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AEP Wind Catcher Support Letters to Oklahoma Corporation Commission Signed by AEP Employees

5/29/2018

3 Comments

 
What's a company to do when it wants to create a feeling of overwhelming support for regulatory approval of one of its projects, but it lacks overwhelming support?

Create it with home-grown resources!

Shame on you, AEP!  Your scam wasn't even that hard to figure out.  Which ever one of your "geniuses" came up with passing the tablet in the workplace ought to be fired.

At the very least, the Oklahoma Corporation Commission should be forced to collect and toss any letters of support for the Wind Catcher project that came from AEP/PSO employees and failed to disclose that the author worked for AEP and had a conflict of interest.  That should lighten the docket immensely. 

A little birdie told me that the OCC Commissioners were looking at huge piles of support letters for the Wind Catcher project on their desks.  Perhaps Commissioners were feeling a bit obligated to approve the project's rate scheme because of such overwhelming support.  So, I looked at the OCC docket for the case.  And I found one of the links to collections of public comment on the project.

Funny that... most of the letters were strikingly similar, in fact so similar that they are obviously form letters.  All contain the following  closing paragraph:
For the aforementioned reasons, I sincerely support and endorse Wind Catcher Energy Connection and the benefits that it will bring to Oklahoma. Oklahoma cannot afford to miss out on this opportunity to invest in our state and the citizens of Oklahoma. I would like to thank the Oklahoma Corporation Commission for their thoughtful consideration on this matter.
And they are all obviously signed on an electronic tablet because each individual signature has that telltale "drunken illiterate" look so common to finger signatures on electronic tablets, where the signature box is well defined and limited.

So, who was collecting signatures in support of the project?  Was it some of the usual suspects like Sierra Club?  Well, yes, of course, but an online letter does not create a distinctive tablet signature, and there's no way Sierra Club could draw that many people to a venue in order to sign their tablet.  Sierra Club is no longer a member run organization and has lost its base because it is too focused on scoring grant money anymore.  Who else is running a "send a support letter to the OCC" campaign for Wind Catcher?  Well, Invenergy is.  That's sort of like cheating though, since Invenergy stands to profit enormously if AEP gets its project approved and buys Invenergy's wind farm.  Shame on you, Invenergy!  But even then, how could tablet signatures get generated online?  And why doesn't Invenergy's form letter of support include the telltale concluding paragraph?

Where were these "supporters" gathered?

I tested my first theory that all "supporters" from a certain date may all live in one city and may have attended a single public event where the tablet was passed.  Since the OCC blocked out the addresses of the "supporters" I had to zero in on unique or unusual names to find out what cities the supporters lived in.

And then I found something really interesting.

Kristine Kurszewski.

She supports Wind Catcher.

She's also an Administrative Assistant at Public Service Company of Oklahoma at Bartlesville.

Wow, what a coincidence, right?  Out of all those dozens of support letters docketed at the OCC I just happened to pick one written by an AEP employee.

Except then there was:

Tiney Holyfield, a Project Control Analyst at American Electric Power in Oklahoma City.

Larry Gattenby, an IT Support Technician for AEP.

Levi Grooms, a Project Manager for AEP in Tulsa.

And lots more, but it was starting to get repetitive. 

It looks like all Wind Catcher's "support" letters were signed by AEP/PSO employees across Oklahoma.  What better place to walk around with a tablet and get employees to give you a finger signature?  I wonder if the employees even knew they were signing a support letter to the OCC?  Or did they think they were signing some routine workplace form?  How voluntary were these signatures, anyhow?  Did employees feel pressured to sign the tablet?  I think AEP has a lot of explaining to do to the OCC...

It also needs to fess up to jamming the docket with fake letters of support from its employees.  Once all those fake form letters are gone, the letters of opposition will rise and shine.  They're in there, but buried among the AEP employee form letters so only a very patient person would be able to locate them.

If the OCC Commissioners have piles of support letters on their desks, they need to weed out any written by AEP employees, whose employment may or may not be tied to their willingness to sign AEP's tablet.  Such "support" cannot be seriously considered as reason for approving such a bad project.

Shame on you, AEP!  SHAME ON YOU!!!
3 Comments

Franklin Co. Sends Transource Packing

5/24/2018

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It was both inspiring and heart wrenching listening to Franklin County residents testify in opposition to the Transource Independence Energy Connection during four PUC public hearings this week.  More than 100 people showed up at the first hearing on Tuesday afternoon, and many of them testified under oath.
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Resident after resident stepped up to the microphone to tell the judges how this project would affect them.  We heard about how this project would burden farmland, oftentimes land that has been in the family since the 1800's.  Farmland sometimes serves as a farmer's retirement plan and much of a farmer's wealth is tied up in his land.  A new transmission line across it not only devalues it, but can make it worthless for future uses.  How many people in No. Va., D.C., and Baltimore do you suppose are offering up a part of their retirement savings in order to make power a few cents cheaper each month?  But yet they ask these hardworking farmers to take that kind of hit.

We also heard from a developer who owns a master planned community in Franklin whose beautiful views, property value, and economic well-being will be forever marred by the presence of this transmission line through the valley.

One of my favorites was a professor of economics from a local university who couldn't find any economic benefit for Franklin County, and quoted some absolutely hysterical lines from Paul McGlynn's testimony that made absolutely no sense.

Katie Hess from South Mountain Partnership approached with maps, studies, and other publicly published exhibits and testified at length about how the project would impact farmland, economics of the region, and the environment.  She also shared that she approached Transource early on in the process in an attempt to develop a partnership of sorts to help site the line to have the least impacts.  Transource dismissed and rebuffed her efforts.  I guess they're now reaping what they sowed.  At the end, Transource's attorney objected to her exhibits as "heresay."  Overruled!

The president of the Franklin County Area Development Corporation testified that Transource's claimed economic benefits to Franklin County were biased and perhaps exaggerated.  Based on his many years of experience developing the economy of Franklin County, he said Transource has failed to quantify the benefits and articulate the need for this project.  He also had an amusing Transource story to tell... that the company assumed he would automatically support the project and sing its praises.  However, he is adamantly opposed.  He is the first local economic development professional I have seen to reject a transmission proposal.  I greatly admire his honesty and professionalism on behalf of the people of Franklin County!

