transmission line will adversely affect our state for generations to come and place undue hardship on its citizens, farms, and businesses.

Our state motto is Wild, Wonderful West Virginia. Tourists do not come to West Virginia to photograph powerlines or camp under the buzz of a 765kV electric line. The economic impact of tourism for West Virginia recently topped $9B. Just a 2% loss to that revenue stream – which is entirely possible due to the large footprint of the project – would total close to $200M. And the businesses that would be affected are not large corporations. They are mom-and-pop restaurants, bed-and-breakfasts, and other small businesses that would be closest to the proposed path – and the results could be devastating to local economies.

The hardship would be equally great to our local farms. Hardy County is the top agriculture county in the state, generating $269M in revenue from over 500 farms. Most of these are not large farms. Carving out hefty rights-of-way would severely disrupt farm operations and, in many instances, drive farmers out of business. In a time when our food supply is increasingly dominated by foreign actors, is this really in the West Virginia’s (or the country’s) best interest?

Valley Link would impose numerous other hardships to West Virginians relating to visual impact, environmental impacts, health concerns, loss of property value, and others – and on top of all of this burden, the Valley Link project would impose substantial costs on West Virginia ratepayers.

It cannot be in the best interest of West Virginia customers and citizens to be compelled to finance infrastructure that exclusively serves out-of-state interests. We should not be forced to subsidize Viginia’s insatiable energy demands. And, on this basis, the PSC should decline to condemn West Virginia property for out-of-state corporate greed and reckless choices.

3.     Valley Link Does Not Balance Reasonable Power Needs with Reasonable Environmental Factors

Far more rationale options exist to deliver power to Virginia data centers that minimize the environmental burden on neighboring states than the proposed Valley Link pathway.

The most logical course of action is to colocate power generation with the data centers. The Department of Energy is driving colocation of power generation directly with data centers – inviting private sector developers to build data centers adjacent to advanced energy generation facilities. Large corporations, such as Google, are already partnering with energy developers to build dedicated energy parks adjacent to data centers. This trend could make the Valley Link line obsolete before it ever comes online – but, unfortunately, after much of the environmental damage has been done.

Some countries, such as Italy and Belgium, are mandating that transmission lines be buried underground, which mitigates much of the environmental impacts and many of the health-related concerns. But these cost more, are less efficient because you need more, smaller lines – and they take substantially more time to install … meaning data centers will likely find other sources of power before the project is complete.

PJM, who will build out the transmission line, makes a considerable amount of money by building power lines, whether they are needed or not. PJM not only does not foot the bill for the ecological havoc they create, they impose those costs on the communities that are destroyed. And there are questions as to the accuracy of their “need” predictions. In a recent meeting, Joseph Domingues, CEO Constellation Energy, pointed out that three regional grid operators (MISO, PJM, and ERCOT) collectively account for less than half the national power demand, but “are projecting demand growth notably higher than a wide range of consultants for the entirety of the US”.

The environmental impacts of constructing hundreds of miles of high-voltage transmission line through West Virginia will be substantial, including: clearing of forested land along the transmission corridor, fragmentation of wildlife habitat; visual impact on scenic areas and rural landscapes; long-term maintenance impacts including herbicide application and vegetation management.

Future power demands are questionable, at best, and all fall outside of West Virginia. As such, there is no “acceptable balance” when all of the environmental costs fall on West Virginia, while all of the power benefits go to Virginia.

In Closing

Our neighboring states, Virginia and Maryland, have chosen to close reliable, fossil-fuel power generation facilities in their states in favor of “clean” renewables like solar and wind. These alternatives cannot support the existing customer base, much less than supporting the future needs driven by electric vehicles and data centers. No amount of power will ever be enough to support their insatiable energy needs. The PSC must reject the Valley Link request because it does not serve the West Virginia community and, left unchecked, they would crisscross our beautiful state with power lines until they blacken the sky.