Grain Belt Express made several revelations last week at a Kansas legislative committee meeting.  It was quite apparent that GBE realized that the NIETCs severely damaged its reputation and project prospects in Kansas (and any other state where Invenergy is trying to build transmission).  Your complete opposition and swift action on the proposed NIETCs gave GBE a real black eye.  GBE is now rightfully terrified that the welcome mat is going to be yanked out from under them in Kansas.  With such a massive uprising of the people, GBE's golden reputation in Kansas may be waning.  YOU can do it again.  You know how, and you've got the numbers!  The world is your oyster, transmission opponents!

So, GBE showed up at a recent meeting of the Joint Committee on Energy and Water at the Kansas legislature and made an obsequious presentation about the failed NIETCs and how great its project will be for Kansas.  You still love them, don't you, Kansas?  Kansas?  Hello?  Somebody needs a hug!

Remember how Invenergy has been claiming (in multiple states) that its transmission projects had NOTHING to do with the NIETCs and that Invenergy did not request them?  I have been pushing back against that for months because it is a big, fat lie.  Of course Invenergy submitted requests for NIETCs for all the transmission projects it is developing.  DOE asked for suggestions of where to make corridors.  They didn't have a crystal ball.  Invenergy DID request these corridors that so upset and horrified thousands of landowners across the Midwest.  Invenergy admits it at minute 12:00 of its presentation.  Listen carefully.

Right, like I've been saying... Invenergy requested these NIETCs.  Later on, Patrick whines that DOE didn't provide adequate notification and landowners got quite ticked off when they found out.  Invenergy was a huge fan of hiding its NIETC requests from landowners, until they got caught.  Then Invenergy first requested that its corridor be narrowed to half a mile, and in November it says it asked DOE to remove the corridor in its entirety.  Let's see... that's about the time you all got cranked up about the corridors.  Invenergy knew it was beat and threw in the towel.  You did this!  Congratulations!  You have the power!

And one more thing before I get onto the real revelation DOE and GBE is trying to hide from you now...

While Patrick Witty gave the presentation and began answering questions, he made the fatal mistake of calling Brad Pnazek up to the podium to answer a question.  The bombastic Brad took over and it was quite a while before Patrick was able to wrest the microphone away from him at the request of a legislator.  It might not have mattered if our friend Brad wasn't a prevaricator of the highest order.  Remember when Brad "misspoke" at a DOE EIS webinar to say that GBE wasn't necessarily a merchant transmission project and had not yet decided how its project would be structured?  Once again, Brad did not disappoint.  I'm going to be frank with you... Brad has a penchant for making crap up if he thinks it will help his position.  Even when the lie actually matters little, Brad can't help himself.  

Brad told the committee that while GBE pays 110% of fair market value, other utilities only pay 90% of fair market value for their easements.  C'mon, Brad, this lie doesn't even make sense!  All utilities are required by law to pay 100% of fair market value for the easements they want.  He followed that lie by saying that while GBE is only going to use eminent domain on around 4% of the easements needed, other utilities use eminent domain for 20% of the easements needed.  This is ANOTHER made up fact.  Utilities usually take less than 5% of the land they need using eminent domain.  A transmission line that attempted to take 20% would be a public relations disaster of epic proportions (sort of like requesting NIETCs, right, Brad?).

Gotta wonder about Brad.  Is he someone's relative or a political favor?  I understand that the Peter Principle elevates employees to their level of incompetence, but it's not just incompetence here.  Brad just can't help making crap up if he thinks it would sound good (in his own head).  Take note!  He's a ticking time bomb.  Deploy as necessary.

Now let's get to the most important and urgent revelation...

That's right, Patrick just casually dropped that in his presentation and the press (and everyone but me apparently) missed it.

As you may recall, Grain Belt Express has applied for a $4.9B loan guarantee (of taxpayer money) from the U.S. Department of Energy.  As part of its intent to grant that loan, the DOE is required by federal law to perform an Environmental Impact Statement on the project so that its environmental effects can be made public and taken into consideration when deciding to grant the loan.  Of course, you may also recall that the DOE granted a "conditional" approval of GBE's loan in its panicked, mad dash for the exit after President Trump was re-elected.  DOE has been madly pumping out the taxpayer dollars to its favored companies and projects ever since November.  GBE's "conditional" approval is contingent upon the completion of the EIS.  So does this mean that the EIS is merely a pre-determined exercise at this point, where the report is written to bolster the already granted approval?  Why even bother?