And, of course, a union shill showed up.  Funny that... the first person signed up to speak was Bernie Kephart.  Except he wasn't there.  How did his name get on the list?  Did he sign up remotely?  Or did someone else sign his name, hoping he would show up?  Bad form, Transource.  Extremely bad form.  Don't junk up speaker lists with names of people who aren't even present.  And the one union guy who did speak told everyone they wouldn't even notice the power line after it was built.  He got a roar of laughter so powerful even he was laughing as he slunk away from the microphone.  Pretty ridiculous!

Attendance was also high at the three subsequent hearings, with about 100 speakers voicing opposition to the project, and many more filling the venue to support the opposition.  The only ones voicing support for the project were a few union plants and a farmer/transmission construction company owner from another part of the state who says he does $30M of business yearly.  Ya know, Transource, you did a lousy job drumming up fake advocacy for your project.

But who needs advocacy when you have liars like Todd Burns schmoozing up the media?  He actually said PJM "identified a deficiency in the grid."  No, it didn't.  It identified a price differential between the cost of electricity in Pennsylvania and the cost of electricity in Washington, DC.  There's absolutely nothing wrong with the grid.  It is not "deficient."  We don't need to "reinforce the grid."  Liar, liar, pants on fire!

It's time for Transource to pack up all its lies, its exaggerations, its fake claims of benefit, its totally false pretense of "working with the community," its injunctions and abusive, lying land agents and take the whole kit and kaboodle back to Columbus, Ohio.  That's not the way the good people of Franklin County live their lives.  You're not fooling anyone, Transource.  Nobody at all.

I'm pretty sure the PUC administrative law judges left Franklin County with plenty of truth, however.  The citizens came out strong and spoke from their hearts.  That's a big win in the regulatory world!
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Investor Owned Utilities Hope To Make Big Bucks Buying Wind Farms and Building Transmission Lines

5/23/2018

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News Flash, right?  Not really.  Investor Owned Utilities (IOUs) are always hoping to make big bucks -- that's what their investors want them to do.  And making a buck for investors trumps serving the public need every time.  Every.Single.Time.  I'm not sure who ever thought it was a good idea to allow entities who peddle a public service, like utilities, to be investor owned, for-profit, monopoly corporations.  It sort of defies common sense, if you think about it too much.  There are plenty of municipal or co-op utilities that operate on a profit neutral basis, of course that just means that they have to give back anything left over, instead of paying a dividend to investors.  It doesn't necessarily rein in their spending to produce lower rates for customers.

IOUs make money owning stuff.  Sure, they make money supplying you with electricity, but they make the big bucks by owning stuff (for your benefit, of course) that you pay off over a long period of time, with interest.  It works almost like a real estate mortgage.  The IOU (and its investors) put up a sum of cash (or credit) to pay for something like an electric generation station, or a transmission line.  You pay them back for that investment over a period of many decades, often at 10% or higher return (or interest) on your unpaid balance.  Your mortgage statement probably tells you exactly how much principal and how much interest you pay each month.  Your electric bill never does.

And here we are, smack dab in the middle of a changing preference for electricity generation.  Gas is cheaper than coal, and much generation has switched in recent years.  New gas plants mean new IOU assets you will pay for.  And then there's the wind hype.  Greenwashing is also brainwashing people to think they can meet all their electric needs with wind power generated... somewhere else (not in MY backyard!).  And Big Wind (yes, that's a proper noun) is in a huge panic to build, build, build before the federal Production and Investment Tax Credits expires at the end of 2019.  Wind turbines generate money as they turn -- .023 for every kwh produced for their first 10 years of operation.  Wow, what a savings, huh?  Except where do tax credits come from?  Where does the money come from?  It comes from YOU, little taxpayer.  It comes right out of your pocket, and many of the companies receiving these generous credits are foreign corporations.

So, with the big wind push, everyone wants to own one of these money mills, or maybe a big, fat new transmission line to be used to move the kwh generated to willing buyers.  Who are the buyers?  They're the utilities that serve customers.  Pretty much no electric customers buy their electricity directly from a wind farm.  Their utility makes the purchase from the wind farm and re-sells the electricity to you.  But an IOU getting all its power via purchase agreements with companies that own the generator isn't getting that big, fat return on owning the generator, a guaranteed income stream for decades.  The same is true of transmission lines... no IOU wants to pay some transmission company (like Clean Line Energy Partners) for service when it can own the transmission line (and the return) itself.  Note to Clean Line:  This is why you failed!  The IOUs may be slow, but they're not exactly dumb when they smell money.  So it's happened that now it's all the rage for IOUs to buy wind farms and build new transmission lines to connect the wind farms with customers.  The IOU makes a return on the cost of the wind farm, the customers cover all the costs to operate the wind farm, and it also makes a big return on any transmission line it owns (and you also pay operating costs for the line).  And if the IOU can get these deals approved fast enough, they can also collect all the tax credits that fall out of the sky when the turbines spin.  Some companies claim that they will use the credits to make the electricity cheaper for customers, and that with the credits, owning the new generator actually makes electric costs cheaper.  Win, win, win!!!

But IOUs, as monopolies, need the permission of regulators (who are supposed to take the place of competition in a monopoly construct) to recover the costs of buying generators and building transmission lines from customers like you.  American Electric Power was the first big IOU to jump into the pool, asking regulators in four different states to approve their plan to buy the nation's biggest wind farm and build a big new transmission line to connect it, and charge the costs of doing so (and their return, of course) to customers.  AEP's execution is faulty.  Not only did they fail to follow utility regulations that require a competitive bidding process for new generator purchases, but they also couldn't show any true need for the transmission line.  New transmission is planned by regional transmission authorities, who determine a reliability, economic, or public policy need for the project, and then assign costs to users of the new line.  A company who doesn't want to go through the regional planning process to determine a need for new transmission usually ends up as a merchant project, where the company assumes the risk and investors shoulder the cost of building it, with revenue recognized through capacity charges billed to those who use the new line.  But AEP didn't want to assume any risk for its investors, so it asked that regulators approve its transmission line without there being any need for it at all (except to connect the new generator it failed to competitively source).  AEP is stuck in the molasses swamp now and it's doubtful they'll be able to pull this off without some under the table and behind closed door deals.  (The cost of which is NOT billable to customers!!)  AEP's idea failed because it was not smartly executed.

