DISSENTING OPINION by
Judge LEAVITT.Respectfully, I dissent. The Public Utility Commission has adopted regulations that place a significant burden upon a utility that seeks to add yet another high voltage transmission line to Pennsylvania’s landscape. I agree with the Vice Chairman, Tyrone J. Christy, that TrAIL Co. did not meet this burden. I also disagree that the Commission’s regulations have relaxed the environmental standards for a transmission line less than two miles long. Indeed, a high voltage transmission line degrades the environment whether it is two miles long or two hundred miles long.
By a 3-2 vote, the Commission approved TrAIL Co.’s proposed construction of a new high voltage electric transmission line and an electric substation in Pennsylvania for the stated reason that they will serve a regional, as opposed to a Pennsylvania, need.1 In doing so, the Commissioners reversed the conclusion of the two administrative law judges assigned to the case that the evidence presented by TrAIL Co. did not demonstrate a need for the project. *488The ALJs presided over a lengthy hearing at which numerous witnesses and experts testified and extensive reports were examined. TrAIL Co.’s proposal was opposed by numerous intervenors, including ratepayers and people who live near the proposed transmission line; Rep. H. William DeWeese; the Office of Trial Staff; the Office of Consumer Advocate; and Energy Conservation Council of Pennsylvania, the petitioner in this appeal.
The ALJs found that business opportunity, not reliability, was the impetus for TrAIL Co.’s proposal to build a high voltage service transmission line. By way of Pennsylvania, TrAIL Co. seeks to move its relatively inexpensive electrical power in West Virginia to Loudoun County, Virginia, where that power can command a higher price. The ALJs found that TrAIL Co.’s proposal served the company’s need for profits but no real consumer or public need. The ALJs rejected TrAIL Co.’s proffered justification for the construction of a new transmission line in Pennsylvania, 1.e., to secure reliability in the grid and to ease congestion in the eastern part of PJM’s region, as unfounded.2
For example, the ALJs criticized the computer models used to develop PJM’s regional transmission expansion plan (Regional Plan) which TrAIL Co. used as its central evidence in support of its claim that the project was needed to resolve future reliability problems.3 The ALJs found the models to be based upon “an overly conservative, belt-and-suspenders approach to transmission system planning.” ALJs’ Recommended Decision at 115. For example, the models did not include the output of generators that are under construction and will be adding power to the regional grid before 2011, the year in which PJM’s models predict an onset of reliability issues. The ALJs further pointed out that the modeling in the Regional Plan was designed to yield only transmission solutions; accordingly, TrAIL Co. did not evaluate other technologies that would prevent a decline in reliability and be less environmentally intrusive. Specifically, the ALJs found that TrAIL Co. did not consider “facility upgrades or tweaks to the 765 kV PATH line, transmission constrained dispatch, high-voltage direct current (HVDC) lines, upgrades or repairs to existing transmission facilities, or any non-transmission solutions.” Id. at 116.
In response to the ALJs’ conclusion that TrAIL Co.’s evidence did not establish a service reliability problem, the Commission summarily reversed.4 It stated:
Here, we find that the record establishes that [the high voltage transmission lines and substations are] needed to address reliability issues and [are] the best alternative available to achieve that result.
Commission’s Adjudication at 36. The Commission provided no specific citations *489to the record to support this conclusory statement. It did not refute the ALJs’ well-supported and detailed findings or analyze their legal conclusions. The Commissioners simply leaped to a different conclusion.
The majority states that the regulation presumes that a high voltage transmission line less than two miles in length presents a minimum adverse impact upon the environment. I disagree with that interpretation of the regulation. It is true that the application process is less burdensome where the proposed line will be less than two miles in length, but that does not mean that the standards that regulate the construction and placement of high voltage transmission lines have been, or can be, relaxed by the administrative agency charged with the enforcement of these standards.
A utility may not construct a new transmission line of any length without the express approval of the Commission. Where the utility proposes a line shorter than two miles, it may seek approval by means of a “letter of notification.” 52 Pa.Code § 57.72(d)(1)(vi).5 Based upon the content of the letter of notification, the Commission may approve the application. On the other hand, the Commission may respond to the letter by requiring a full application. In any case, this abbreviated filing procedure does not alter the substantive standards by which any proposed high voltage transmission line is evaluated. It is a moot point here because TrAIL Co. chose to file the full-fledged application, not the “letter of notification.”
