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MO PSC Hearing - Part II

6/22/2023

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The good news -- I finally finished watching the 30+ hours of PSC hearings.  The bad news -- I need to write it all up according to my notes (3 more pages).  With a dreary rainy (hurray!) day today and nothing better to do, buckle up, it's going to be a long one.

I will begin with GBE witness Kevin Chandler.  I got to wondering why the transmission company land acquisition guys are always so contemptible.  I feel like I've watched this guy a thousand times, each with a different face.  They are completely devoid of empathy for the people whose lives they permanently impact.

Anyhow... Kevin said that when a landowner asks to have the project buried, he must reject that for the reasons already mentioned in Mr. White's testimony.  He proceeded to list Invenergy's "reasons" for not burying:

1.  Tiger Connector is a double circuit so it needs two trenches as per regulations. 
2.  There are thermal considerations (i.e. the line gets too hot when buried).
3.  It's more disruptive to farmland to dig a trench across it.

Let's tackle these in turn.  Double circuit would need two lines if on towers, and those lines can be right next to each other, but not if buried?  There's no logic here.  I'm not sure Kevin got this right.  Thermal considerations are not insurmountable for buried AC lines.  There are plenty of buried AC lines that utilize conduits and cooling fluid to keep temperatures in range.  It is possible.  Digging a trench across farmland?  Whoever said GBE should be buried on its preferred route?  Burial has always been tied to minor rerouting to utilize existing road/rail rights of way.  GBE avoids that question by pretending landowners want to bury it across their farmland.  Landowners want it buried on existing rights of way in order to avoid their farmland altogether.  And, finally, all these excuses could be avoided if GBE had seriously considered burial on existing ROW years ago, when it was first raised.  A line buried on existing highways or rail could have been rerouted to connect in Callaway County without the need for a "Tiger Connector" in the first place.  But GBE has refused to ever consider it.  Why should the company be rewarded for its obstinate behavior that creates a project more damaging to host landowners than it needs to be?  At what point will the PSC take the reins here to protect the public?

There was a whole bunch of confused discussion about GBE's annual payment option for landowners that was never cleared up (although some people seemed to think so).  If the landowner "selects" the annual payment option, then he is paid 20% of the agreed price at signing.  He may be paid another 10% of the agreed price 3 years later, if construction has not yet started.  His annual payments begin when construction starts?  ends? Who knows?  The annual payment is 5% of the remaining balance.  He is paid 5% the first year, and the payment is escalated by 2% for each remaining year as long as the right of way is used.  What was never properly laid out is the number used for the 2% escalator.  Is it 2% of the balance due to landowner?  If so, every landowner should take this deal.  Or, is it 2% of the 5% of the balance due to landowner?  If so, every landowner should reject this deal.  There was a lot of funny math going on by people who probably shouldn't do math in public.  Let's try to clear this up.

Agreed price $100,000.  20% initial payment = $80,000 remaining balance. No point in including the 10% at year 3 payment because it may or may not happen.  Let's keep that balance at $80,000 when annual payments begin.  Five percent of that is $4000.  Landowner will receive $4,000 on year one.  If the 2% escalator is on the $80,000 balance, then the landowner would receive $5,600 on year 2, climbing to $7,200 the next year, increasing $1600 per year.  However if the 2% escalator is based on that 5% $4,000 first year payment it will only be $4080 at year two, $4160 at year three, climbing by $80 per year.  Honestly, the second scenario is more likely.  However, even when the judge requested to see a GBE landowner form with this proposal set out, it seems like she got everything but (easement, crop, structure payments).  I saw no indication that there actually was a landowner handout that properly explains how this annual payment would work.  Is it even legal to rope landowners into that scheme without a proper explanation?  The PSC needs to make sure that landowners are properly informed of how this annual payment would work before they are offered a deal.  Personally, I would like to know why the landowner cannot be paid 100% when they sign the agreement, like any other real estate deal?  If the property is taken using eminent domain, GBE would have to pay landowner 100% when its petition was granted.  Whoever thought paying a pittance percentage should be allowed in the first place?  Why isn't interest added to the subsequent payments, which for some landowners can come a dozen years after they sign an easement agreement?