Now our second example was planned much better, over a longer period of time, and not the knee-jerk rush to riches steamroll that AEP attempted.  Ameren got regional planning approval to build a new transmission line across northeast Missouri several years ago.  Supposedly it was needed for reliability and to move renewable electricity across the region.  The project nearly tanked on its first run at approval because it stupidly attempted to route it on new right of way across areas without a transmission line.  But, ever resourceful, Ameren finally recognized its problem and went back to the drawing board to re-route its project on existing rights of way.  And it was approved.

Now Ameren says it wants to buy what will be the biggest wind farm in the state of Missouri, and use the new transmission line to connect it to its customers.  Ameren arranged its big wind buy into distinct and manageable pieces.  First, the transmission line.  Then the wind farm.  If Ameren can pull this off, it will be sitting pretty with two new assets that it can earn a return on for decades.  AEP.... take a lesson in strategy and patience, instead of acting like a bull in a china shop.

Of course, it remains to be seen if this wind farm will actually be built and if Ameren will actually end up owning it.  It also remains to be seen how many more large IOUs try to get into this game before the tax credits dry up.  After that happens, Big Wind is dead.
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Clean Line Sells Off Another Appendage

5/21/2018

4 Comments

 
"Across the country, we are seeing clear proof of how building new efficient transmission infrastructure provides substantial benefits for consumers, through the delivery of clean renewable energy at rock bottom prices, job creation, and economic development.  We have worked to bring the Western Spirit Transmission Line and the Mesa Canyons Wind Farm to advanced stages of development in New Mexico, and are very pleased that Pattern Development will now take both projects over the finish line," said Michael Skelly, President of Clean Line Energy Partners.
The only "clear proof" here is that there's a fire sale going on down at the old fire house.  Clean Line is selling off its projects to anyone who will buy them.  And why is that?  BECAUSE CLEAN LINE ENERGY PARTNERS HAS FAILED!

And Clean Line's failure is clear proof that long-distance transmission to export wind energy across regions is not marketable.  There are no customers willing to finance such a transmission project.
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First Clean Line sold the Oklahoma portion of its Plains & Eastern project to NextEra.  NextEra was only interested in the Oklahoma portion.  NextEra wasn't interested in the Arkansas and Tennessee portions, maybe because there were no customers to purchase capacity at that end.

Now Clean Line has sold its Western Spirit Clean Line and the leases for its Mesa Canyons wind farm.  That's two of Clean Line's five project proposals.  Are the other three projects for sale?  Probably, but who would buy them?

The Rock Island Clean Line has been made illegal in Iowa, and the Illinois Supreme Court ruled that Clean Line is not a public utility in that state.  It can't be built.

The Grain Belt Express Clean Line has also been declared not a public utility by an Illinois appeals court.  It can't be built in Illinois.  Maybe it's time to chop that project up and try to sell a portion for pennies on the dollar?

And what of the Centennial West Clean Line?  There's no public information available about progress for that project, therefore there obviously is no progress.  Would someone buy it?

With the sale of two of its five projects now, it sure looks like Clean Line Energy Partners is finished.  If Skelly thinks having doors slammed in his face across the country is "clear proof" that his projects are wanted and needed, he's living in a self-delusional fantasy world.
Each RTO has its own system for modeling and evaluating proposed projects, and nothing is more difficult than deciding who should pay what, according to Mike Skelly, founder and president of Clean Line Energy Partners, the one company currently trying to build long-distance transmission lines in the Midwest. He offered up a restaurant analogy.

“If you go out to dinner and everybody orders different dishes, and you’ve got to figure out who’s gonna pay for what, it gets tricky,” he observed. In the inter-regional transmission world, typically a number of utilities and other customers benefit from new transmission capacity, but no one is eager to pick up the tab.

Skelly said the messy business of dividing the bill is one reason Clean Line has structured its two Midwestern long-distance transmission lines in a way that minimizes dealings with RTOs. It has proposed using DC instead of AC current, will take on power at one location and deliver it to two locations.


“We felt like the inter-regional planning processes didn’t work nine years ago, and they don’t work today,” he said.
Clean Line’s Grain Belt Express would ferry wind energy from Kansas to Indiana – and from the SPP to PJM. The Rock Island transmission line would move wind energy from northwest Iowa to the Chicago area – and from the MISO to PJM. Skelly said he knows exactly who would benefit from the project, and who, therefore, would pay for it: usually the wind farms whose electrons are moving to the east.

Except, those people don't want to pay for it.  So, if Skelly went out to dinner and pretended he had forgot to bring his wallet, could he force the other diners to pick up his tab?  I think Skelly would spend a long night washing dishes.  Or trying to sell his projects to other companies.

The rest of the projects aren't marketable in their current state.  I do make significant note that the sales Clean Line has made were to companies who saw their purchase as a strategic, rather than profitable, move.  If NextEra had an Oklahoma transmission route, it could try to compete with AEP's Wind Catcher project.  If Pattern owns its only competition in New Mexico, then it could be more certain of getting its project built.  Is there any strategic value in Rock Island, Grain Belt or Centennial West?  I believe Skelly is hoping so, because there's no other reason to keep spending money trying to prop up these failed projects to appear viable.  One thing is for certain, nobody is buying the failed Clean Line projects with the intent of building them as Clean Line envisioned.  It's more like buying a beanie baby at the thrift store to use as a dog toy.

Until the next sale....
4 Comments

York County Judge Issues Thoughtful Opinion on Public Utility Trespassing

5/14/2018

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If a privately held utility has been granted public utility status by a state, does that give the company the right to enter any property in the state at any time to perform potentially damaging tests and surveys?  That's the question being considered by judges in the states of Pennsylvania, Maryland, and Oklahoma recently, courtesy of American Electric Power and its subsidiaries.

This issue has rarely come up in the past because transmission public utilities have been able to propose projects, apply for permits, and even receive approval without creating this kind of pitched battle between the utility and landowners.  Utility entry to survey has been voluntary, and landowners who agree have signed survey permission forms releasing the company from liability for incidental land damages.  Even when large numbers of landowners refuse permission, such as happened with the AEP's PATH transmission project, the company was still able to pursue its regulatory applications and route planning because the transmission project didn't have a firm "drop dead" date by which it must be constructed.

