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Ogres, Orks, Obakes and Offsets

4/30/2023

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What do these four things have in common?  They are entirely mythical.  They simply don't exist in reality.

This article caught my eye this week.  Google is partnering up with EDPR to build "community solar" that will power Google's gigantic data center power suck.  Except they won't.  The new solar projects won't provide power to Google data centers.  They will simply "offset" Google's enormous thirst for electricity supplied by coal and gas-fired power plants.  After all, if Google actually powered its data centers with solar, you wouldn't be able to use Google after dark, and everything would be erased by dawn each morning.  Instead, Google uses good old reliable fossil fuel burning electricity and activates its climate guilt to build renewables somewhere else for someone else to use.

It's a scheme that has been around for awhile.  Years ago, I investigated "renewable energy credits", or RECs to find out that they aren't actually energy at all.  While renewable generators provide and sell power to actual customers, they also sell RECs.  A REC is the social and environmental attributes of renewable power.  It is a completely separate product that is bought and sold, although it doesn't actually exist.  A REC is mythical, just like an offset.  An offset pretends that a power customer like Google can "offset" its carbon footprint by producing enough renewable power to match its use of fossil fuel power.  They believe if they produce as much power as they use then it negates their use of power.  Someone else's use of that power is supposed to substitute for that person's use of dirty power.  Except does it really?  If Google cannot rely on solar power 24/7, can anyone else?  Of course not.  We all use power 24/7.  This is starting to sound like a pyramid scheme where other people get stuck using unreliable renewable power 24/7 while Google uses all the good, reliable stuff without guilt because it has "offsets."

This is pure nonsense!

Sure, giving away money generated by the sale of community solar power is all Robin Hood-ish.  But would the community solar actually benefit the community in which it was sited if that community did not meet the financial qualifications?  Or is Google going to build these community solar projects in rural areas and give the profits to energy users in urban areas that qualify?  It's all so much fairy tale fantasy.

Ditto on the idea that overbuilding of renewables and connecting them all by overbuilding transmission can somehow make up for renewable power's unreliable intermittency.  But yet the political minions claim this to be so because it all works out on average.  Average.  A math problem.  If we have this much renewable power, and it has an average capacity factor of 30%, then if we build 70% more than we actually need that will create a 100% capacity factor. 

Capacity factor is the percentage of a power plant's maximum capacity that is actually produced.  Power plants cycle up and cycle down to follow load.  They don't run at their full capacity all the time.  However, renewable generators cycle up and cycle down at the whim of nature and load is supposed to follow them.  There's the difference.

Presuming that a region with lots of intermittent renewable power can "borrow" from its neighboring region when it doesn't have enough power doesn't work because its not a math problem.  It's reality.  What if the neighboring region is also experiencing inadequate generation?  Night is long, and an hour's time difference isn't going to cover it.  Say the sun sets in the Pacific at 9:00 p.m., and the sun rises over the Atlantic at 6 a.m.  There's a three hour time difference, so the Pacific solar generation ends at midnight Atlantic time.  It's still 6 hours before the sun rises there. 

Battery power, you say?  But we don't have the technology to store electricity for long periods of time, batteries are very expensive, and they come with their own environmental burdens.  Not a solution.

We have not found the "clean power" silver bullet.  It's not wind + solar + transmission.  However, saying it is makes certain people and certain companies very, very rich.  What a bunch of patsies!  Making crap up for the sake of political and financial gain is never going to stop.  However, we can all get a lot smarter and stop believing it.

When the power flickers on and off in the middle of the night, I used to think it was an equipment failure somewhere, roll over, and go back to sleep.  Now when it happens, I feel compelled to get out of bed to check my phone to make sure the grid hasn't crashed in a spectacular way before I can relax enough to go back to sleep.  Welcome to the land of Ogres, Orks, Obakes and Offsets.
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Appeal Filed on GBE's Illinois Permit

4/25/2023

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So begins another round of permit wack-a-mole for Grain Belt Express...

Last week, the Concerned Citizens and Property Owners, along with four other parties to the Illinois Grain Belt Express permitting case, filed appeals of the approval of the Illinois Commerce Commission.  You may read one of the essentially identical appeals here.

