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Grain Belt Express Asks For Loan From Shady DOE Office

10/22/2023

During a hearing before the Senate Energy and Natural Resources Committee last week, Missouri Senator Josh Hawley questioned Jigar Shah, Director of the U.S. Department of Energy's Loans Program Office. Senator Hawley's questions revolved around Mr. Shah's apparent conflict of interest in attending pay-to-play invitation-only industry conferences where he was accessible to companies that wanted to get loans from his office. At one point, Senator Hawley rendered Mr. Shah speechless. Watch this brief exchange here:

Senator Hawley's questions stemmed from this Congressional report which revealed that Mr. Shah founded a clean energy trade group called The Cleantech Leaders Roundtable before he was appointed Director of the Loans Program Office. Once he was appointed, he continued to attend and speak at the group's private functions. These are the paid conferences that Senator Hawley was referring to. The Cleantech Leaders Roundtable is a shady organization that keeps its membership secret, and its functions are invitation-only for members. Who attends these functions in order to hobnob with Mr. Shah, who controls the purse strings of billions of dollars of taxpayer-backed government loans? Do you think Grain Belt Express parent company Invenergy is a member? It would be odd if it was not.

After Mr. Shah went from CleanTech Leaders to the DOE's Loans Program Office, the organization made this social media post:

It appears to me that this group was positively chortling over its good fortune to have one of its insiders in charge of doling out billions of taxpayer dollars for "clean energy" loans. Hundreds of Billions $$$$$$ of your tax dollars!

Senator Hawley was spot on with his questioning. But what Senator Hawley seemed to miss was Mr. Shah's connection to something happening in the Senator's own backyard in Missouri. Grain Belt Express has applied to Mr. Shah's office for a government-guaranteed loan for up to 80% of its cost to build the project. With GBE's costs estimated to be around $7B, this means a $5.6 BILLION dollar loan to Grain Belt Express backed up by your tax dollars, if Mr. Shah approves.

Furthermore, Grain Belt Express currently only has one customer for less than 5% of its project capacity, and that customer received below-cost pricing. Grain Belt Express does not currenty have the revenue needed to make necessary payments on a government-backed loan.

Senator Hawley should demand that DOE make sure that Grain Belt Express has the necessary signed customer contracts to provide enough revenue to pay back any loan it receives, and under no circumstances should the DOE loan money to GBE before it has sufficient revenue in place in the form of signed and verified contracts.

If DOE loans money to GBE based on its PLAN to sell its service at some time in the future it could turn into a nearly $6B boondoggle, 12 times worse than Solyndra!

While Senator Hawley's questioning of Jigar Shah made great theater, it is up to you to make sure he takes the next step to tie Mr. Shah to the loan application of Grain Belt Express that is currently under Mr. Shah's review. Help Senator Hawley make this connection by contacting him here or by calling his office at 202-224-6154.

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GBE FERC Amendment Questioned by Missouri Landowners Alliance

10/21/2023

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As I mentioned in an earlier post, Grain Belt Express has a long way to go to actually make its project a reality. GBE needs approval from the Federal Energy Regulatory Commission to negotiate rates with potential customers. Only through this process can GBE sign up customers who will pay the costs of constructing its transmission line. Without customers, GBE is nothing but a PLAN.

Clean Line applied for, and received, Negotiated Rate
Authority from FERC way back in 2014 based on Clean Line's corporate structure, investors, and the project it was planning to build at that time. Once it was approved, Clean Line proceeded with an Open Solicitation. An Open Solicitation is a fair and transparent process by which a merchant transmission line like GBE negotiates with potential customers and awards capacity on its project through the signing of contracts. The company needed to provide wide notice of its project and the capacity it was offering so that interested potential customers could make offers and negotiate to use the project. A company like GBE must offer the opportunity to bid and negotiate to ALL potential customers. Customers responded to GBE's Solicitation and GBE began negotiations with them. Except, no contracts actually resulted from that process. At some point, Clean Line engaged in what some thought was a shady deal with MJMEUC (the 31 cities) to purchase 200 megawatts of GBE's capacity. Was the offering widely noticed? Were negotiations based on fair principles? Nobody knows because Clean Line never submitted the required Compliance Filing to FERC explaining how it conducted the process that resulted in the MJMEUC contract. Clean Line just sort of walked away from the process and never closed its Open Solicitation or made the required filings with FERC. That was in 2016.

Since that time, Invenergy bought the project. It should have made a filing notifying FERC that it did so and find out what it needed to do to transfer GBE's Negotiated Rate Authority to its new project. But it didn't. Invenergy did nothing with its NRA either. It just simply sat there collecting dust.

Finally, just before the MO PSC approved GBE this month, GBE got inspired to file an "amendment" to its Negotiated Rate Authority with FERC. GBE's FERC application was sort of like the one it filed at the MO PSC -- a simple "amendment" that skims over all the changes to the project and asks for approval based on stale information filed by Clean Line. GBE was trying to pull the wool over FERC's eyes by not informing them of all the changes to the project. They might have succeeded, but...

The Missouri Landowners Alliance filed a Protest on GBE's NRA amendment docket at FERC yesterday. MLA's comments blew me away! It seems that perhaps GBE has violated a bunch of FERC's rules with its actions since it bought the project, such as negotiating with potential customers without an Open Solicitation. MLA also contended that the MJMEUC contract should be void because Clean Line never made the required Compliance Filing that required FERC's approval before the contract was valid. GBE said that it was prepared to make the required compliance filing at some time in the future, but the MLA opined that may be difficult since it has been over 7 years since the contract was negotiated and signed by Clean Line. Where are the records necessary to make a detailed compliance filing? Did they go into a dumpster in Houston 5 years ago?