Now, however, AEP subsidiaries find themselves involved in two projects that do have firm in-service dates.  Transource's "Independence Energy Connection" has a June 1, 2020 completion date written into its Designated Entity Agreement with PJM Interconnection.  And PSO's Wind Catcher generation and transmission project must be completed by December 31, 2020 in order to qualify for the federal production tax credits that supposedly make it economically beneficial.  Both of these projects have self-imposed hard completion dates, therefore AEP wants to get as much pre-construction surveying and engineering done as possible during the permitting phase.  It's going to take too long to survey and test after regulatory approval and eminent domain authority is granted for these specific projects.  AEP fears it may miss its drop dead dates.

Ya know what, AEP?  You're going to miss both these dates anyhow.  Landowners who use their land as a source of income have another timetable.  These dates were already too ambitious from the start.  Transmission never stays on schedule, as you should well know since you like to parade your 16-year timetable to get your Jacksons Ferry-Wyoming project built as some kind of regulatory, and not personal, failure.

AEP subsidiaries claim to have a right under the law (or even by virtue of flimsy precedent), as public utilities, to enter into any property at any time to conduct tests and surveys.  If it's that simple, why are you asking courts for injunctions to allow entry?  As Judge Richard Renn in York County, PA, opined:
Plaintiff is quick to claim that it does not need any court order to enter upon the lands because it has that inherent right pursuant to the Eminent Domain Code. (Plaintiff's Brief in Opposition to Defendants' Preliminary Objections ... p. 7.) Yet, Plaintiff is here in Court seeking just that -- a court order permitting it and its agents entry onto lands of Defendants.
Why are you wasting time in court, AEP?  Is it because you're really not sure you have such a right?  If you have such a right, why is this the first time this issue has come up?  And why have you been seeking voluntary permission for decades?  If you, indeed, do have such a right, you should have been exercising it for years and not asking landowners to voluntarily sign away their rights.

Judge Renn also took into consideration the nature of the studies and tests, and their specificity to each property.  AEP asked for blanket permission to enter and perform any number of invasive tests, at its own discretion, including the right to cut and trim vegetation and drill holes.
...claiming an immediate need to access Defendants' property for the purpose of obtain[ing] critical information, including various environmental studies, (including, wetland delineations, habitat assessments, and threatened or endangered species surveys), appraisals, geotechnical surveys (including soundings and drillings for testing soil and bedrock, cultural resources surveys, civil surveys (including trimming or cutting vegetation necessary for survey purposes) and all other surveys and tests necessary to properly assess the area, design and construct the proposed electric transmission line ...
(Plaintiff's Motion,~ 22).

From this description, the nature of the proposed intrusion onto Defendants' land appears to be quite extensive, quite possibly resulting in damage to the land. In fact, Defendants acknowledge the possibility of damage by noting in its Motion that it stands ready to pay damages should such occur.
While the law in Pennsylvania states that the utility shall pay for damages, it lacks any specificity to ensure damages are adequately compensated in a timely fashion.  Who shall determine the extent and value of the damages?  When shall payment be made?  What about remediation -- whose responsibility is that?  And what happens if the landowner and the utility cannot agree on damages?  And what about damages that cannot adequately be compensated, such as the cutting of trees that provide a buffer or serve some other economic or sentimental purpose for landowner?  Payment based on their marketability as timber is hardly adequate when the landowner never intended them to be marketable timber.  Who determines the value of lost or spoiled crops?  What's the value of eradicating invasive plant species that are caused by the utility's entry?  What's the value of disturbed top soil or soil compaction and its effect on future crops?  It seems that a little more expertise is required here to determine and price damages other than a utility's self-interested determination of immediate, visible damages and their value.

Judge Renn was not inclined to allow the utility to
disrupt Defendants' peaceful possession and enjoyment of their lands with "soundings and drillings ... [and] trimming or cutting vegetation ... " possibly resulting damages, on the off chance that the power line may, in fact, run over a portion of those lands, with one exception.
That exception being the bog turtle hunts that Transource described with specificity in its motions, because the judge believed them to be non-invasive and unlikely to cause damage.

However, I note that perhaps the turtle hunts may not need to take place on every property.  Does every one of the 36 properties in York County contain a wetland suitable for bog turtles?  And for the ones that do, is there still enough time to perform the surveys according to the published guidelines?  Run, turtles, run!!!

The only thing that Judge Renn didn't deny was the turtle hunts because they were specified as to procedure and he found them to be potentially non-damaging.  The rest of AEP's trespassing wish list has been denied until further consideration and possibly a trial.  Maybe Transource should have just stuck to the turtle hunts to begin with, and not asked for blanket permission to take over and damage private property?

Because that's what AEP is also asking for in Oklahoma.  Blanket permission to perform damaging surveys on an uncertain route for an uncertain project has been recommended for denial by an Oklahoma Corporation Commission judge.  And the only thing they rely on there is precedent where a utility was allowed the right of entry for purposes of preparing its filing of an eminent domain suit.  AEP claims it is actively constructing a transmission line in Oklahoma and preparing eminent domain suits to acquire land for its project, except that's not even close to true.  AEP doesn't even have a certain route yet and the OCC has not determined there is a need for the project or that it will permit the company to charge its costs to ratepayers in the state.  Without cost recovery, AEP will not undertake this project.  It's all about what might happen and AEP is certainly engaging in a land-damaging fishing expedition of the kind Judge Renn denied in Pennsylvania.
We fully realize that the final route may not be able to be approved absent the studies Plaintiff seeks to undertake. However something more than Plaintiff's mere assertions as to whose lands might be affected is required to satisfy us that Plaintiff is not on the proverbial "fishing expedition." We are mindful of Plaintiff's argument that preventing discovery at this stage of the proceedings makes it difficult for it to obtain final route approval. However, our concern is not with what Plaintiff must do to satisfy the PUC, our concern within the context of this litigation in general, and regarding Plaintiff's discovery request in particular, is to ensure that a party does not suffer from "unreasonable annoyance, embarrassment, oppression, [or] burden" during the discovery process.
My understanding is that Oklahoma doesn't approve transmission routes, so what's the reasoning for doing the surveys at this point in time?
PSO will suffer irreparable harm, damage, and injury unless the acts and conduct of Defendants above complained of are enjoined because further work and construction of the
transmission line cannot continue unless the location and description of the right-of-way easement across the Property owned by the Defendants can be determined.
Who you trying to kid here, AEP?  A judge?  You know full well that you're not actually constructing anything and are nowhere near filing condemnation actions.  That costs money AEP doesn't want to spend until it is guaranteed recovery of its costs to construct this project from ratepayers.  And that approval (from four different states no less!) has not happened yet.