Chandler was asked repeatedly whether an eminent domain case would contain all the terms in the company-written easement being offered to landowners.  The company-written easement includes such things as permission to sell additional uses of the ROW and allowing GBE to pocket the cash for the additional use of your land.  The easement agreement also includes a provision that landowner waives setbacks.  It also has a provision that requires the landowner to "cooperate" with GBE approvals and permits, including allowing GBE to sign things in the landowner's name.  NONE of that would be granted by a court in an eminent domain taking, and GBE would be laughed at for suggesting such things.  Why is this so hard for Kevin Chandler?  He drank way too much water and deferred to another witness.

When asked why GBE did not attempt to site its project on existing rights of way, Kevin said that it was because there was too much stuff built near the existing lines.  I suspect that the true answer is that GBE has no right to use the rights of way of other public utilities for its  merchant project.  GBE didn't even TRY to find another route for Tiger on existing lines (whether existing lines could be upgraded or expanded instead of taking new right of way for Tiger).  Of course, if another utility's lines were used, GBE would lose control of Tiger and someone else would build it and collect the profits.  Therefore, landowners were tossed under the bus like so much garbage so that public utility fiefdoms could stay intact.

The subject of land agent harassment came up.  Kevin denied it ever happened.  But why did he turn so completely red and look away from the bench when he answered?  His denial was maybe not the complete truth.  Didn't need a psychologist to figure that one out.

There was a question about whether landowners agreed to changes in the agricultural protocols.  Landowners have NEVER been consulted about the Ag Protocols in the first place -- they were a deal negotiated in secret by former Gov. Nixon and GBE.  Why start now?

GBE said it cannot get the project financed if they don't have all the land they need.

Kevin's excuses for not agreeing to include structure payments for Tiger if lattice structures are used was not believable.  He said there was no need because Tiger's monopoles would not change.  Is that like how Clean Line's monopoles for GBE were tossed in the trash when Invenergy took over?  Landowners on the HVDC portion were promised monopoles for years.  Many of them signed easement agreements based on monopoles, however now Invenergy is using exclusively lattice structures.  Should all these old easement negotiations be reopened?  Anyhow, Kevin said that letting the landowner choose which payment plan he wanted based on what was more beneficial would not work because it would be too "difficult" for GBE (and maybe marginally more expensive?).  Kevin said it would be too "difficult" for GBE to process different agreements for different landowners.  For crying out loud, how incompetent are you that all agreements must be the same or you can't handle doing them?  Kevin also said that landowners would have a hard time making a choice because they wouldn't know how many and what kind of structures there would be when easements are signed.  If you have no idea what you are building, Kevin, why are you asking landowners to sign agreements?

Next witness (and I hear you all groaning in relief, like I did) was Dr. Loomis, the guy with the computer generated study of all the economic development and jobs that he purports will happen if GBE is built.  I will keep this short, because I'm not sure anyone believes this computer-generated nonsense.  Although Dr. Loomis's report calculated "benefits" it did not include any financial detriments, such as lost farmland, lost jobs, reduced local power production.  It's all sunshine and roses in Dr. Loomis's computer.  Basically, I think his study is a "garbage in/garbage out" situation and nothing he said made me change my mind.  It was interesting that the Commission thought his report was crap in its 2015 decision denying GBE, but not crap in its 2019 decision approving GBE.  Just goes to support my longstanding theory that regulatory bodies do not consider the evidence and then make a decision based upon it, but that they make a decision in advance that is not evidentiary based, and then use the evidentiary record to fill in the blanks to create reasoning for the decision.  Any piece of evidence can be considered or not, depending on the decision that has already made.  Keep that in mind as we move forward here.