Read a copy of MLA's Protest here.

20231020-5079_mla_protest_er24-59_final.pdf
File Size:	2096 kb
File Type:	pdf

Download File

Thanks to MLA's comments, FERC now knows that there are problems with GBE's "amendment" that are going to require a little more work and contemplation by the FERC Commissioners. It's no longer a matter of a quick and simple rubber stamp.

Keep your eyes on this one! GBE's ability to negotiate with customers is riding on it! And, remember, no customers, no GBE!

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PJM Selects New Transmission Scenarios

10/15/2023

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On October 3, PJM Interconnection revealed its preferred scenarios for new transmission to connect coal-fired electric generation plants in West Virginia and southwestern Pennsylvania to the unabated build out of new data centers in Northern Virginia that are making our grid unreliable.

PJM narrowed the 72 proposals it received down to just 3 preferred scenarios shown in this presentation on pages 41-43. PJM says it included the proposal on page 41, identified as NextEra 175, because it was a non-incumbent solution. PJM went on to indicate that this proposal really doesn't have a snowball's chance in hell of being the final selection. PJM is favoring the 500 kV or 765 kV scenarios on pages 42-43. PJM said that it will select one of these two for an immediate recommendation for approval and build, and select the other as a long-term scenario. From what PJM said, and from browsing the submissions in PJM's next competitie proposal window, I surmise that the 500 kV scenario is the "right now" project and the 765 kV scenario is the long term solution it will recommend next. Therefore, we can expect that PJM will approve and assign BOTH of these proposals to be built within the next 5-7 years.

Let's concentrate on the 500kV scenario. PJM says that this scenario is part of proposal number 853 submitted by NextEra. NextEra is a competitive transmission developer based in Florida. It's not your local utility. NextEra 853 looks like this on PJM's map:

The portions of this proposal that affect Jefferson County, West Virginia and Loudoun County, Virginia look like this:

There are two connecting route segments in Jefferson County, West Virginia and Loudoun County, Virginia. The following is PJM's narrative description of where these routes will go. The brown text indicates portions where NextEra will wreck and rebuild the existing 138kV transmission line (wooden H-frame poles) as a double-circuit 500/138 kV line that will require at least an additional 30 feet of right-of-way. The green text indicates portions of the project that will be on new 165 ft. wide right-of-way. For the Loudoun County portion, the new 500 kV line will be routed in areas without existing transmission lines.

Segment 1
General route description: Route is approximately 22 miles long. Starting at a new dead end structure at the new Woodside substation, the line routes east along the existing Stonewall - Feagan's Mill 138kV transmission line ROW for 11 miles with the entire Stonewall - Feagan's Mill 138kV transmission line rebuilt under the new greenfield transmission line. The new line routes around the existing Feagan's Mill substation and then resumes using the existing 138kV transmission ROW between Feagan's Mill and Millville, for about 2 miles where the 138kV transmission ROW separates from the existing Bismark - Doubs500kV transmission ROW. The line routes adjacent to the existing 500kV transmission ROW for almost 4 miles before resumes using the existing Millville - Lovettsville 138kV transmission line. The line uses the Millville - Lovettsville 138kV transmission line ROW for approximately 4 miles to the east before deviating from the existing 138kV transmission ROW to create a new ROW. It is advantageous to rebuild the existing 138kV transmission circuits underneath the new 500kVtransmission line to minimize viewshed impacts, reduce ROW acquisition costs, reduce residential land infrastructure impacts, and reduce tree clearing requirements, especially for the furthest east section where the new line crosses the Appalachian Trail. This line component ends east of the Appalachian Trail, where a different line component begins to continue the route to new Gant substation.
The new right of way will be an expansion of an existing transmission line corridor for approximately 80% of the route length, where a 30 ft additional width will be required beyond the existing, assumed, ROW edge. For approximately 20% of the route length, the right of way will have its own corridor with a width of 115 ft (10%) and 165 ft (5%).
The majority, approximately 80%, of the proposed structures will be single circuit 500kV lattice towers with 138kV (TTVS-500-138) in a horizontal conductor configuration. The 138kV line to be underbuilt is an existing line. Approximately 20% of the structures will be single circuit 500kV lattice towers (TTVS-500) in a horizontal conductor configuration. Any proposed deadend structure will either be lattice tower or a 3-pole, one phase per pole structure type.

Segment 2
Route is approximately 25 miles long. The component begins as a continuation of the 500kV -138kV underbuild from the new Woodside substation. The line continues to follow the existing Doubs - Bismark 500kV transmission ROW for about 0.5 miles before turning south. The line maintains a predominately south-southeast direction for about 17 miles, with minor shifts in route direction to reduce impacts to existing structures, residences, and vegetation. The new line shifts east around Leesburg, Virginia, for about 5 miles, before reaching the Dulles Greenway. The line routes alongside the Dulles Greenway ROW for about a mile before turning north and terminating at the new Gant substation.
The new right of way will have its own corridor and will have a width of 165 ft.
The proposed structures will be single circuit 500kV lattice towers (TTVS-500) in a horizontal conductor configuration. Any proposed deadend structure will either be lattice tower or a 3-pole, one phase per pole structure type.