An EIS has several steps that the federal government usually drags out for years.  The first step is Scoping, where DOE shows the project to the public and asks them what it should study.  The DOE engages in the widest notification it can to make sure impacted communities can be engaged to make comment.  The DOE held public "workshop" meetings and accepted a boatload of public comment back in 2023.  Then DOE published a Scoping Report to share what they learned.  

And since then... crickets.  DOE did nothing with GBE's EIS for two years.  Guess they thought they had all the time in the world...  and then the real world intruded.  Now it's apparently a rush-rush, hurry up emergency.  DOE has set the MINIMUM time frame it can get away with to accept comments on its Draft EIS.  You have only 45-days to comment from the date the notice was published in the Federal Register.  You read the Federal Register every day, don't you?  You don't?  Of course you don't!  So, how is that public notice?  Sure, it's available to the public, if you know where to look and your crystal ball lets you know it's there.  Where's all the notice to the public?  Last time, DOE did media and sent notices to landowners.  DOE has a list of people who commented on the scoping in their possession.  Where's the notice?  There isn't any.  Isn't that where GBE and DOE got in trouble on the NIETCs?  Lack of public notice is a serious issue.  How can you tell when your government is trying to pull one over on you?  Lack of public notification of its actions.  DOE has become a very shady agency during the past four years.  Isn't it time to clean house?  At any rate, your deadline to comment is March 3, 2025.  

The EIS is over 400 pages, and has numerous appendices.  You're supposed to read, digest, and comment on all this in less than 45 days, because the clock has already started ticking.  Ask your Senators and Representatives to demand that DOE not start its 45-day clock until it has notified all impacted communities, landowners and the people who commented on scoping.  It's going to take more than 45-days to notify everyone and by that time the comment period is over.  This deadline and lack of public notification is ABSURD!  An extension must be demanded.

And just like the NIETCs, lack of DOE notification doesn't prevent grassroots notification.  Spread the word!  Let everyone know about the Draft EIS and the upcoming public meetings where people can get more information and make oral comments.  The meeting schedule is here.

There are ONLY 2 meetings being held across the state of Kansas.  How far are you expected to drive in the dead of winter to attend one?  100 miles?  200 miles?  300 miles or more?  There's also just 2 meetings for Missouri!  Let your elected officials know that this is an inadequate number of meetings!

And here's something else DOE "forgot" to tell you... you can request your own personal copy of the EIS, whether electronic or on paper.  Each paper copy DOE has to send out costs GBE several hundred dollars.  Request your paper copy by emailing:  
[email protected]
Please also read the Federal Register Notice to scan for other information that DOE didn't include on its EIS page.

Also take note that the EIS is a public recitation of the environmental impacts of GBE, it not a pass-fail test that promises no impacts.  The federal government is required to make the environmental impacts of its action public and allow the public to comment on them.  If you notice things that DOE missed in their report, let them know.  If you think their conclusions are wrong, let them know.  If you think DOE didn't adequately study alternatives, let them know.  And, most of all, let the DOE know that you demand they select the "no action" alternative that means they don't grant the loan.

This is going to be a lot of work, but don't give up.  Remember how your participation in group action cancelled the NIETCs.  You activated your elected officials and their involvement was crucial to your success.  Like the shampoo bottle says... lather, rinse, repeat.

As you may be aware, a group of Illinois landowners appealed a recent decision by the Federal Energy Regulatory Commission to somehow "continue" Grain Belt's Negotiated Rate Authority at the same time it granted completely new authority.  Of course, FERC can't do these completely opposite things at the same time.  The basis for Invenergy's intervention in the case and request to dismiss the case is that the Illinois landowners have no standing to bring the case because they have no interest in the outcome.