And because it just can't help exaggerating and asking for more than it really needs, AEP has requested the Oklahoma judge order landowners to pay for the cost of its overreaching lawsuit.  Do you really want to punish landowners that way for resisting you, AEP?  You think landowners who won't sign your voluntary permission forms and give up their rights should pay for your overpriced lawyers to sue them?  Or did you just add that as an intimidation tactic?  Despicable!

While these fights seem very specific to two AEP projects, the effect of them could potentially be broad.  Should we upend the current status quo that makes survey permissions voluntary until after utility commission review (at which time the commission can issue an approval contingent upon surveys and tests being performed)?  Or should we roll out the red carpet for any utility to enter upon and damage the property of any landowner at any time?  Seems to me if it's the latter then new laws and regulations covering this activity are sorely needed because we will all be subject to corporate dictatorship instead of due process.  Private property rights shouldn't be set aside in favor of corporate profits.
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Citizens Pan Transource at Public Hearing

5/14/2018

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The Pennsylvania Utility Commission is holding public hearings on the Transource Independence Energy Connection proposal to build two transmission lines on entirely new right-of-way in York and Franklin Counties. 

The first day of hearings occurred last week in York County, where many citizens spoke out in opposition to the project.  The citizen opposition was bolstered by comments from local elected representatives.
State Rep. Kristin Phillips-Hill, R-York Township, said the project doesn't show that it will provide "long-term, significant benefits to our local Pennsylvania communities economically, nor preserve our tremendous agrarian heritage and scenic beauty."

She said, "York County is proud of its strong preservation heritage with nearly 42,000 acres and 282 farms."

Phillips-Hill said the question of why two existing high-voltage power transmission lines that run parallel to the proposed route and are not operating at full capacity aren't being utilized hasn't been satisfactorily answered.
Indeed, Rep. Phillips-Hill!  Why is this company proposing a transmission line on new right-of-way when existing infrastructure through the community is only half-utilized?  Can we blame the company, PJM Interconnection, or federal energy planning procedures?  All of the above!  The Feds encouraged competitive transmission projects, where companies compete to build the best project at a bargain price.  And PJM ran a competitive transmission contest to see who could propose a project that alleviated a congestion concern from 2014.  And PJM selected Transource, a new entrant without any existing assets in the geographic area.  And Transource can only build new assets because it doesn't own any existing ones that could be upgraded or rebuilt to economically alleviate the constraint with minimal intrusion on local landowners.  All three of these entities have since conspired to continue to push this outdated idea, even though better alternatives have been recognized.  What good is competition when it costs communities and ratepayers more than upgrading existing assets?  It's nothing more than an exercise in trying to force a solution that is no longer economical because a project looked good on paper once upon a time.  And it's proof that PJM's competitive process does not work on economic projects because the entire exercise takes too long and is subject to public input.  PJM's "market efficiency" competitive transmission planning process is an abject failure that should be abandoned in favor of better, cheaper, less invasive ideas.

I considered the name of this project recently, and the irony is laughable.  "Independence?"  Making Washington, DC, Northern Virginia, and Baltimore dependent upon electrical generators in Pennsylvania rather than generating electricity locally is "independence?"  Independence for whom?  There's nothing "independent" in a transmission project that serves as nothing more than an intrusive leech, sucking resources out of one state to serve a more economically prosperous and politically connected geographic region at the expense of one not so well positioned.  That the economic prosperity of the big cities is proposed to gain at the expense of the economic prosperity of small Pennsylvania communities is wrong, just wrong.

It's up to the Pennsylvania Utility Commission to protect Pennsylvanians, not toss them under the bus in order to provide benefits for citizens of other states.  And you need to tell them so!  The second York public hearing is scheduled to take place today, beginning at 1:00 and 6:00 at the Airville Volunteer Fire Department.

Two additional public hearings will take place next week in Franklin County.
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Please come out and support your community, whether it is giving oral comment, submitting written comment, or simply showing your opposition from the audience.  This may be your only opportunity to have your say, please don't miss it!

See you there!
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The Art of Opposition to Defend Your Own Little Pink House

5/10/2018

2 Comments

 
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I had to go a little bit out of my way last night to see a movie.  It was worth the drive, and I wasn't disappointed, although there was no happy ending.  There were some feel good moments, and a little bit of schadenfreude in the ending montage detailing the fate of certain villains.  I wasn't surprised by anything I saw, in fact there was a lot of deja vu and a running mental checklist of how certain things were handled from a public relations perspective.  And there were a couple gut punches thrown in there, such as the scene where several elderly characters plead that they just want to be left alone to die in their own houses.  I feel like I've met those people before, because I've heard the exact same thing more than once while opposing various electric transmission proposals over the past 10 years.

Little Pink House is an independent film that tells the story of what it dubbed "the most hated court decision."  In the late 1990's the economically depressed city of New London, Connecticut, got the idea to "re-develop" a working class neighborhood to lure a big corporation to the city.  Corporate giant Pfizer stepped into the role, and the political movers and shakers couldn't do enough to please them, including using eminent domain to demolish a community and hand it over for corporate use.  It was a crisis for the community.  And when crisis strikes, the community says... "someone should do something about this."  Resident Suzette Kelo unwittingly became "someone," as most "someones" usually become; not voluntarily and not by design, but out of necessity.  Becoming "someone" is not a conscious choice and the goal of becoming is never recognized until after it happens.  All of a sudden, there "someone" is, thrust into a role on a path they never knew existed and aren't quite sure where it leads.  But "someone" never quits and never looks back, and sometimes the path never ends, but winds on to things never imagined.

Kelo rallied her neighborhood (feel good moment) and fought the city every step of the way.  The pinnacle of the neighborhood rallying was a "public meeting" put on by the city's cluelessly arrogant economic development woman.  The "town hall" format soon went south, with sarcastic questions that began with Kelo and soon devolved into a free for all shouting match between the residents and the economic development woman.  "This is bullshit!"  Oh how many times have we all wanted to shout that out?   (And maybe one time I actually witnessed it happen).