PJM has indicated that it will make its final selection on October 31. If you even think you may be affected by this proposal, you need to make PJM aware of your concerns now. You can send your comments on this proposal to PJM by emailing [email protected], [email protected] and [email protected].

If you do nothing, your next notice may be a postcard in the mail indicating that NextEra is routing the transmission line through your property and requires you to sign over a right-of-way across your property. Don't be a sitting duck!

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Missouri PSC Speculates On GBE

10/15/2023

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If wishes were horses, beggars would ride!

The Missouri PSC issued an Order last week speculating on the Grain Belt Express transmission project. I don't know when I've seen an Order so full of mistakes and baloney before. This is apparently what happens when a utility regulator is turned into an avenue to award political favors. None of the current Commissioners have any knowledge or experience with the electric utility industry... and it shows! I felt stupider after reading the Order. Much of it was copied and pasted from the PSC's last Order approving GBE, such as:

Agricultural impacts will also be reduced because no more than nine acres of land in Missouri will be taken out of agricultural production as a result of Project structures.

The Order also says:

The Project is designed to have a minimal impact to land. In Phase I for the HVDC Main Line approximately 9 acres will be taken out of agricultural production. For Phase I Tiger Connector approximately 0.2 acres will be taken out of agricultural production. And for the Phase II HVDC Main Line, approximately 7 acres will be taken out of agricultural production.

How much land will be taken out of production? A 200 foot wide strip across more than 200 miles of Missouri, that's how much. The PSC obviously has no clue!

And then there's this ridiculous quote taken out of the original GBE Order that's like biting on something rotten.

There can be no debate that our energy future will require more diversity in energy resources, particularly renewable resources. We are witnessing a worldwide, long-term and comprehensive movement toward renewable energy. The energy on the Project provides great promise as a source for affordable, reliable, safe, and environmentally-friendly energy that will increase resiliency of the grid. The Project will facilitate this movement in Missouri, will thereby benefit Missouri citizens, and is, with the conditions set out below, in the public interest.

There can be no debate? Of course there is debate! There is debate about everything, especially the failure of "clean energy" to keep the lights on despite trillions of our tax dollars being poured into this empty well. Anyone who states that "there can be no debate" is a totalitarian lunatic!

And here's the non-debatable and speculative part...

Grain Belt has a viable plan for raising the capital necessary to finance the cost of constructing the Project on a project financing basis. Specifically, after advancing development and permitting activities to a status at which developers of wind and solar generation facilities and other potential customers of the transmission line are willing to enter into commercial agreements for an undivided interest (purchase or lease) or long-term contracts for transmission capacity on the Project, Grain Belt will enter such contracts with interested parties that satisfy necessary creditworthiness requirements. Grain Belt will then raise debt capital using the aforementioned contracts as security for the debt.

Grain Belt anticipates utilizing a combination of commercial and governmental sources of financing, and, at this time, is still evaluating all potential options for financing. Options for governmental sources of financing include the Western Area Power Administration (WAPA) Transmission Infrastructure Program (TIP); and the Bipartisan Infrastructure Bill Transmission Facilitation Program; Department of Energy loans to non-federal borrowers for transmission facilities pursuant to the Inflation Reduction Act and potentially other government funding options. Additional equity capital may also be raised to help finance construction of the Project, or Grain Belt’s existing investors may make additional equity investments in the Project.

Grain Belt Express has only one customer for just 5% of its project capacity. It also does not have approval to finance its project on the backs of American taxpayers.

Coulda, woulda, shoulda. It's going to be a long journey to having GBE fully subscribed, especially since GBE does NOT even have FERC's approval to negotiate rates with potential customers. After being asleep at the switch since it bought the project from Clean Line Energy Partners in 2019, Invenergy has suddenly become inspired to "amend" the negotiated rate authority FERC granted to Clean Line Energy Partners in 2014. Just like GBE "amended" its permit from the Missouri PSC when what it really did was create a totally new project that wasn't sufficiently reviewed. Just because the uneducated PSC Commissioners in Missouri fell for that ruse doesn't mean FERC will as well.

Perhaps the best part of GBE's FERC "amendment" is this claim made by Invenergy:

Consistent with the Commission’s requirements for obtaining and maintaining negotiated rate authority, Grain Belt Express’s negotiated rates will continue to be just and reasonable. In the context of negotiated rates, the Commission considers whether the merchant transmission developer has assumed the full market risk for the cost of constructing its proposed project, and is not building within the footprint of the developer’s (or an affiliate’s) traditionally regulated transmission system. The Commission also considers whether the merchant transmission owner (or an affiliate) owns transmission facilities in the same region as the project, what alternatives customers have, and whether the merchant transmission owner is capable of erecting any barriers to entry among competitors, and whether the owner would have any incentive to withhold capacity.
Here, Grain Belt Express has assumed, and will continue to assume, the full market risk for the cost of constructing the Project. Grain Belt Express has no captive pool of customers from which it could recoup the cost of the Project.

No customers.... just captive American taxpayers who would foot the bill if GBE defaulted on a government loan, and who would pay GBE for its capacity under DOE's Transmission Facilitation Program.

There's also the matter of GBE's pending Environmental Impact Statement that won't even be in draft form until sometime later this winter. Only after that document is finalized will DOE make a decision on whether to grant a taxpayer-backed loan. What's a taxpayer-backed loan? It's the same as any loan with a co-signer who is responsible for repayment if the borrower defaults. In this case, the co-signer would be every taxpayer in the country. GBE has applied to shift all risk for its project onto captive taxpayers.