Chapter 57 of the Commission’s regulations, entitled “Electric Service,” was promulgated under Section 501 of the Public Utilities Code, 66 Pa.C.S. § 501. Subchap-ter G of Chapter 57, “Commission Review of Siting and Construction of Electric Transmission Lines,” establishes the substantive standards for the approval of any proposed high voltage transmission line. These regulations are binding on the Commission and have the force and effect of law. Sierra Club v. Pennsylvania Public Utility Commission, 702 A.2d 1131, 1135 n. 5 (Pa.Cmwlth.1997).
The regulations provide that when an application is submitted, a hearing is required. 52 Pa.Code § 57.75(a).6 At these *490hearings, the Commission must accept and consider evidence on, inter alia, the following matters:
(1) The present and future necessity of the proposed [high voltage transmission] line in furnishing service to the public.
(2) The safety of the proposed [high voltage transmission] line.
(3) The impact and the efforts which have been and will be made to minimize the impact, if any, of the proposed [high voltage transmission] line upon the following:
(i) Land use.
(ii) Soil and sedimentation.
(iii) Plant and wildlife habitats.
(iv) Terrain.
(v) Hydrology.
(vi) Landscape.
(vii) Archeologic areas.
(viii) Geologic areas.
(ix) Historic areas.
(x) Scenic areas.
(xi) Wilderness areas.
(xii) Scenic rivers.
(4) The availability of reasonable alternative routes.
52 Pa.Code § 57.75(e)(l)-(4). After the evidence is received, the Commission may grant or deny the application for the proposed high voltage transmission line with “conditions or modifications [to] the location, construction, operation or maintenance of the line.” 52 Pa.Code § 57.76(a). The Commission may not grant the application, with or without conditions, unless it determines:
(1) That there is a need for [the high voltage transmission line].
(2) That it will not create an unreasonable risk of danger to the health and safety of the public.
(3) That it is in compliance with applicable statutes and regulations providing for the protection of the natural resources of this Commonwealth.
(4) That it will have minimum adverse environmental impact, considering the electric power needs of the public, the state of available technology and the available alternatives.
52 Pa.Code § 57.76(a)(l)-(4).
In sum, Subehapter G presumes that a high voltage transmission line degrades the environment. The regulation does not ban new lines, but it requires the utility to make a compelling case for their construction. It requires the Commission to find unequivocally that the new line “will have a minimum adverse environmental impact, considering ... available technology and the available alternatives.” 52 Pa.Code § 57.76(a)(4) (emphasis added).
The Commission is not satisfied that these standards have been met. Accordingly, it has directed TrAIL Co. to do post-approval environmental impact studies, as a condition to the approval. However, these studies should have been submitted with the application and then reviewed and challenged in the course of the administrative hearing on TrAIL Co.’s proposal.
The ALJs found that TrAIL Co.’s application was defective because it lacked the *491information necessary for its evaluation. The ALJs explained that
TrAIL Co is asking this Commission to trust it to do all of the right things after approving what is basically a concept of a project rather than one that is fully developed. We suggest that this Commission would be shirking its oversight review duty were it to do so.
ALJs’ Recommended Decision at 190. The Commissioners agree that TrAIL Co.’s application is incomplete. Their adjudication expressed concern over the “lack of alternative route descriptions” and general “lack of information” in the application. Commission’s Adjudication at 43, 46. Nevertheless, the Commission approved the applications conditioned on TrAIL Co.’s submission of the missing information “prior to commencing construction.” Id. at 47.
Neither the Public Utility Code nor Chapter 57 of the Pennsylvania Code authorizes the issuance of a certificate of public convenience before the submission of information relevant to the merits of a utility’s proposal to construct a high voltage transmission line. The Commissioners are not authorized to approve an incomplete application. For that reason alone, the Commission’s adjudication should be reversed. In addition, the Commission’s conditional approval does violence to the process required for every application for certificate of public convenience. To allow the application to be completed after the certificate of public convenience is granted is problematic for two reasons.
First, it suggests that the adjudication is not a “final order” within the meaning of the Administrative Agency Law, 2 Pa.C.S. §§ 501-508, 701-704. This means that the Commission has retained jurisdiction so that it can modify or even revoke its approval, should the studies expose problems not anticipated by the Commission or even by TrAIL Co. Accordingly, the Commission’s order is interlocutory, and our review is premature.