As Kelo's neighborhood begins to be torn down around her, help finally arrives with a pro bono lawyer from The Institute for Justice.  Kelo becomes the sympathetic face of the community and is offered up to the media in order to build the public story.  Like any ordinary person thrust into the spotlight, she's unsure of herself.  The coaching she receives from IJ is classic.  You are the expert on your own story -- simply tell your story and sidestep or defer the questions that fall outside your expertise.  After a tentative start, Kelo eventually finds her confidence.  And the court battles begin.  There's a self-involved city lawyer who reminds me of a slightly less arrogant version of an attorney I met once upon a time, and a judge who's almost a dead ringer for a judge I also once met.  I found these parallels personally stunning to the point of being a bit distracting from the story for me, but adding to the building feeling that I know these characters.  I've met them hundreds of times over the past 10 years, although the faces and names change each time.  Yes, it was just a movie last night, and these were but actors, but the actions and dialogue were a spot on portrayal of the very real stories that have happened time and again.  The characterizations were authentic, without any of Hollywood's over the top exaggerations and heroic hogwash.  Even the villains were real - mentally screwed up by their own egos and privilege to the point that they can do these things to other human beings without any conscience.  That's because the villains don't see the people they affect as real -- they simply become numbers and statistics.  A dot on a map.  A name on a list.  Someone to be bulldozed aside on the road to fame and fortune.

I'm sure you know that Kelo eventually lost her battle at the U.S. Supreme Court in a 5-4 decision.  But in the wake of that decision, many states tightened up their laws to prevent eminent domain for the sole purpose of economic development.  But where are we now, more than a decade later?  Has the memory dimmed?  There's still plenty of people being wiped out by the threat of eminent domain for private gain, where everyone's Little Pink House would pay more taxes if it was a Walmart... or a new electric transmission line promising to provide "cleaner" or "cheaper" electricity to communities far, far away.

The Institute for Justice, the hero fighting for the little guy in the film, has refused to involve itself in any eminent domain battles waged by utilities upon private property owners.  As I understand it, they get a bit tangled up in the fact that utilities sometimes need eminent domain to provide service to those who don't have any, or to ensure utility service stays reliable.  If that were the only reason utilities used eminent domain, perhaps they'd be justified.

But we've all become so used to the idea that utilities have the power of eminent domain that we've failed to notice the way they've managed to stretch that authority into situations that no longer fit the original purpose.  Should a transmission company building for its own profit be able to decide where to ship power for economic or environmental purposes?  Who gave utilities that kind of authority?  When did someone's desire to use "cleaner" electricity become a good enough reason to take the property and effect the economic well-being of another person many hundreds of miles away?  When does saving one geographic customer base a few cents on their electric bills become a just reason for taking from a land and business owner several states away?

It's time to take a look at a utility's reasons for eminent domain and keep it in check to make sure that it serves a true public use for everyone, and not just to serve the wants of a select group.

If you've ever been involved in transmission opposition, you need to go see this movie.  It has absolutely nothing to do with electric transmission, but everything to do with opposition.

Find out where it may be playing in a theater somewhere near you here.  And if you have to drive a bit to find it, it's worth it.
2 Comments

AEP Treats Landowners Badly

5/9/2018

1 Comment

 
AEP wants to increase its corporate profits by building a transmission line through your property?  Bad news.  AEP has been increasingly disrespectful to landowners and actively seeks to coerce and bully landowners into submission long before its projects are even approved.  It's high time this company's abysmal treatment of landowners is reined in by regulators.  It's coming: AEP's "relationship" with landowners is speeding down the track on its way to a spectacular wipeout.
AEP likes to pretend it is "working with landowners."  As if saying it makes it so.  Nothing could be further from the truth.  The reality is that AEP is working AGAINST landowners.

AEP's huge dilemma is that it is engaged in several transmission projects with compacted time lines.  If AEP cannot get its projects approved and built by certain dates, the projects will be cancelled.  And what's the first thing that goes by the wayside when AEP is in a big hurry?  Landowner relations.  AEP simply doesn't care about establishing a cordial relationship with landowners it proposes entering into a co-tenant relationship with in perpetuity.  Instead, AEP is simply attempting to mow down landowners on its path to profit.  Logically, this just can't end well for AEP.  There's going to be a huge price to be paid for each minute, incremental "victory" AEP believes it has won along the way.

A transmission company files an application at a state regulatory commission, hoping to ultimately receive approval for its project.  The regulatory process takes a long time, especially in states with no statutory deadline for a decision on the application.  Transmission companies have dealt with this long lead time by attempting to perform surveys, environmental studies, and engineering work during the regulatory process, with the goal of getting as much pre-construction work accomplished as possible before the regulatory decision.  However, this requires cooperation from landowners who may grant permission for the company to enter private property to perform its pre-construction work.  When landowners refuse, the company has no choice but to put this work on hold until after the regulators make a decision on the project.  When all pre-construction work has not been performed on a project that a regulator approves, the transmission permit is conditioned upon such work being performed before construction begins.  It's simple.  And it works.  And, most importantly, it avoids the kinds of power struggles AEP has recently engaged in with landowners.  As well, it avoids the extra expense of pre-construction work for a project that is ultimately denied by regulators.  Since many transmission projects approved by regional transmission authorities such as PJM Interconnection come with abandonment incentives that reimburse transmission companies for project expenses in the event that a project is subsequently cancelled or denied by state regulators, the money transmission companies like AEP spend on pre-construction activites comes out of the pockets of electric customers across the region.  Having to wait for approval before engaging in expensive pre-construction work can save ratepayers a lot of money on an abandoned project.

But AEP didn't want to wait on its Transource Independence Energy Connection.  Because PJM Interconnection put such a tight timeline on the project, AEP is attempting to get as much of its project built as it can before regulators make a decision.  After all, it doesn't cost them a thing... except goodwill.  And AEP is going to need a lot of landowner goodwill if it expects to actually build this project someday.

So AEP lied to landowners who refused to grant access.  AEP told them they would be arrested.  AEP told them they would trespass on private property after giving 10-day notice under Pennsylvania law.  Except the law wasn't really as clear as AEP tried to make everyone believe.  AEP threatened to sue landowners for access. 