So, the Missouri PSC approved GBE? Big Flipping Deal. Grain Belt Express is going nowhere without customers that will pay to build it. There can be no debate that GBE's financing plan is a house of cards.

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U.S. DOE Box Checks EIS Scoping

9/27/2023

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Remember at the beginning of this year when the U.S. Department of Energy held public meetings to gather scoping comments for the Environmental Impact Statement it must prepare before it decides whether or not to grant deep-pocketed energy conglomerate Invenergy a loan of more than a BILLION dollars to finance its no-revenue Grain Belt Express transmission line? Did you know that DOE has prepared its Scoping Report that will guide the EIS? You didn't? That's because there was no public notice. DOE didn't send out a mailer, or even an email to the persons on its electronic mailing list. It simply updated its website and didn't give any notice whatsoever. If I had not stopped by there to look for something, we'd still be in the dark!

But since the cat is out of the bag, let's talk about DOE's Scoping Report. The scoping report sets the parameters for the EIS. It determines what will be studied in the EIS. Here's what DOE says it will study:

Air Quality and Greenhouse Gas (GHG) Emissions
Geology, Soils, and Paleontology
Water Resources
Noise
Vegetation
Wildlife
Cultural Resources
Transportation and Access
Land Use
Recreation
Environmental Justice
Public Health & Safety
Visual Resources
Social, Economic, and Community Resources

But according to DOE, these are the most common topics that the public asked to have studied:

Limitations on land uses that could potentially result from the Project’s construction and operation
Consideration of alternatives to the Project as currently proposed
History of the Project, including previous routing studies and past interaction with landowners
Concerns about the Project’s proposed route and infrastructure placement
Potential impacts on wildlife; social, economic, and community resources; geology and soils; health and safety; and vegetation

The DOE didn't listen to a damned thing you said. It simply checked the "public participation" box and went on its merry way.

The most popular comment was for DOE to study alternatives to Grain Belt Express. Siting new transmission on existing rail and road rights-of-way was the most common form of this scoping suggestion. However, DOE has absolutely NO INTENT to study any alternatives. The only "alternatives" DOE chooses to consider are to build, or not to build.

It's wholly debatable whether DOE's excuse for not studying any alternatives will pass legal scrutiny. I think it went something like this... DOE is only considering whether to loan money so it's either yes or no and does not involve selecting an alternative. Pretty lame, right? That same excuse could be used by any federal agency contemplating using federal resources for a project that could impact the environment. We're either going to participate or not, we're either going to construct it or not, etc. See how it goes? DOE's refusal to study viable alternatives (or any alternatives at all) is NOT legal.

The EIS is for the purpose of notifying the public of the environmental impacts caused by a government action. It doesn't mean there can be no impacts, it just means that the public needs to be "aware" of them. The EIS should rightly study different alternatives that would have differing degrees of environmental impact so that it selects the one with the least impact. There simply is no legal wiggle room to refuse to study any alternatives.

In addition to the Scoping Report, DOE also published a list of comments it received. See Appendix J. In addition to making sure your own comments were received and correctly transcribed into the appendix, you may want to browse and read some of the other comments. One that stood out to me is the comments of Stephen Jeffery, Counsel for Callaway Concerned Citizens Against Solar beginning on page 68 of Appendix J (the comments are arranged alphabetically by last name, look under "J"). He did an excellent summation of all the mistakes DOE has made so far, and why the mistakes are not legal. I wonder how much better it could get if he found out how merchant transmission works? At any rate, he's the one I would hire to sue DOE when their box checking exercise concludes with a fait accompli loan approval.

When will that be? It looks like the rush, rush hurry up EIS schedule has been a bit delayed. Originally, DOE said it would publish the draft EIS this fall, open a comment period, and have a decision on the loan by summer 2024. Now the draft EIS won't be published until winter 2024, and comments are expected to continue into summer. Looks like the GBE EIS is already around 6 months behind schedule. Expect further delays.

Here's the big question... will DOE bother to notify anyone when the draft EIS is published, or will it just make another quick upload to its website and stay mum? DOE has tured NEPA into a travesty. Shame on them!

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Spin Studies

9/17/2023

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Americans for a Clean Energy Grid is by far the king of spin studies. Even the name of this industry group is spin! "Americans"? It would be more aptly named "Corporations for Building Transmission From Which We Profit". CBTFWWP. Has a nice ring to it, doesn't it? Use of the word "Americans" is a tired, old front group tactic used by corporations to make you think that their front is actually made up of average people who love whatever is being sold. The only "Americans" here are corporations, and not all of them are actually American corporations!

ACEG is nothing but a transmission industry front group that writes numerous spin studies to promote their product, whether we need it or not. The studies aren't compiled for regular Americans like you... they are put together and promoted endlessly on Capitol Hill to convince your elected representatives that they should enact enabling legislation for more transmission, and more profits for their members. If you wrap your propaganda in a "study" it's supposed to have more clout. Another old propaganda trick!

So, here's the latest Spin Study being spun by CBTFWWP, and it includes a list of transmission projects we need right now to usher in a clean energy future.

The Spin Study names 36 transmission projects that it claims are "Ready to Go." It defines "Ready to Go" like this:

The determination of whether a project is ready-to-go relied on two criteria: 1) whether the project is at or near the finish line on the various federal and state permits they may need; and 2) whether the project is actively pursuing the cost recovery, allocation, and/ or subscriptions required for the developer to proceed. Inherently some judgment is re- quired. Based on these criteria we excluded over ten significant projects that are in earlier stages of development and not yet far enough along to be considered ready-to-go.