At this stage, it's a simple notice of appeal.  The case for granting it will be made in a series of briefs that will be filed as this case progresses.  For now, the notice sets out what the appellants are seeking.  The appellants...
...request that the Appellate Court for the Fifth Judicial District REVERSE the above referenced orders of the Commission in their entirety, and declare Section 8-406(b-5) of the Public Utilities Act unconstitutional as Special Legislation, as violative of the Equal Protection Clause, and as violative of the Separation of Powers Clause.
The appeal asks the Court to nullify the ICC's permit for Grain Belt Express and nullify the special Grain Belt Express legislation that was passed at the legislature last year and signed by the Governor.  If granted, it would put GBE back to square one in Illinois.

It stands a very good chance of succeeding.

While the arguments in briefs have yet to be filed, I expect the arguments to be very similar to the ones these parties made before the ICC.  Those arguments were rejected by the ICC, which is just as well because it is an issue for the courts.  The ICC cannot declare legislation unconstitutional and refuse to follow it, that's a court's job.

For now, we must wait to see the briefs.  Stay tuned...
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Missouri PSC Staff Questions Approving GBE

4/23/2023

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I'm guessing these professionals don't have a particular hankering for vanilla panna cotta with GBE sauce, like the Kansas regulatory staff does.  The Missouri PSC Staff thoroughly and carefully went through all the evidence Invenergy filed in the Grain Belt Express application to amend its permit and they have refused to rubber stamp it while gorging themselves on utility sweet treats.

All testimony is available here by entering Case No. EA-2023-0017.  I urge you to read it yourself, I'm only providing a very high level summary.  You will enjoy all the juicy details by reading it in its entirety.

The Staff provided its Report summarizing the testimony of 9 separate witnesses.  They were quite thorough.  And they weren't buying GBE's nonsense.

The Staff Report says that Invenergy's purported "changes" to its project are not presented in their entirety.  There have been lots of changes that GBE simply skipped over without notice in their application to amend.  These changes matter.  For instance:
  1. The project does not have bi-directional capabilities whereby it may reverse flow from west to east to east to west.  The Commission's permit says it does.
  2. The project is going to take a lot more than 9 acres of agricultural land out of production.  Even though the PSC touted that fact in its approval, Invenergy has since changed the monopoles to 4-legged lattice towers with a much bigger footprint.
  3. Invenergy has petitioned the Federal Energy Regulatory Commission for approval to charge captive customers who don't use the project for "reliability" and "resilience" services.  The PSC's permit says none of GBE's costs will be recovered from Missouri customers who don't sign up to use the line.  That may no longer be possible.  If FERC approves the cost shifting, there is nothing the PSC can do about it, except fail to approve the project.
There's more... read it!

The Staff Report also says "...much of Invenergy’s evidence 'depend[s] on puffery, evolving understandings of the project itself, and the constant changes in supply, demand, and pricing of electricity in the market and for that potential supplier or customer.'"

The Staff Report questions the MJMEUC contract because it does not note geographic changes in interconnection location.  How much does the change cost customers in new transmission charges?  Is the contract still valid?

Most importantly, the Staff Report recommends against approving Invenergy's two phase project because the Commission's original approval noted that the project's economic feasibility depended upon selling service in PJM to make up for below cost contracts like MJMEUC's.

Individual witnesses had more to say.

Shawn Lange wrote about MISO's Long Range Transmission Plan Tranche 1 and how new lines in that plan provide regional solutions to future energy needs, avoid reliability projects and age and condition replacement projects, increase import capabilities to Missouri by enabling access to subregion resources, and finally, it  decreases local resource adequacy needs.  Lange brings up an open FERC complaint where Invenergy is arguing that MISO must include an operating GBE in its future base case upon which it begins its planning.  Invenergy says that if MISO did so, then some of its LRTP lines wouldn't be necessary because GBE will take their place.  Invenergy supplied an analysis to FERC that says says GBE + LRTP would cause negative effect on benefits that LRTP would otherwise bring to certain MISO zones, like Missouri.  Missouri would receive less benefits from LRTP if GBE is constructed. 