The landowners responded to Grain Belt's weak motion, asking, "What's it to ya?"  Only Paul Neilan could write a brief with that phrase in it!  His response was engaging and spelled out exactly why the Illinois landowners had an interest to bring this case.  When GBE applied for its Illinois permit, it told the ICC that it had negotiated rate authority from FERC.  The ICC based their approval on that fact, along with others.  If it turns out that GBE did NOT have negotiated rate authority at that time, then that is grounds to have the approval thrown out and GBE would have to reapply.  Of course, GBE's bespoke legislation that allowed it to apply for a permit in the first place has expired.  Therefore, GBE would have to get new legislation passed in Illinois that allowed them to apply again.  Because what FERC did in the Order under review tried to say GBE had "continuing" negotiated rate authority when FERC also claimed to have reviewed GBE's request anew, what happens in the FERC case is pivotal to what happens in Illinois.  Even a dense person could see that the Illinois landowners have standing.  You can read a copy of the landowner's brilliant response here:

GBE and FERC are caught between a rock and a hard place, claiming that FERC never needed to approve the sale of GBE from Clean Line to Invenergy under Sec. 203 of the Federal Power Act.  If that's true, then why didn't Invenergy notify FERC when it bought the project?

Neilan writes extensively about GBE's attempt to belittle Illinois landowners by calling them "A group of citizens who roam the country in search of governmental wrongdoing."  How disrespectful can you get?

Someone is respecting landowners and their rights, and it's not GBE or FERC.  Let's hope the DC Circuit Court of Appeals can set things right again!

Jefferson County is going to need a new slogan for roadside signs soon.  I suggest the above, maybe bolstered by some fine print... "All the electricity that makes Loudoun the wealthiest county in the nation comes through here first!"  What is Jefferson County getting from all this?  Homes and businesses taken using eminent domain, multiple huge new transmission lines of the highest voltage built in the U.S. in close proximity to our homes and schools, and higher electric bills.  What does Loudoun County get?  Data centers, lots and lots of new "economic development" data centers.  Loudoun County ended 2024 with a budget surplus of over $250M, thanks to all the data centers it has approved and built.  Loudoun County gets the gold, and West Virginia gets the shaft.  Again.

When are West Virginia lawmakers going to *wake up* and realize that we don't have to export the electricity generated here using our coal and gas resources?  We could use it right here to increase our own economic development!  Instead, we've been shipping the excess power we generate out of state so other areas can get rich using it to attract economic development like data centers.  Why not create incentives for data centers to locate here in West Virginia, right next to our existing generators?  West Virginia could finally start growing its own tech industry and use its plentiful resources to attract new business.  Data centers are hungry, hungry, hungry for steady, dispatchable electricity and promoting West Virginia as the ideal location for new data centers is win-win for West Virginia.  Exporting our electricity to Loudoun County over huge new high-voltage extension cords is lose-lose for West Virginia.

Yesterday, PJM Interconnection's Transmission Expansion Advisory Committee met for more than 4 hours.  A handful of intrepid electric ratepayers and citizens attended to make comment and ask questions.  At the end of the day, PJM stuck with its previous recommendation to order and build another new transmission line through Jefferson County.  Last year, PJM ordered the building of a different transmission line through our county.  Over the past two years, PJM has ordered two new major transmission lines crossing through Jefferson County on their way from West Virginia coal-fired generation stations to Loudoun County's data centers.  Yesterday, PJM informed us that it will be opening two more bidding windows in mid-2025 to solicit even more power lines for Virginia's data centers.  PJM is having trouble keeping up with Virginia's data center demand, and the only place with available power left is West Virginia.  Funny that Virginia hates our coal-fired power stations, and Virginia is on target to meet its VCEA requirement to reduce its carbon emissions to zero by 2045, but Virginia has no problem at all importing more and more coal-fired electricity to use in its data centers and pretending they're still meeting their environmental goals because it is not generated in Virginia.

The project PJM will be recommending to its Board of Managers for approval is a new 765kV transmission line beginning at the John Amos coal-fired power station in Putnam County, and crossing 14 West Virginia counties on its way to data center alley (Putnam, Kanawha, Roane, Calhoun, Braxton, Lewis, Upshur, Barbour, Tucker, Preston, Grant, Hardy, Hampshire and Jefferson) 3 counties in Virginia (Clarke, Frederick and Loudoun) and end in Frederick County, Maryland at a new substation south of Point of Rocks. If you want to see maps of where this project will be routed in Jefferson, find them here.  Here's PJM's awful maps and listing of the project's components.
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PJM's awful maps are insisting that the "new PATH" project will be constructed on "existing ROW or parallel to existing ROW" indicated by the pink line on the map.  Elsewhere in PJM's presentation was the statement that the new 765kV development would require 100% new right-of-way.  That's right... the new PATH will require a completely new 200 ft. wide right-of-way (ROW).  PJM and the new PATH sponsors are trying to pretend that they can create a new 200 ft. wide ROW directly adjacent and parallel with the existing transmission line corridor in Jefferson County.  PJM believes there is value and risk reduction in a parallel line siting.  That might be true, if there was actually land available parallel to the existing ROW, but there's not.  The existing ROW is lined with homes, schools, businesses and even new solar farms.  A new 200 ft. parallel ROW will destroy everything in its path.  For this reason, I insisted that PJM at least draw its "new PATH" correctly on its awful, out of proportion map as a new greenfield corridor.  PJM refused.   We can't even get a little honesty.