Has permits? Has cost recovery? Then what the hell is "Clean Line" doing on this list? The Oklahoma portion of the failed Plain & Eastern Clean Line isn't even a real project yet. What permits does it have? Who is paying for it? That's some "judgment"!

Clean Line – Originally proposed in 2009 by Clean Line Energy Partners to deliver renew- able energy from the Oklahoma Panhandle to Southeast markets, the Oklahoma portion of this DC merchant line was purchased and is now being developed by NextEra Energy.

The spinners justified their "judgment" for including this project with this article from 2017 that informs NextEra bought the remains of the Oklahoma portion. It doesn't say anything about permits or cost recovery. The only place "Clean Line" is ready to go is the trash can.

The spin gets even thicker on the projects that have failed since the first Spin Study.

Lake Erie Connector – DC line under Lake Erie, connecting Ontario with PJM, the grid operator in the Mid-Atlantic and Great Lakes region. The project had been under devel- opment for approximately 10 years, but ITC Holdings, which purchased the rights to the project in 2014, placed the project on hold citing economic conditions.

Oh? Economic conditions? How could that be so with all the government handouts to transmission in the IIJA and the IRA? Here's the "economic conditions" that have caused that project to be shelved... it's a merchant line that can't find customers.

“ITC made the decision to suspend the project after determining there is not a viable path to achieve successful negotiations and other requirements within the required project schedule. External conditions – including rising inflation, interest rates, and fluctuations in the U.S.-to-Canadian foreign exchange rate – would prevent the company from coming to a customer agreement that would sufficiently capture both the benefits and the costs of the project,” an ITC spokesperson said in a prepared media statement. “As a result, the company believes suspending the project is in the best interest of stakeholders.”

Lots of words in that salad when "can't find any customers at the price we need to build this thing" would do. It's a shame, too. That project was actually routed underwater so it didn't create any land impacts.

Speaking of word salad, the spinners claim that new transmission will be the key to reaching clean energy utopia.

Not only has investment in regional transmission lines been decreasing, but at the same time the need for regional transmission has been increasing due to a variety of factors. These include increasing demand growth, electrification of transportation and other sectors, higher natural gas prices due to European demand, a changing resource mix due to the economics of new renewable generation, increased customer demand for renewable resources, significant utility commitments for renewable energy expansion and decarbonization, and new public policies from local, state, and federal governments promoting carbon-free generation. The aggregation of these trends suggests a shift in the generation mix and significant load growth over the next few decades, both of which will require new transmission capacity.

But that's not even true. The spinners presume that all new transmission will be "for renewables." PJM Interconnection is the first to make a liar out of them by creating new transmission to feed Northern Virginia data centers from fossil fuel generation in the Ohio Valley.

Transmission capacity is also critical in helping shift national economic policy toward an increased focus on onshoring manufacturing to develop domestic supply chains. De- velopment of new domestic manufacturing along with growth in data centers, partially driven by AI, represents the potential for significant economic growth and job growth for the US.

These new manufacturing facilities, along with new data centers, often require additional transmission to ensure the grid has the capacity to reliably interconnect significant new industrial loads. However, delays are already beginning to occur. Interconnection requests for data centers have dropped across the country and in Northern Virginia – a national hub for data centers – there is a scramble to meet the soaring power demand as current grid capacity is limited.

Some experts estimate that fully electrifying the US’s industrial load could more than double current US power demand. The current issues are arising even before manufacturing for microchips and additional electric vehicle production and battery manufacturing facilities fully ramp up, along with hydrogen production facilities. If sufficient transmission capacity is not available, these investments could be significantly delayed or even canceled.

That's right... when PJM was faced with new data center load, it did not propose transmission from renewable generators to meet need. That's because data centers use as much energy as large cities, and you can't reliably serve them solely with intermittent renewables. New data center load will INCREASE carbon emissions by ramping up the generation of fossil fuel electricity. This is what is going to happen when load increases... transmission connecting existing fossil fuel generators will be proposed. New data centers actually crash our clean energy policies.

The Spin Study has been produced for one purpose only... to pander to Congress to pass even more enabling legislation for transmission. Its recommendations to do just that are at the end of this "study." It recommends special tax credits for new transmission, federal transmission permitting and siting, federal eminent domain, and wider cost allocation.

There are also additional policy levers that Congress and FERC could pull to help facilitate faster and more effective buildout of new transmission. Americans for a Clean Energy Grid’s Legislative Principles outlines a number of these potential approaches.

I'd like to pull a couple levers... maybe the one that sends this Spin Study to the dumpster.

Enabling new transmission with legislation is the fast track to increasing carbon emissions.

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Is PJM's Competitive Transmission Process Rigged?

9/14/2023

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Something is sure starting to stink!

Since the old PATH days, PJM has been required to revise its transmission planning to put long-lead needs out for bid in a competitive process. This is supposed to ensure that PJM's 65 million electric consumers pay a lower cost to construct the transmission they need. It is supposed to give independent transmission companies an opportunity to build projects cheaper than the utility that serves the impacted service area, which PJM refers to as "incumbents." This is supposed to produce lower electric bills for the consumers.