On the other hand, if the Commission has issued a “final order,” then the burden has been shifted, improperly, from the applicant seeking approval of a new transmission line. To have the approval revoked or modified on the basis of post-approval amendments to TrAIL Co.’s application means that a new proceeding may have to be instituted to have the approval rescinded or modified should the amendments not yield the desired information. The burden will be placed upon the Commission or upon Intervenors to prove the grounds for a revocation or modification. It is the applicant utility, however, which properly bears the burden of proving the need for a certificate of public convenience.7
The Commissioners are quick to congratulate themselves for their ability to look beyond the parochial interests of Pennsylvania in favor of regional interests. The Commission’s job is not to advance broad-mindedness. Its job is a precise one: to enforce Pennsylvania statutes and regulations. Nothing in Subchapter G of the regulation suggests that the Commission should consider regional interests *492when deciding whether to grant a certifí-cate of public convenience for the construction of a new substation and high voltage transmission line in Pennsylvania. Regionalism is addressed in the Public Utility Code, but not in the way understood by the majority Commissioners. The Commission is required to work with others, including the North American Electric Reliability Council, to ensure continued “adequate, safe and reliable electric service to the citizens and businesses of this Commonwealth.” 66 Pa.C.S. § 2805(a) (emphasis added). There is no Loudoun County in this Commonwealth.
Indeed, the Commissioners’ allegiance to regional interests appears to have trumped their allegiance to Pennsylvania consumers and landowners. TrAIL Co.’s proposed new high voltage transmission line will drive up the cost of energy in West Penn’s service territory. These customers “will have to pay for generation after the 502 Junction to Loudoun line is built [and] they will be required to pay increased transmission costs.” Vice Chairman Christy’s Dissenting Statement at 4. West Penn customers alone will be responsible for $14.5 million per year in additional costs attributed to the various TrAIL Co. lines, including $10 million for that part of the line located in Pennsylvania. In West Virginia, those property owners burdened by the new high voltage transmission lines will be compensated, in part, with free electric service so long as the lines remain in place. No such deal was struck for Pennsylvania landowners. As Vice Chairman Christy aptly noted, the Pennsylvania line imposes all of the costs and none of the benefits on one segment of the public: Western Pennsylvania consumers.
For the foregoing reasons, I would reverse the Commission’s adjudication granting TrAIL Co.’s exceptions to the recommended decision of the ALJs.
. Vice Chairman Tyrone J. Christy filed a dissenting statement to the Commission's Opinion and Order. Commissioner Wayne E. Gardner filed a statement concurring with the Commission’s vote approving the TrAIL Co.'s application on appeal here but dissenting to the Commission’s approval of the Greene County settlement agreement.
. PJM Interconnection is a regional transmission organization that coordinates the movement of wholesale electricity in a region that includes 13 states ranging from Illinois to New Jersey and Michigan to North Carolina.
. Notably, reliability was not even studied until after PJM announced its plan to address service needs in the eastern part of the 13-state region by building generators in Ohio, Kentucky and West Virginia, the easiest place to build them, and distributing electrical service from there. It did not consider a local solution, i.e., building generators closer to the places where the need for electric service exists.
.The Commission is opaque on the reliability basis for granting TrAIL Co. a certificate of public convenience. "Reliability” can justify the grant of a certificate of public convenience for any and every proposed high voltage transmission line because, theoretically, any addition to the grid will improve reliability.
. It states, in relevant part, as follows:
*490Upon the filing of an application, the Commission will set the time and place for hearing or hearings of the application and will thereupon require the applicant to cause the weekly publication for two consecutive weeks of a notice of hearing.... The notice of hearing for publication shall contain a brief description of the proposed [high voltage] line, its location, a statement of the date, time and place of the hearing and of its purpose and a statement as to where and when a copy of the application is available for public examination.
52 Pa.Code § 57.75(a).
. The settlement between TrAIL Co., West Penn Power Company and Greene County eliminated the proposed "Prexy Facilities” project, which was part of TrAIL Co.’s original application, and is not part of this appeal. The AOs found that TrAIL Co. did not prove a need for the Prexy Facilities. The Commission directed the parties to participate in a collaborative process to identify alternatives to the Prexy Facilities, in part because TrAIL Co. did not consider technological alternatives to a new substation and new high voltage transmission line. By that logic, the Commission should have denied that part of TrAIL Co.’s proposal on appeal here.