Who is PJM fooling?  Not us!  PJM is trying to fool its Board of Managers by telling them that nobody will mind this new 765kV transmission line and that it won't be taking any new land.  PJM thinks this will make the Board more likely to approve this project as non-controversial.  We're not going to let that happen, but that's another blog post coming soon -- writing to PJM's Board of Managers to insist they deal with the truth about this project.

As part of its creation of its new transmission plan, PJM is required to create a "Constructability and Financial Analysis Report" for the proposed projects to present to their Board when seeking approval.  PJM's Constructability Analysis is a complete joke!  The report starts out by detailing the "Approach", or method, of performing this study.

The approach calls for PJM to do an "in-depth" review of each project's ROW acquisition, land acquisition, and siting and permitting requirements, among others.  As part of this, PJM is required to do a "desk top" investigation of each project's land use mapping (using actual maps!) to include:

These are just a few of the things that must be studied as part of this Constructability study.  Did PJM do that?  No, they didn't.  PJM simply copied the narrative written by the project sponsor in its bid for the project and turned a blind eye to the actual impacts of this "new PATH" 765kV transmission line.

Here's what PJM's Constructability Study concluded about the project:

There's absolutely nothing in there about any of the development bordering the existing corridor they want to expand.  Perhaps if it doesn't have to acknowledge the destruction of Jefferson County's built community, then PJM can continue to believe that a parallel siting is somehow less risky than a new line somewhere else.

PJM negligence becomes even more glaring if you read the analyses of the other projects that were not selected.  Some of these other projects have very detailed narratives of how they will affect the built community.  Read it for yourself (full report).

Here's just a couple examples that caught my eye:

PJM also evaluated these projects based on the proposer's experience building similar lines.  In its report, PJM said that FirstEnergy (proposed owner of new PATH) passed this test.  When I questioned PJM about what 765kV lines FirstEnergy has ever owned or built, PJM said they were actually using the experience of another company, Transource (an AEP affiliate).  When asked how many 765kV lines Transource has ever owned or built, PJM again came up empty.  Ditto on Dominion.  The ONLY utility with this experience in the country is American Electric Power (AEP), parent company of Transource.  PJM's constructability analysis is not based on reality and has enough holes in it to drive a truck through.  The truth is that PJM simply FAKED this report based on biased information it was given by the project sponsors and didn't perform any analysis at all.  If this isn't true, then PJM is encouraged to produce the desktop study with all the required data and make a liar out of me.  PJM's Constructability Report is pure, unadulterated CRAP.

I also questioned PJM about whether the "new PATH" project was actually competitively bid.  Since 2011, FERC has required regional grid planners like PJM to open competitive bidding windows when it needs new transmission projects.  The idea is that utilities will compete with each other to create the best project at the least cost.  Bidders often include "cost caps" and other financial considerations that limit the costs to consumers.  PJM has been running these bidding windows for around 10 years now.  The big investor owned utilities did not like these windows because they don't want to have their profits limited by having to compete for projects.  So, the utilities started building smaller, local, supplemental projects that did not have to be approved by PJM as a way to avoid competition.  Because of this, there were pretty much no opportunities to build new transmission using competitive windows.  Therefore the utilities did not have to compete.  If you try to thwart the deep rooted greed of investor owned utilities, they will eventually find a way around whatever roadblock you construct. And now they have figured out a way around PJM's competitive bidding window.  The three biggest utilities in PJM got together ahead of time and came up with a scheme to limit competition and increase profits with their joint bid into this window.  FirstEnergy, AEP's Transource, and Dominion submitted "joint proposals" that did not have any cost caps or financial considerations for ratepayers.  If they didn't have to compete with each other, then they could score a project with an unlimited price tag.  Of course, this kind of behavior to limit competition and fix prices is what's known as a cartel.  Once the three utilities had their project selected, they have now decided to create a shell company "joint partnership" to own the projects because PJM cannot award a project submitted as a joint proposal to individual companies (that would violate FERC's rules!)  Reality is that this "competitive" window was illegally controlled by a cartel.