Does this really work as regulators intended? Over the years I have read about various complaints made by some of the competitors in PJM's competitive "Open Window" transmission bidding process claiming that their project was not treated fairly. I can see how they might come to that conclusion. I'm seriously starting to develop the opinion that PJM's competitive process is nothing more than Kabuki theater performed to hide uncompetitive behavior that produces financial windfalls for its incumbents. PJM's thumb is on the scale... maybe its whole body! This process cannot be be called transparent and competitive by any stretch of the imagination.

PJM's bidding windows present a problem to be solved with transmission. Any qualified entity may submit a proposal. PJM publicly posts redacted versions of all the proposals it receives for a window here. Select 2022 Window 3 from the list, to see an example. Next, PJM creates maps for each proposal because a picture is worth 1,000 words. However, PJM's map-making skills leave much to be desired. A creative Kindergarten could do a better job making accurate maps with finger paints. Already for Window 3, we have seen at least 5 different versions of maps for the proposals. I'm pretty sure the actual number is much higher than 5, but I haven't been keeping track. PJM has been notified of numerous additional errors in its newest version of the maps, however PJM has not corrected any of the errors, nor even responded to emails pointing them out.

Errors in PJM maps include drawing greenfield transmission lines as brownfield and making inaccurate designations between greenfield and brownfield; creating substations that are not part of any proposal; mismarking the voltage of new substations; leaving components off certain maps... and I could go on because the list of errors is as long as my arm.

PJM chooses not to explain itself, nor why it is attempting to create maps when it does not posses the proper skill set. Why doesn't PJM simply require the bidder to include an accurate map of its project components using certain parameters? It would have saved loads of time and money so far for Window 3.

PJM's maps include a completely different legend for each map in the Window 3 series. In some legends, a 765-kV substation is pink, in others, it is red. In some maps, the colors in the legends do not match the colors on the maps (go ahead, PJM, find the map where a color not on the legend appears -- I double dare you!). It is impossibly confusing to flip between the different maps to compare different proposals because the maps are not equal. Some are definitely manipulated and do NOT follow the written proposal or provide an accurate comparison to other proposals. It's almost like PJM is using the maps as an influencing tool.

Who is PJM trying to influence with its maps? I have asked PJM repeatedly what it does with these maps, and it has refused to answer. I'm going to assume they CAN'T answer because the answer may point to the real reason for this map-making incompetence and, perhaps, purposeful manipulation.

Here's another uncompetitive process at PJM... I wanted PJM to accept public comment regarding the proposals in Window 3 to compile for its feasibility study. The feasibility study looks at things like routes, environmental considerations, permitting, supply chain, cost of the project and the possibility of delay relating to community opposition to the proposal. Since a number of the proposals in Window 3 are basic recycling of old projects that were opposed and abandoned, I think it's only fair that the feasibility study acknowledge how and why these projects failed the first time and what may have changed that would make them successful this time around. But, PJM just gave me the run around instead of being appreciative of more information for its feasibility study. PJM would only receive verbal public comments at its monthly TEAC meetings, which requires a complicated and frustrating sign up and registration process and then several hours of waiting for the appropriate time to comment. And even then, PJM was rude and argumentative with the few people that managed to jump all these hurdles in order to comment. PJM preferred to argue over meeting procedures than the substantive issues. You blew it, PJM! This is not what an open and inclusive stakeholder process looks like! PJM has flat out refused to respond to my many attempts to find a way to accept, compile, and include public comments in its feasibility studies.

PJM says that it has hired a third-party contractor to prepare feasibility reports for its preferred scenarios. Will the contractor use the maps for its evaluation? If so, it will be evaluating something that is not accurate. An evaluation of an inaccurate proposal results in an inaccurate study. What a waste of time and money! Will the contractor use information about routing, permitting, environmental issues, and the possibility of opposition for its evaluation of the feasibility of the preferred scenario? Signs point to "no" since PJM is trying so hard to make sure any public comment stays far, far away from its contractor. If the contractor does not know about obstacles, then it won't include any in its feasibility report... smooth sailing ahead (while the people on the ground are swearing vehement opposition).

However, PJM also uses its feasibility reports and maps to inform its Board of Managers about the projects it is recommending for approval. Therefore, an inaccurate feasibility report gives an inaccurate picture of the recommended projects to the Board of Managers. How can the Board of Managers accurately evaluate recommended projects when the information they receive is inaccurate, or perhaps manipulated to influence their decision and lead them down the primrose path to making the decision to approve the recommended projects based on pure fiction?

I'm starting to believe PJM's "competitive" process is rigged through the manipulation of mapping and feasibility studies that drives PJM to select and approve a project unfairly.

Ball in your court, PJM.

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The Haves And The Have Nots

9/8/2023

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Data Centers in Northern Virginia need more power. They can't get it from local suppliers in Virginia, therefore regional grid operator PJM Interconnection has asked for new transmission proposals to import new electricity supply to serve the Northern Virginia data centers.

But why can't they build more renewables in Virginia to power the data centers, you ask? First of all, the data centers need as much electricity as a large city. Imagine taking New York City and plunking it down next to Dulles Airport and expecting to hook up to the existing electric system. The data centers use half as much as NYC! The load is just too great to solve with new renewable generators at load. This is a fact that seems to be escaping the elected officials in Virginia -- they don't realize how much electricity these data centers use.

Bates said he didn’t realize running a power line to a data center was considered a transmission line.

We all need to educate our local officials on the consequences of building energy sucking data centers in our communities. It's not just a distribution service line on small wooden poles like homes or businesses use. The power requirements are so great that data centers need big new high-voltage transmission lines and substations. They also need big new energy generators to produce the energy used.