Claire Eubanks questions whether the 150% FMV compensation for Tiger Connections easements actually makes up for the elimination of structure payments.  The Guidehouse study that GBE bought and filed as evidence can only be relied on in a general sense because specific results are skewed.  The Study assumes bi-directional operation and does not account for LRTP benefits.  Here's an interesting quote, "...in a general sense, the wind resources available in Kansas may have a higher capacity factor than those in the east, but the accredited capacity of wind and solar is lower than other resources. In other words, either storage or thermal resources are still needed to alleviate the capacity shortfall driving the 2022/2023 PRA results.”

Michael Stahlman says cost of the project has doubled, but GBE's one contract with MJMEUC has not changed how much it must pay.  He recommends against a two phase project.
“The Commission previously found that the economic feasibility of the project is dependent on the project’s ability to sell to PJM as the revenues from the Missouri converter station, based on the MJMEUC contract, were insufficient to cover the project’s costs.”
He noted that GBE has applied for a DOE loan for up to 80% of the project's costs.  The DOE loan would limit Invenergy's financial risk.

He attacks the Repsher study Invenergy bought and filed as evidence.  He says it assumes a generation mix that does not exist and does not consider the cost of generation.  It also relies on both project phases, not just one to produce benefits.  It assumes a generation mix that does not exist.  It does not consider the cost of generation.  It relies on unreasonable renewable generation capacity factors (74%).
“...the impact of generation that fluctuates hour to hour may ultimately increase prices. The injection of wind or other intermittent energy in a given area can result in the energy markets needing more expensive generation that can handle the ramping up and down of energy supply. Such generation is often more inefficient, which can paradoxically result in higher emissions, not less. A comparable example is the fuel efficiency of a vehicle at highway speeds compared to the same vehicle in stop-and-go traffic.”
He has concern that the Commission will have no jurisdiction over phase 2 once phase 1 is constructed, as that may shift jurisdiction to FERC.

Michael Rush says GBE is not a “national security” asset any more than any other transmission project.  He questions claims that GBE could support national security assets because the claim is not backed up by any contracts.  He says the testimony of GBE witness Monken should not be relied upon.

Krishna L. Poudel says GBE is not included in Ameren or Evergy integrated resource plans, even though GBE claims it could help meet the these goals.

Cedric Cunigan says, “Staff recommends that the Commission order the Company to provide documentation that all relevant permits have been received prior to approval or, in lieu of that, the Commission should condition any approval on all relevant permits being approved and submitted prior to beginning construction of the Tiger Connector.”

Alan Bax says the permitted Ralls Co. AC connector line was located near the converter station.  The Tiger AC connector line is 40 miles away from the converter.  Tiger is a substantial change as it requires 40 miles of new right of way.  And he says the new Ameren substation located at the Tiger interconnection point could be charged to captive Ameren customers.

Whew!  It looks like the Missouri PSC professional staff is not feeling the love.  Of course, GBE is permitted to file a rebuttal to the Staff's testimony, and then the evidentiary hearings will allow for cross examination of all the witnesses, both Staff and GBE.

Will the Commission listen to the warnings of its professional staff?  Or will they wander off and make a political decision that does not protect Missourians?  Only time will tell!
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Although politics produces a vast supply of hot air, it cannot keep the lights on

4/20/2023

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Did you submit your comments on the U.S. Department of Energy's draft National Transmission Needs Study yet?  Today is the deadline.  You have until midnight.  See this for more information and instructions for sending your comments.  It's really easy -- you simply send them an email.

Why is this important?  Because this "study" (and I use the term lightly, very, very lightly) will determine where new transmission is "needed" in the U.S.  DOE's study says it is "needed" everywhere, aka maybe at your house?  Once DOE says it's "needed" in the final study, then greedy transmission developers will ask DOE to designate a transmission corridor for every unneeded, money-making project they can dream up.  Once DOE designates a corridor for every transmission project that anyone wants to build anywhere, that activates federal eminent domain and permitting by the Federal Energy Regulatory Commission.  That's right, this "study" is ground zero for having your land taken using federal eminent domain.  It's all downhill from here once DOE issues its final study this summer.  This is your last chance to let them know what you think.

