We can’t ignore the elephant in the room – these kinds of projects are intended to facilitate the transfer of “clean” energy resources across multiple regions, and often provide no benefit to communities who are asked to bear invasive new infrastructure that only benefits others in far-distant cities. These kinds of projects are an attempt at top-down pressure to force load in one region to choose resources from another, favored, region. There is no empirical evidence that beneficiary communities would choose these resources if offered through new transmission. In fact, experience gained by the failure of the Clean Line Energy Partners merchant transmission projects suggests that even when these kinds of energy choices are offered to load, they are not selected. When left to their own devices, states may choose to use renewables from their own state or region, rather than import generation from another part of the country. Local resources provide more than “cheap” energy; they provide economic growth to the community and keep energy dollars working within the community, state, or region.
Interregional and resource unlocking transmission projects are some of the most hotly opposed transmission today. The larger a project’s geography, the more opponents it garners, and opposition to these kinds of projects has been wildly successful because of its mass and momentum. Rural landowners and businesses will continue to vociferously resist this unnecessary and sacrificial invasion, making these kinds of projects a non-starter.
Providing financial incentives to these projects cannot overcome opposition and the state politics that drive rejection. Until a way to transfer energy long distances that does not rely on overhead structures and eminent domain is developed for common use, these projects are best left to existing planning processes and the merchant transmission world. Incentive rates cannot solve this problem.

Paying everyone for their costs to compete completely upends the competitive process
and removes any consumer benefit from the competition itself. This isn’t Little League Baseball, where every player gets a trophy for participating; it’s big business with large financial rewards.

The true magnitude of its burden on consumers for circumstances out of their control has been taken rather lightly. Consumer interests deserve serious consideration in a fair evaluation of the use of the abandonment incentive, instead of being a voiceless speed bump thoughtlessly tossed under the bus in an attempt to protect utility interests.

Environmental and business interests call for the development of transmission incentives
to spur the construction of a “build it and they will come” proactive grid of the future. The
suggestion that we go “all in” on forced use of remote renewables may be a bad bet because it conflicts with the recent rise of distributed generation, local renewables, and non-transmission alternatives, and may not be the cheapest or most effective way to reduce carbon emissions.

It is no surprise that environmental groups, transmission developers and suppliers, and even corporations with their own voluntary renewable energy goals, are urging the Commission to use incentives to force the building of new consumer-financed transmission that meets their self-imposed goals, or ensures decades of new profit.

Commenter Advanced Energy Buyers Group thinks the Commission should award incentives to encourage new transmission to meet the voluntary goals of its member corporations. Corporations, no matter how big, should not be directing and demanding where
and when consumer-financed energy infrastructure is built. Consumers cannot bear the financial responsibility of this kind of corporate virtue signaling.

Commenter American Wind Energy Association’s support for building a new grid for renewable energy at consumer expense may be a poorly disguised attempt to reduce generator connection and transmission costs in order to make up for the financial loss of the expiring Federal Production Tax Credit. Once the credit is gone for good, remote industrial wind is going to need all the financial help it can get to compete on a cost basis with local renewables.  Reducing transmission congestion and costs by pro-actively building a consumer-financed grid for export is one way to accomplish that.

It suggests wider cost allocation and an expanded definition of “benefit” so that the cost of new transmission can be increased while still scaling pre-defined cost/benefit ratios. ACEG wrongly suggests that such a plan will show state and local authorities the benefit of transmission and convince them to approve more projects. In addition, ACEG believes it can smooth siting by increasing project costs to provide “mitigation” payments to landowners and local communities who may oppose new transmission projects.