Perhaps the bright spot of this hearing was the MO PSC Staff witnesses.  They were credible, down to earth, plain speaking witnesses who apparently have never thought GBE was a good idea for Missouri.  Most of their testimony was short and their appearances on the stand brief.  GBE knew better than to poke a stick into the lion's cage.  The Commission would do well to listen to them.  After all, that's what they are paid to do... the technical stuff, the brain power, the experience that guides the appointed Commissioners to make a reasoned decision in the best interest of Missouri.

And then there was Michael Stahlman, the lead Staff witness (who had been sitting with Staff counsel through most of the hearing).  Stahlman told the actual truth, even when it was not what someone wanted to hear.  Stahlman testified that GBE's "bi-directional" capability should not be depended upon as a reason for approval.  He said that using this capability was dependent upon GBE getting withdrawal agreements from the RTOs.  My take is that in order to actually deliver power from elsewhere in an emergency, GBE would need permission to withdraw that power from elsewhere.  GBE can't just be a power vacuum, sucking up what it wants and blacking out certain regions that are left with reduced supply.  Stahlman said that Staff opposes the "phasing" of the project into two independent parts.  He said there was no justification for making this change.  I think he's right because GBE will be stuck waiting for its U.S. Government loan approval until probably 2025 or so.  By that time, it should be almost ready to go in Illinois, right?  Certainly ready enough to begin construction on the western end.  Why must GBE have this "phasing" approved?  It purports to have all the permits it needs to get started, except Missouri.  The explanations are not logical.  Could it be because it doesn't have enough customers to complete the whole project?  Staff believes the project needs both "phases" for optimal operation and financial success.  I think Staff is spot on.

Couple other tidbits from my notes of this excellent witness (that I spent more time listening to than taking notes apparently because my notes are incomplete)  Grain Belt Express never submitted evidence proving that the Commission's finding in its last order that power prices are $10 higher in PJM is no longer true.  We are stuck with that finding and must start there for this "amendment."  With no evidence that the financial success of the project is NOT dependent on selling capacity to PJM, there is no evidence that the project would still be financially viable without the PJM connection proposed for phase 2.  GBE completely failed to produce any evidence to change that finding.  Some times the most expensive attorneys are not "all that and a bag of chips."  Sometimes they make huge blunders because they don't concentrate on the right things.

There is only ONE contract for GBE, in Missouri or elsewhere.  Based on GBE's worksheet submitted as evidence, other customers are expected to be charged a price that is 10 times higher than the one negotiated with Missouri Electric Commission.  No wonder it doesn't have any other customers.

The success of the project should be based on actual future revenue, not simply projected revenue based on MOU's that are not actual contracts.

Stahlman said that the 74% capacity factor for Kansas wind and solar in GBE's study is not realistic.

There are too many assumptions being made because the Commission is being asked to take GBE at their word of what may happen in the future. 

Stahlman said most of GBE's studies are studies of social costs and benefits, instead of the economic feasibility studies the Commission needs to approve the project.  I got the impression that there was a lot of useless fluff in GBE's testimony, perhaps designed to hide the facts.

Stahlman said there is no evidence the project is economically feasible if built in phases.  If GBE's change is not approved in this proceeding, it still has permission to build its project as originally proposed, so it's not like the Commission would be denying it.  However, the same economic feasibility questions arose in the last case and the Commission approved it anyhow.

There was some discussion about whether lower power prices assumed by GBE would help ALL Missouri ratepayers.  No matter how much Stahlman tried to explain this, nobody seemed to get it.  Two ways utilities can meet load in Missouri - either produce their own power or buy it from the market.  When they buy it from the market, lower prices there mean lower prices for consumers.  But for utilities that still produce their own power, lower prices in the market mean higher prices for their customers.  This is because a company that owns its own generation usually sells a portion of what's produced and not needed into the market.  The proceeds for the sale of the extra electricity generated and sold offset the costs for the customers, producing a lower cost because they got dividends from power sales.  Lower market prices mean the dividends they get from power sales are smaller.  That makes their rates higher.  Why was that so hard for everyone to understand?