Last month, I sent an email requesting that PJM come to Jefferson County and give us a presentation about what it is they do so we can find out about their processes.  This was in response to a disparaging comment one of the PJM staff made to a Jefferson County citizen, telling her to "get a basic education" before asking questions at the TEAC.

This month, PJM came prepared with a long list of online "resources" that we can use to educate ourselves.

Invenergy has been trying to build its merchant transmission Cimarron Link project since at least summer of 2023.  That's when its courting of landowners was brought to my attention.  It is likely that it has been in the works much longer.

A merchant transmission project is to transmission what a private toll road is to transportation.  There is an existing network of electric transmission lines that serve all public utilities that provide service to all who request it.  Because this is a public network (compare to a public highway) everyone who takes electric service pays a portion of constructing the network and keeping it operating.  Our tax money pays to keep our highways maintained for everyone's use.  But a merchant transmission project is a supplemental, speculative transmission line.  It is not necessary for public utility service and it is not subsidized through our electric bills.  It's a private electric toll road to ship electricity that is paid for by the electricity wholesalers who choose to use the private roadway to receive electricity they purchase from generators.  A merchant transmission line relies on voluntary customers to pay for its construction and operation.  If a merchant transmission project doesn't have any paying customers, it's not economic and cannot be built.  It is a speculative investment by private companies who want to bet that if they construct it, it will attract paying customers.  Much like a private toll road highway, it is not for the use of the general public, but only those who can pay the toll to use it.

Cimarron Link is a merchant transmission project.  It is not needed for reliability or economic purposes, and it is not part of any transmission plan by regional grid operator Southwest Power Pool.  It's "need" would only come from paying customers who want to use it.  But Cimarron Link doesn't have any customers!  Therefore it applied to receive a capacity contract from the U.S. Department of Energy, and it was awarded such a contract in 2024.

The capacity contract is essentially the U.S. government using taxpayer dollars to pay the "toll" on Cimarron Link.  But the government isn't a public utility and does not supply electricity to anyone.  The idea is that the government will underwrite the cost of constructing the project with the hope of re-selling the ability to use the toll road to an actual utility somewhere down the line.  Of course, anyone could sign up to pay the toll now, but they haven't.  If they don't want to use Cimarron Link now, what's the chances that they will want to pay the toll later, after the project is constructed?  There is no precedent for this new capacity contract program and it is unproven that it will actually work.  If it doesn't, the government will continue to pay the toll for Cimarron Link for up to 40 years in the future, even though it is not actually using it, and Cimarron Link may never deliver any electrons to anyone.  The government is acting as a speculative investor, betting that it can sell something that Cimarron Link cannot.  Good luck with that!

So, Cimarron Link lined up at the hog trough to help itself to a $306M capacity contract.  While it was filling its belly, it also thought that maybe a National Interest Electric Transmission Corridor would taste good, so it applied for one of those as well.  A NIETC would have been a federal land use designation that created a zone for construction of Cimarron Link and would make it eligible for federal permitting and eminent domain if not granted by the State of Oklahoma.  But that didn't work out.  The U.S. Department of Energy cancelled the proposed Delta-Plains NIETC that Cimarron Link wanted to use to route its project across Oklahoma.  Now Cimarron Link can only use Oklahoma laws to try to take property using eminent domain.  If Oklahoma does not grant Cimarron Link eminent domain authority, the project is essentially dead.  Sure, Cimarron Link can continue to try to obtain voluntary easements across private property, but if the landowner refuses, that's the end of it.

Which brings us to Cimarron Link's recent suits against landowners to obtain an injunction allowing Cimarron Link to enter private property to perform "surveys" against the landowner's wishes.  When it filed its lawsuits, Cimarron Link claimed it was "authorized to exercise the power of eminent domain for the appropriation and use of lands and rights-of-way necessary for a public purpose by law specifically, Tit. 27 Okla. Stat. Sec. 7 and Tit. 66 Okla. Stat. Sec. 51-60."    Cimarron Link claimed it was a corporation that was engaged in the transmission of electricity in Oklahoma.  But is it really?  Not right now it isn't.  It's not furnishing anything to anyone.  But it wants to do so.  So, it's not really clear that Cimarron Link's speculative merchant transmission project is authorized to use eminent domain.