Transmission opponent Patti Hankins from Harford County, Maryland, has put together an eye-opening presentation showing the energy supply profiles of several Mid-Atlantic states. Is your state an electricity importer or an electricity exporter? Nobody seems to be paying attention to this important fact these days, when everyone seems to be focused on increasing renewable generation and phasing out fossil fuels like coal, gas and oil. The media drones on incessantly about closing fossil fuel generators, and many people think that renewables like wind and solar supply a huge amount of our energy. What's really happening up the line when you turn on your light switch?

This presentation tells you everything you need to know.

comparison_of_pjm_state_installed_capacity_2022.pdf
File Size:	2140 kb
File Type:	pdf

Download File

Did you know that Pennsylvania and West Virginia are the only two states in our region that export electricity to other states? Pennsylvania's electricity is mainly created from natural gas, with coal and nuclear making up the vast majority of the remainder. In West Virginia, the numbers are even more astounding, with 91% of the supply created by burning coal. Natural gas makes up the majority of the remainder. In both Pennsylvania and West Virginia, wind and solar provide so little energy that it's hard to even see their slice of the pie.

On the other hand, states like Virginia, Maryland, the District of Columbia (that imports 99% of the electricity it uses!), Delaware, New Jersey and Ohio are big energy importers. These states all have renewable energy goals and policies that have served to shut down a big majority of the fossil fuel electric generators that used to supply their energy. Additions of wind and solar have not kept up with the supply lost by closing fossil fuel generators. Even in these renewable loving states, wind and solar make up a very small percentage of the power that is used. The percentage is so small that it cannot support the state's electric load under any circumstances. So, where do these states get their electricity? From West Virginia and Pennsylvania via high-voltage transmission lines. Little do these states know that when they turn on the light switch, they are using good, old-fashioned coal and natural gas. And they stand ready to INCREASE their use of fossil fuels by building more energy hogs in their areas. This is the reason PJM is currently proposing a high-voltage transmission build out of epic proportions.

The thought of building the big baseload generators needed to power the new data centers near the data centers isn't even contemplated. It would never happen! However, why is it okay to increase the burning of fossil fuels in other states in order to power new data centers? Don't we all breathe the same air? Who's the NIMBY now?

We're not as far along on a renewable energy transition as people are being told by the media. Wind and solar is getting all the attention (and government handouts), but it's actually powering little. The corporations, utilities, and local governments lie about how "clean and green" they are. If they actually only used the renewable energy they produce, their lights would be out for a vast majority of the time. Without West Virginia and Pennsylvania burning fossil fuels, polluting their environments, and sacrificing to build gigantic new electric transmission line extension cords to the east coast cities, these areas would experience rolling blackouts worse than a third-world nation.

Another lie the media loves is that we need to build new high-voltage transmission to ship renewable energy around the country. After looking at these graphs and maps, you'll realize this just can't happen. We are currently stuck in a world of HAVES and HAVE NOTS. West Virginia and Pennsylvania HAVE the electricity and Virginia, Maryland, DC, Delaware and New Jersey HAVE NOT. What's really going to be on these new transmission lines is fossil fuel electricity from states with enough to export. So while the federal government comes up with new programs and taxpayer-funded giveaways to grease the skids for new transmission, they must acknowledge that the only thing they are actually doing is INCREASING emissions.

Elected officials considering new plans for data centers and other big energy hogs that they hope will bring new tax revenue, jobs, and economic development need to recognize that their state does not have enough electricity supply to support this new infrastructure. New transmission lines from states that burn fossil fuels is not the answer. The data center boom must be paused until the localities that will reap the financial rewards can build the clean infrastructure they will need to support it.

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Nobody Asked Me

9/7/2023

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...and I'm betting nobody asked you either, but Big Green has now proclaimed that

If care is taken to make sure that host communities benefit in the short and long term from the energy projects in their backyards, they will be less inclined to oppose them, leading to faster timelines for clean energy and transmission projects.

Of course, this is a baseless statement. There has never been a transmission project where "communities" received so much benefit that they dropped their opposition (or never started opposition in the first place).

Nevertheless, these Big Green blowhards are courting Congress to pass more legislation greasing new transmission, wind and solar projects. And they're pretending they speak for impacted landowners. Their bold new plan has been issued as another tedious "report".

The report says the craziest stuff, like:

Community opposition to large-scale wind and solar projects is growing across the United States. There are many reasons for this trend, including misinformation about renewable energy, concerns about project impacts, and concern that most of the benefits flow outside of the community while the burdens fall within. Communities often see hosting renewable energy projects and transmission (which touches multiple communities) as an impediment to their goals, such as preserving community identity, land preservation, and in some cases ensuring ecosystem conservation. While some landowners see these projects as a potential source of revenue from leases, others worry that the projects will reduce the value of their land. Finally, in many communities, while there may be both supporters and opponents of clean energy projects, the opponents are often more vocal, better resourced, and more passionate than the supporters. Because of all these factors, an alarming number of communities are adopting restrictive zoning and land use ordinances that effectively ban the siting of clean energy projects.

This rise in opposition highlights the importance of ensuring that developers and local officials disseminate accurate information about potential projects and that the permitting process allows engagement from a broad range of voices so that decision-makers can accurately assess the environmental impacts as well as benefits of projects. Furthermore, it is important to ensure that host communities share in the benefits of projects in their own backyards.