None of this made any impression whatsoever on landowners (except to further anger them and create entrenched resistance).  AEP filed a whole bunch of confused legal actions against landowners.  Lengthy court processes ensued.  And the court processes have gone on just long enough to ensure AEP's time sensitive turtle hunts can't possibly take place this year.  Awww... that's really too bad.  But were turtles really the reason?  I'm sure there's plenty of damage AEP can do to landowner property cutting down trees, running over freshly planted crops, drilling holes, propagating invasive weeds, compacting soil, encouraging erosion, creating drainage issues and generally impacting farm operations for the entire growing season.  Sadly, all these activities can be performed any time of the year, perhaps even after harvest, when their effects will be somewhat mitigated.  But AEP is a bully, and destroying farm operations for this year is supposed to intimidate landowners into agreement.

That's not going to happen.  The more AEP tries to bully landowners the more determined the landowners become to resist.  This battle is far from over.
AEP also did not want to discuss specific eminent domain cases. However, AEP spokesperson Melissa McHenry specified that as of this past spring, the company had more than 3,200 easements on projects, including more than 903 miles of transmission line. Out of the 3,200 easements, only 41, or 1.28%, required eminent domain filings, she said. In some of those cases, eminent domain was necessary “because the land was without clear title, and, therefore, condemnation by publication was necessary,” she said.

According to McHenry, when AEP constructs or upgrades a transmission line that requires the use of a landowner’s property, easement negotiations begin with property owners after state regulators have approved the project. The negotiations are based on the fair market value of the property needed for the ROW, she said. Appraisals and market data studies are conducted to determine market values and a basis for acquisition negotiations. Negotiations will continue “as long as practical” to reach a voluntary agreement.

If it becomes clear that a voluntary agreement between AEP and the property owner cannot be reached and other viable alternatives do not exist, the company will then exercise the right to eminent domain to secure required easements.
AEP uses eminent domain only 1.28% of the time, you say?  The more AEP enrages landowners, the less they fear the company, and the higher that percentage climbs.  Has AEP ever built a transmission project that required eminent domain for 98% of the project?  Of course not.  That's absurd.  Those kinds of projects never get built.

And how successful will AEP be asserting involuntary entry on Pennsylvanians when the Maryland portion of its project is not subject to such abusive laws?  And what about AEP's transmission projects in other states that don't have laws that allow trespassing prior to condemnation?  Does AEP think that pretending it does have such authority will actually be enough to intimidate landowners into allowing involuntary entry?

The only thing it does is fill landowners with a terrible resolve to resist AEP completely.  Resistance causes project delays.  AEP's timetable is not a landowner priority.  It's not a regulatory requirement.  The more desperate AEP becomes, the more resistance it creates which will ultimately result in prolonged delays... and project failure.  The price of victory in one small battle oftentimes results in losing the war.  Pretty dumb stuff, AEP.  What idiot there thought that was a good idea?  If I was in charge, I'd fire that person.

So, what if AEP involuntarily forces its way onto your land?  Fully document the condition of your land before the invasion using pictures and video.  Keep a running visual diary of AEP's actions on your land, both during and after the invasion.  Don't sign any voluntary permission forms that abrogate your rights.  Have damage professionally remediated and keep all receipts.  Don't settle for less than it costs to restore your property to its original condition.  This bully deserves to be treated the same way it treats you.

And remember how you were treated by AEP during the next legislative session.  Abusive laws need changing.

Having a reputation as a landowner bully really isn't a good thing in the long run.  It squanders goodwill for no  reason.  Nobody likes a bully.
1 Comment

Top Ten Clean Line Mistakes - #1 Dressing Up Like a Farmer

5/3/2018

2 Comments

 
At long last, we've come to recognize Clean Line's biggest mistake... ever!

At the first Illinois Commerce Commission public forum in Mendota, Illinois, Clean Line vice president Jimmy Glotfelty showed up in business casual attire and then proceeded to make an arrogant ass out of himself. 

Gosh, for some reason nobody liked Jimmy that day.  It couldn't be his flippant attitude, his penchant to argue with people waiting outside the venue, his dismissive reaction toward the members of the public who made comment (while Jimmy played with his phone, feigned sleep, and then went outside to find someone to argue with).  It wasn't the outfit that caused him to act that way, it was just Jimmy.

Luckily for Clean Line, the ICC scheduled a second public forum for the Rock Island Clean Line since many landowners at the first one had been unable to get inside because Clean Line filled the venue with hungry college kids in ugly orange shirts.  An opportunity had presented itself for Jimmy to have another chance to make a good first impression on the hardworking people of Illinois!  Better not squander this chance, Clean Line!

And then someone got an idea.  An awful idea.  Someone had a wonderful, awful idea.
Was it because it was nearly Halloween, when costumes are on everyone's mind?  Or was it because someone had recently watched the movie Promised Land, where utility representatives bought farmer costumes before calling on the locals?  Maybe it was a misguided political ploy left over from the Kerry campaign?  Whatever the reason, it was a truly dreadful idea.

They dressed Jimmy up like a farmer and sent him off to the Mendota forum.
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  • Plaid shirt.  How farmerish!
  • Brand new work boots.  Not a speck of dirt on 'em.
  • Khaki "work" pants.  How you going to get anything done when your pants are so long they pool around your ankles?  Maybe he needed the boots to keep from tripping on his pants.
  • Carhartt work jacket.  Brand new.  Never seen a chore.
  • Expensive watch.  Priceless.  Every farmer wears an expensive watch to do chores.  How else would he know when it's quitting time?
Before the forum even started, I got a phone call from a laughing farmer telling me that Jimmy had shown up wearing a farmer costume.  No way!  Way!  I asked for pictures.  Lots and lots of pictures.

Trick or Treat, Jimmy!

And Jimmy's humiliation got passed around the bleachers on a tablet.  And people laughed.  Oh how they laughed!  They laughed so hard, I almost felt sorry for poor, misguided Jimmy.
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Almost.

But it was real difficult to feel sympathy while laughing so hard.

Dressing up like a farmer does not make a transmission ignoramus a farmer.  It does not help real farmers to relate to him.  Furthermore, it is incredibly insulting to real farmers when some fancy pants from Houston pretends he's a farmer in some lame attempt to appeal to them.  Clean Line might as well have posted a huge flashing neon sign in the lobby, "WE THINK YOU'RE STUPID!" 