"If FERC were to reinforce its policy of permitting transmission project developers
to include in their project costs expenses that were incurred to mitigate the concerns of a local community inclined to oppose the construction of a nearby transmission line, a less contentious project approval could save more than their cost. This might include such expenses as providing a new railroad track
overpass, upgrading a school or community center, or repaving some of the community’s streets. The ability to make such social investments could help build the case for state and local acceptance of a project, and could allow that transmission line to be completed more quickly…"

ACEG has it wrong on all counts. The Commission does not have “a policy of permitting transmission project developers to include in their project costs expenses that were incurred to mitigate concerns of a local community...”. ACEG conflates several misconceptions of existing rate precedent that was recently settled by the Commission in Opinion No. 554. It’s almost as if ACEG failed to take notice of that decision at all. Payments to local communities intended to influence their opinion and decisions in a transmission permitting case are expenditures “…for the purpose of influencing the decisions of public officials…” that belong in Uniform System of Accounts (USoA) account 426.4. Account 426.4 is not included for recovery in transmission formula rates, and its recovery through stated rates requires individualized Commission review and approval.

Furthermore, the idea that landowners and communities can be influenced to support transmission proposals by what essentially amounts to bribe money is the contention of a
Pollyanna. Money is not the issue that foments opposition and we consider this contention insulting. Adding to the insult is the absurdity of paying financial rewards to a community and then collecting the cost of those rewards from the very same community through electric rates (in some instances with added return). In that instance, communities would be paying to bribe themselves.

For example, the Commission could permit applicants to request the recovery of specified O&M expenses as capital costs for ratemaking purposes in the area of forestry and vegetation management to encourage best-in-class practices. Effective vegetation management is vital to the reliability of the Bulk Power System, as evidenced by the 2003 Blackout.*
Extreme weather conditions, whether it be excessive rainfall, drought or heat, is making traditional vegetation management more challenging while simultaneously increasing its
importance. Vegetation management is an on-going and evolving challenge facing transmission owners as extreme weather conditions intensify, which only heightens importance of vigilance in preventing encroachment of vegetation to ensure the reliability of the grid.  The NERC Reliability Standards applicable to vegetation management do not apply to facilities that are
below 200 kilovolt. Vegetation management, therefore, should be considered as one of the most critical components to maintaining system reliability, and should be prioritized in a way that puts it on equal footing with transmission investment. Best-in-class vegetation management creates long-term system benefits by reducing outages. The Commission could provide a greater incentive to adopt and implement state-of-the-art vegetation management practices by allowing transmission-owning entities to book the costs
that currently would be categorized as O&M expense as a capital cost to be amortized over an appropriate period. Treating these costs as capital would allow transmission owners to earn a return on the unamortized balances and thereby create an incentive to these entities to focus funds in this reliability-critical function. This incentive rate treatment would support the Commission’s reliability goals and benefit customers by reducing outages over the long term. By permitting applicants to capitalize certain O&M expenditures, the Commission could incent best practices for grid security and reliability that benefits all customers.

*And the East Texas issue!

According to PSC records dating back to the 1970s, the commission has never rejected a utility application to build a transmission line.

Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it's the only thing that ever has.
Margaret Mead

Apex Clean Energy Vice President of Public Affairs Dahvi Wilson said it’s no longer simply a matter of getting landowners to sign off on projects. Now, Wilson said, utilities need to secure public support.
“We’re increasingly before state [and] local governments, and we’re facing opponents that are very sincerely concerned about what’s coming to their communities but also misguided,” Wilson said.
Utilities are increasingly facing the deliberate spread of misinformation online about proposed projects, she said. “We’re in a lot of debate right now over what’s true.”
Wilson said regulators must now ascertain whether data are scientifically rigorous or simply pulled from a questionable webpage.

North Dakota Indian Affairs Commissioner Scott Davis, a member of the Standing Rock Sioux tribe, led negotiations with the Dakota Access Pipeline over a two-year period. He described how he was constantly afraid of a protester’s death and listening to helicopters conducting crowd control near his home.
“Don’t underestimate the power of my people. You can tell them not to do it, and they’re going to do it,” Davis said. “Quite honestly, government hasn’t treated us very well in the decades of our existence.”
Davis said “old-fashioned” face-to-face discussions with tribal or community leaders is the best approach to introducing projects with communities, native or not. Davis also warned that treaties protect tribal land.