Misinformation you say? All the misinformation is coming from project developers and proponents. Nobody trusts them because they are in hot pursuit of the almighty dollar, not local interests. The "information deficit" ploy has never worked. Minds are never changed no matter how much nonsense the developers spew. We're not stupid, uninformed bumpkins that just need to be "educated." Is this going to become a free speech issue where "misinformation" is outlawed and the developers are judge, jury and executioner of misinformation?

We're NOT better resourced than deep-pocketed developers. We're just speaking the truth. Truth still matters in rural communities.

Several states, including New York, California, Illinois, and Washington, have enacted laws that improve the siting process for large-scale renewable projects and provide potentially powerful models for similar legislation in other states. Among other things, these laws modernize the permitting process and explicitly provide benefits to host communities via mechanisms like utility bill discounts. States should be encouraged to adopt model siting and permitting laws that expand community engagement while limiting the ability of localities to unreasonably ban all wind and solar projects.

The LAST thing rural states want is to be like California or any of those other states. We live here for a reason... because it's NOT California.

But the best part of this idiotic paragraph is the statement that we can EXPAND community engagement while LIMITING the actions the communities can take. That's not engaging the communities... it's oppression.

Bringing communities from opposition to support—or at least to open-mindedness—is a major challenge to renewable energy growth that needs sustained effort, engagement, and thought. Our recommendations provide a starting point.

And also an ending point because rural communities aren't going to fall for any of your B.S. It is IMPOSSIBLE to undo opposition to big energy projects that benefit far away cities. Build your own power plant in your own backyard, you sanctimonious morons.

Coalitions should work together to build support for well-sited projects that benefit the host community. In cases where developers have done their due diligence as outlined in the preceding recommendations, environmental and conservation groups, labor groups, local landowners and businesses, and other stakeholders—including, where relevant, environmental justice and tribal groups—should form coalitions and work together to support the project. A key part of this support should be highlighting the community benefit agreements, payments in lieu of taxes or other mechanisms for benefit sharing, the creation of local jobs, and addressing other ways to compensate local landowners for any perceived or actual diminution in property values.

Coalitions of the unaffected? Utilities have been trying this for decades without success. These coalitions have always been outed for the greedy, paid off schills that they are. We don't need these idiots to advocate for "benefits" for us because these "benefits" are really for them. There is no benefit that can outweigh having a new transmission line in your back yard or across your prime farmland. What these coalitions actually try to do is simply outshout community opposition and collect benefits for themselves. It's a tactic that never works. Regulators aren't stupid, you know, and they've seen this a thousand times.

This new report is complete garbage. However it has now been made crystal clear exactly which idiots are writing all the new clean energy legislation. It's not your elected representatives. It's private interests.

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How To Profit Off The Misery Of Others

9/4/2023

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As I wrote in February, the U.S. Department of Energy has $760M burning a hole in its pocket. The Inflation Reduction Act created the Transmission Siting and Economic Development Grant Program, which intends to give your tax dollars away to get new transmission built faster. The program proposes to give grants to state and local siting authorities (your state utility commission) for the purpose of studying new transmission proposals, creating public engagement, and approving them lickety split. But that's not all... the geniuses have also come up with "economic development" grants for "communities" affected by the construction and operation of new transmission projects. The grants are available through your local government. If you want to make some quick cash for "economic development" projects, just form an organization and ask your county to assist you in applying.

But the DOE forgot to define an "affected community." Who is "affected" by new transmission? Is it the landowners who are coerced to grant easements for the project under threat of eminent domain? Is it adjacent landowners who won't have easements but may still have to look at it every day? How far out from the center line of the new transmission project does an "affected community" spread? What if it is on the other side of the county, where they won't see or hear any construction or operation? Is it a nearby city or town that also will not see or hear it? What is an "affect"? DOE somehow fails to say in its wordy rules for applying for one of these grants.

Either DOE is going to be flooded with applications from governments and organizations who have only a tertiary relationship to an "affected community" but a huge appetite for government cash, or it is not going to get ANY applications at all. Landowners and persons living on or near new transmission lines won't be forming organizations and begging for taxpayer cash. They simply want the transmission project to go away... maybe it can go in the backyards of the grant recipients? Wouldn't that be ideal?

DOE is holding another one of its ridiculous webinars that almost nobody attends to explain to the public how its new TSED program works and how to apply. The webinar is scheduled for September 14. You can sign up here.

Ask them who is eligible, and how "affected" your community must be to receive a grant.

This is nothing but taxpayer funded bribery. Pretty amusing that DOE will prohibit using any of its grant funds to lobby federal elected representatives (Congress) but has no prohibition on lobbying your state elected officials, your state public service commission, or any other entity that must approve the project before it can be built. Don't they realize that these grants ARE lobbying at the local level?

And how are these grants to unaffected organizations going to speed up the siting and permitting of new transmission projects? They won't. No landowner in his right mind would support a transmission project across his property in exchange for bribe money given to an unaffected person or organization.

This program is headed nowhere but to court, however it's going to waste millions of your tax dollars on the way. But don't worry, it's reducing inflation, don't ya know?

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Grain Belt Express Asks For Loan From Shady DOE Office

GBE FERC Amendment Questioned by Missouri Landowners Alliance

PJM Selects New Transmission Scenarios

Missouri PSC Speculates On GBE

U.S. DOE Box Checks EIS Scoping

Spin Studies

Is PJM's Competitive Transmission Process Rigged?

The Haves And The Have Nots

Nobody Asked Me

How To Profit Off The Misery Of Others

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