And, just in case another transmission nimrod wants to try to dress up like a farmer in the future, here's what a REAL FARMER looks like.
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Look!  He's engaged in actual work involving a crop.  He's got dirt on his clothes!  I don't see a watch.  He knows it's quitting time when the job is done.  People like and respect this farmer.  He works hard.  He's honest.  He treats others fairly.  He would never take something that doesn't belong to him.  He would never toss other people under the bus for his own profits.

It's not the outfit that makes the man.  It's the man that makes the outfit.
2 Comments

Your Renewable Energy Goals Are Not My Problem

5/2/2018

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It's politically correct for everyone to have renewable energy goals these days.  From corporations to governments, everyone wants to look like they're doing their part to make energy cleaner.  But what about when you're not really doing your part and instead trying to force other people to do your part for you?  It's all well and good to take personal responsibility for your environmental footprint, but not so much when your efforts include making your environmental footprint someone else's problem.  If you demand that the power you consume must be greener, shouldn't you be willing to sacrifice to get there?

The politically correct and politically connected are increasingly demanding that their environmental goals must be met through the sacrifice of others.  Maybe we shouldn't blame them for their selfishness.  Perhaps they earned it honestly over the years because the sacrifice of others to provide the energy that powers their bastions of urban utopia was never questioned or opposed. 

"West Virginia?  Oh, those poor folks like coal and pollution because it provides jobs.  Put all the power plants, transmission lines and other undesirable infrastructure there.  They don't mind."

But now maybe they do mind.  So now you think, "Let's clean up our environment and stop buying dirty stuff from there!  Let's buy clean energy from somewhere else!"

How about you make your own energy... for once?  How about you build a power generator in your own neighborhood?  But that's too costly, you say, there's not enough space for new power generators, and besides, you don't want energy infrastructure in our own back yards!

Exactly.  So what makes you think others do?  Especially when the others won't receive any benefit from your infrastructure?  Oh sure, the renewable energy enthusiasts and the companies who make money hand over fist meeting their needs try to pretend areas hosting new energy infrastructure will "benefit" from new projects.  But that's all they present -- trumped up benefits with absolutely no mention of all the local detriments that come with this infrastructure.  Payments to local governments or environmental groups are nothing more than dirty hush money.  That money will run out soon, but the detriments will be permanent.

Big wind is destroying rural middle America, turning it into an industrial wasteland and fomenting bitter animosity that destroys formerly peaceful communities.  And what for?  So they can export the idea of wind power to urban communities, and make a bundle of tax dollars in the process.  When the handouts stop, so will the push for Midwest wind, but by that time, what will be left?

Eastern states with renewable energy goals are calling for more "clean" power, and the companies who build transmission are only too happy to offer it to them.  Instead of building clean generators in their own communities, certain states want to import it from some far off golden renewable land where they don't have to make any sacrifice to produce it.  I'm talking about you, Massachusetts.

First it was Northern Pass, which promised to bring "renewable" hydro power from Canada.  Massachusetts doesn't connect with Canada, therefore Northern Pass suggested stomping through New Hampshire on its way south, like Godzilla on his way to Tokyo.  Except New Hamphire refused to be the sacrificial lamb for Massachusetts needs.  So now it's "New England Clean Energy Connect," another aerial transmission project that uses Maine as the sacrificial lamb.  Central Maine Power says Maine doesn't mind, and in fact many towns and business groups have "endorsed" the project.  Everything's good, right?  Maine loves making a sacrifice to its own environment and economic prospects in order to meet Massachusetts renewable energy goals.  Well, maybe not.  It's not so easy...
But Maine regulators must find that NECEC will benefit Maine residents, even though none of its electricity will be sold in Maine. Additionally, the project’s direct-current design restricts instate generators — such as wind or solar farms — from hooking up to the line.
It's deja vu all over again.  One state is being asked to sacrifice for the needs of another.  And we're not just talking about bringing in power to keep the lights on in that other state, we're talking about bringing in "cleaner" power so that the other state can continue to use as much as it wants without harming their delicate environmental conscience.  And just like the last project, there is opposition.

And some of this opposition has a different character.
But opponents, which include national energy companies that own competing power plants, say the project could force their plants offline, costing jobs, tax revenue and the ability to build new wind and solar projects in Maine.
And national energy companies have a lot of resources to refute the murky claims of benefit being offered by project owner, Central Maine Power.  Such as:
• Maine power plants, including Wyman Station in Yarmouth, could close, and hundreds of jobs and more than $5 million in property tax revenue would be lost.
• Several Maine wind and solar projects could be canceled, too, because the line would be designed like an interstate highway from Canada with no on-ramps in Maine for other generated power.
• Despite being labeled a clean project, the line wouldn’t really lower carbon emissions that accelerate climate change because no new hydropower facilities would be built, meaning fossil-fuel power plants outside New England would be called on to backfill demand in New York state and elsewhere created by the diversion of power to Massachusetts.

And those claims that construction of the project will lower electric costs throughout the region, including Maine, are also being challenged.
Asked Tuesday to clarify the $40 million savings to Maine ratepayers, John Carroll, an Avangrid spokesman, said an analysis done for the company attempts to quantify the “downward pressure” on energy prices in the wholesale markets. The effect, he said, is similar to using less of a higher-cost fuel to meet electric demand; it produces lower prices for consumers.
In the testimony, opponents acknowledge that the project could “suppress” wholesale electric rates at first. But Tanya Bodell, executive director at Energyzt Advisors LLC in Boston, said that falling prices associated with other planned renewable generation projects would soon negate the impact of the new transmission line.

Let's be real here, shall we?  This project doesn't benefit Maine, it benefits Massachusetts.  And when this proposal also fails, will Massachusetts move on to the next?  Or will they finally take responsibility for meeting their own ambitious goals?

Transmission projects that visit the "needs" of one state or geographic region on the beauty and economic prosperity of another are doomed to failure.  We're not all a bunch of short-sighted bumpkins who will swoon over a pile of shiny beads.  That only happens in history books.

The only kind of transmission project that stands a chance anymore is one like this.  Completely buried along public rights of way or underwater.  Why hasn't Massachusetts selected one like that?  Because supplying Massachusetts with renewable energy is cost competitive, and doing the right thing costs too much.  When you set your renewable energy goals, Massachusetts, did you think it would be cheap?  Did you think it was going to be easy to visit your needs on other states?  It's not.  You set your goals, you need to meet them at your own expense.  Your goals = your problem.
0 Comments

    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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