“[For] a lot of you that have tribes in your states, treaties are the law of the land. They’re in the Constitution. … Understanding tribes, where they’re coming from, is so important,” Davis said. “I think in this world of progress, progress, progress, what drives us — what pushes the gas pedal of progress — is trust. If you’re just rubber-stamping [energy infrastructure projects], you will have an issue.”

Wilson said the wind industry, which previously tended to submit projects quietly, hoping for little public notice, is now more transparent. She also agreed that it’s imperative for utilities to spend face-to-face time in a community.
“If the people that are fighting our projects are much more liked in the community, the community is going to believe them over us,” Wilson advised.
However, she said, it’s still a “hard sell” to convince many utilities to spend money to embed company representatives in a community to foster trust.

Environmental Law & Policy Center Senior Attorney Brad Klein said it’s generally good practice for a utility to perform a full environmental impact analysis early in the process and thoroughly investigate alternatives to a large energy infrastructure project.

“I don’t think alternatives are appropriate in all cases, but they should be fully considered up front,” Klein said. Decisions should be made based on “full and fair information,” he said, which should contemplate new technologies, battery storage and collections of distributed resources.

Klein also acknowledged that there will be environmental trade-offs with any large infrastructure project. But utilities and regulators shouldn’t insult groups of concerned citizens, he said.
“Don’t dismiss local communities as NIMBYs [‘not in my backyard’]. That’s insulting,” Klein said. “When we lose the public’s trust, you lose the larger fight.”

What you want
Baby, I got it
What you need
Do you know I got it?

On August 2, 2019, the Verde Transmission Project notified the United States Bureau of Land Management and the United States Bureau of Indian Affairs that the Project would not be moving forward and that the Project was officially requesting to withdraw its application for right-of-way approval from these agencies.

Our results also suggest that transmission line developers may garner greater support from communities that will host such lines if they explain explicitly that at least one source of electricity is solar or wind.

Of course, higher support for transmission lines that carry renewable electricity may not be sufficient to overcome all opposition, especially from property owners most directly affected by the siting; nor is it guaranteed that a response to a hypothetical survey scenario reflects how one would respond to the same scenario in reality.

Invenergy’s investment will support three of the organization’s central programs:

• The Blue Jacket Program, which Invenergy will donate 125 signature jackets annually.
  
• Career and Leadership Development Events.
  
• Building out the FFA national alumni network.
  

More than half of Invenergy’s U.S.-based renewable energy projects are located in the same zip code as an active FFA chapter.

“FFA is important to the communities where Invenergy projects operate..." said Mick Baird, SVP of Renewable Development at Invenergy.

The Court of Federal Claims held that none of the developer fees were includible in the applicants’ qualified grant basis because the fees had not been substantiated to the satisfaction of the court. The court applied as its legal basis for this disallowance, the so-called “sham” transaction doctrine applied under the tax law.

The development agreement was a three-page document, according to the Court of Federal Claims, wherein Bishop Hill agreed to pay IWNA a $60 million development fee. The government’s requested findings suggest that the development agreement disclosed that this amount was intended to compensate IWNA for development services that it had already performed for Bishop Hill. The development agreement was signed by two officers of Invenergy Wind and was terminable by construction lenders if the exercise of their remedies resulted in Bishop Hill being no longer controlled by IWNA. According to the government, another single member disregarded entity of Invenergy Wind, Invenergy Wind Development North America LLC (IWDNA), transferred $60 million to Bishop Hill’s construction account in July 5, 2012. On the same day, the $60 million amount was transferred to IWNA’s operating account. And, on the same day, the $60 million amount was transferred back to the same IWDNA account from which the amount originated. According to the government: “Thus, on July 5, 2012, $60 million travelled through three bank accounts and in each account, the debit and credit of $60 million cancelled each other out.”