Now, maybe Cimarron Link thought it would be easy to convince a local judge that it currently has that ability so that it could force its way onto private property to do surveys for its transmission project.  But the people fought back and said it did not have that authority under state law. 

Maybe Cimarron Link thought it could continue operating under the radar long enough to get such a determination by a local court, but that idea ended when it got too greedy and helped itself to a NIETC designation.  The people of Oklahoma found out about that, and they were incensed.  Huge opposition to the NIETC soon developed and all of a sudden people stopped cooperating with Cimarron Link.  The sleepy days of keeping quiet and bullying landowners to sign voluntary easements are over.  Now Cimarron Link has a huge problem on its hands.  It is not clear that Cimarron Link has eminent domain authority, and the people are refusing to sign voluntary easements.  Cimarron Link's little piggy has eaten itself into a full-blown HOG, and we all know what happens to hogs... they end up on the dinner table!

Perhaps sensing that its effort to convince a court that it has eminent domain authority wouldn't be successful, Cimarron Link recently withdrew its suits for entry against landowners.  But it did so without prejudice, which means Cimarron Link reserves the right to bring this issue before the courts in the future.  Cimarron Link said it was withdrawing its suits to "allow more time for engagement with landowners."  Well, good luck with that, Cimarron Link, landowners have formed a wall of resistance and are having none of that, thanks to the opposition that developed during the NIETC debacle.  Word has it that Cimarron Link is trying to move on to adjacent landowners and begin its game on a new, unsuspecting public, but is that really going to be successful in the new public relations disaster environment that NIETCs created?  What other tricks might Cimarron Link have up its sleeve?

Cimarron Link is a project owned by Invenergy, a private energy firm based in Chicago.  Invenergy has invested in several merchant transmission projects around the country.  One of its projects, the Grain Belt Express, was rejected by Illinois courts because it wasn't a public utility with the ability to use eminent domain.  Illinois law required that a public utility actually be currently engaged in the business of furnishing power in order to file an application to build a transmission line that could use eminent domain to acquire land.  Like Cimarron Link, Grain Belt Express was a speculative project by a new entity that was not a public utility.  But Invenergy found a way around that by creating bespoke, special purpose legislation that granted it eminent domain authority in a handful of counties it wanted to cross and allowed it to apply for a permit.  This special purpose legislation was tucked neatly into the Illinois Climate and Equitable Jobs Act (CEJA), an energy bill that comprised thousands of pages and was dumped on the legislature just hours before the vote, making sure that legislators didn't have time to even read it before voting.  As a result, the legislation passed, and Grain Belt Express was suddenly a public utility that could use eminent domain to acquire land for its merchant transmission project.  Now, I'm not saying that Invenergy's fattened hog is going to use the same tactic in Oklahoma to ensure it has the power of eminent domain before re-filing its suits to enter and take land for Cimarron Link, but it's certainly possible.  Keep an eye on what's happening at the Oklahoma legislature this year!  And while you're keeping an eye out for amendments to Oklahoma eminent domain laws, perhaps you might want to propose some of your own?

Thanks to the NIETC public relations disaster, landowners are talking to each other and comparing notes about the things they have been told by Cimarron Link.  And, if any of the things I have heard are true... shame on you, Cimarron Link!  Invenergy's Grain Belt Express project has a "Code of Conduct for Land Agents" that set some ground rules for interaction with landowners.  Oklahoma landowners might be quite shocked to find out which tactics are not allowed on a different Invenergy merchant transmission project.  Why isn't Invenergy using this same Code for the Cimarron Link?  Don't Oklahoma landowners deserve the same respect and honesty as the landowners in Kansas, Missouri, and Illinois who are targeted by Grain Belt Express?  Maybe someone wants to ask Invenergy why it doesn't have a Code of Conduct for Cimarron Link?

Cimarron Link's little piggie ate too many government handouts and has now turned into a full blown hog.  Everything was going great until Cimarron Link ate that NIETC dangling over its trough.  Cimarron Link brought this public relations disaster upon itself, and now it has to pay the consequences.