Want to know what I think?  Of course you do, or you wouldn't be here!  I just sent in my comments.  They start off like this...
The Law of the Instrument is a cognitive bias that is often expressed with the phrase, "If
the only tool you have is a hammer, every problem looks like a nail.” The draft National
Transmission Needs Study epitomizes the Law of the Instrument because it prioritizes
transmission as the only possible solution. Three years ago, DOE’s last congestion study
concluded, “…the Department has not identified transmission congestion conditions that would merit proposing the designation of National Corridors.”   Now the Department has
found terrible congestion in an area so vast that if the DOE were to designate corridors to
solve it, the entire continental U.S. would be one gigantic “corridor.” The only conclusion that can be drawn by these drastically different findings is that the DOE’s transmission studies are not based on data and science, but on political goals. This does not benefit the citizens the Department exists to serve. Although politics produces a vast supply of hot air, it cannot keep the lights on.
Click here to read the rest of it. 
national_transmission_needs_comments_final.pdf
File Size: 106 kb
File Type: pdf
Download File

Speaking truth to power can be fun!  Don't miss out!
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Chump Change

4/19/2023

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An insignificant amount of money that is thought to be a lot of money by a blockheaded chump.

I see that Buchanan County, Missouri, signed a Grain Belt Express Road Use Agreement for chump change, seemingly because Randolph County did it first.
...in the Buchanan County Courthouse, where Grain Belt has agreed to pay more than $300,000 over 20 years to bring the power line through this area.
The deal, based on a similar agreement in Randolph County, would provide Buchanan County with one lump-sum payment of $75,000 plus $15,000 annually for 20 years.

So there Buchanan County was, in the catbird seat where it could have asked for anything in exchange for signing Grain Belt's agreement... and they settled for chump change.

Why is $75K up front and $15K a year an insignificant amount for Buchanan County?  According to the Google Gods, Buchanan County's annual budget for 2022 was $85.6 million.  That's MILLION.  Those Grain Belt payments are hardly going to make a dent in that.

Grain Belt could be using (and abusing?) Buchanan County's roads during construction of GBE (if it actually ever finds any customers to create project revenue).  The agreement says GBE will repair the roads after construction.  Right.  I'm sure GBE will cheerfully agree to repair every road it damages, even those off the haul routes, or ones where nobody has proof that GBE contractors caused the damage.  The key point here is that GBE will only repair the roads that it agrees it damaged.  I've yet to find a construction truck that admits or apologizes for road or berm damage.  Good luck, Buchanan County!

Even after construction is "complete," the transmission line could be there for perpetuity and like any aging transmission line it may need repairs and upgrades.  Good luck there, Buchanan County!

So, how much is $15K in Grain Belt's world?  It would be like me flipping a dime at one of those professional panhandlers that stand at traffic lights pretending to be homeless.  Did Buchanan County stop to consider (maybe even ask) how much revenue GBE could bring in if it ever finds any customers to pay for it?  It's probably a lot more than $15,000 per year.  It's probably more like $15,000 per hour.

Gosh, what a deal you made for your citizens, Buchanan County!

If they weren't sure of the relevance of $15K to GBE and whether or not it was a considerable sum for allowing GBE to cross county roads, maybe they could have assured that they were paid what it was worth by asking for a percentage of the annual profit, instead of a set sum that becomes less and less valuable over time as the value of money falls.

Chump:  a foolish or easily deceived person.
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    About the Author

    Keryn Newman blogs here at StopPATH WV about energy issues, transmission policy, misguided regulation, our greedy energy companies and their corporate spin.
    In 2008, AEP & Allegheny Energy's PATH joint venture used their transmission line routing etch-a-sketch to draw a 765kV line across the street from her house. Oooops! And the rest is history.

    About
    StopPATH Blog

    StopPATH Blog began as a forum for information and opinion about the PATH transmission project.  The PATH project was abandoned in 2012, however, this blog was not.

    StopPATH Blog continues to bring you energy policy news and opinion from a consumer's point of view.  If it's sometimes snarky and oftentimes irreverent, just remember that the truth isn't pretty.  People come here because they want the truth, instead of the usual dreadful lies this industry continues to tell itself.  If you keep reading, I'll keep writing.


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