Stahlman took every opportunity to bring up the GBE FERC complaint that GBE wanted to bury.  Eventually, the judge decided that the FERC complaint was not relevant and refused to take official notice of it for this case.  The Staff counsel said something like denying the Commission the information in the FERC complaint deprives them of knowledge crucial to the case.  This is perhaps the most important statement uttered during this whole proceeding.  Why shouldn't the Commission listen to testimony explaining that case?  Is it because they are too lazy to take in more information?  Do they operate in a silo?  I don't think so since one of the Commissioners asked Stahlman whether he thought Invenergy would go to FERC to get what it wants if the MO PSC denied the application.

Basic understanding of the FERC complaint is important to Missouri's future, both with and without GBE.  It's important for Missouri ratepayers who will never take service from or pay for GBE.  Here's the FERC complaint, in a nutshell.  GBE wants MISO to reopen its Long Range Transmission Plan approved and ordered last year in order to include a completed GBE in its base case.  The base case is the presumed future transmission system that MISO uses as a starting point for its planning.  Including GBE in the base case does NOT include it in MISO's transmission plan, but could lower the amount of new transmission needed.  MISO did not include GBE in its base case because GBE had not yet signed an interconnection agreement and therefore the project was not certain enough to be included.  GBE says that if MISO re-opens Tranche 1 and adds GBE to the base case, then several new transmission projects approved and ordered by MISO will no longer be necessary.  GBE says that its project will fill the need that those projects are meant to fill.  In other, simpler words, GBE is worried that MISO's planned projects will compete with GBE and could be a reason why GBE can't find customers or sell at the price it needs to make its project economically feasible.  GBE wants its project included in MISO's plan to eliminate any competition from generation in Iowa shipped to Missouri on new MISO Tranche 1 lines.  How many times did GBE witnesses talk about congestion on MISO's lines making generation from Iowa more expensive than GBE?  If GBE is so worried about competition from new MISO transmission lines that it would file a complaint against MISO at FERC, then it must believe that MISO's projects would make GBE uneconomic for customers.  If GBE was cheaper for Missourians than buying wind from Iowa, GBE would not care if MISO build some new projects that couldn't compete.  It is only if GBE knows that its project cannot compete with MISO's projects price-wise that trying to stop MISO's projects is necessary.  If GBE wins at FERC, Missouri ratepayers may be tied into using GBE at the price it sets, instead of buying renewable generation from Iowa at lower prices.  This is why the FERC complaint is relevant. 

The next witness from Clean Grid Alliance seemed to agree that generation in Iowa is "more expensive" because of congestion in MISO's transmission system.  Kind of supports what I just said above, right?  If MISO removes that congestion by building new lines in its Tranche 1, then suddenly Iowa wind can compete with Kansas wind to bring cheaper power to Missouri.  Then the CGA witness tried to pretend that there is such a need for renewable generation in Missouri that BOTH GBE and Tranche 1 are needed.  If that's true, what's the point of the FERC complaint?  Thanks for making my points for me, Goggin.  Then he tried to say that all transmission projects built exceed their benefit estimates, so we should just build them all.  Not really a useful witness for GBE at all.  Bravo!

But even worse than that was Sierra Club's witness.  For all his "experience" in transmission, he seemed to know a lot less than I do.  Has he been hiding under a rock for the past decade?  Most of his testimony was based on a DRAFT U.S. DOE transmission needs study that received much criticism when it was released (See Appendix A-2, Comment Matrix).  He said that because DOE found a "need" for transmission that GBE needs to be built.  DOE is not a transmission planner and the purpose of the study is not to plan and permit transmission.  The DOE study cost/benefit ratios are not applicable to GBE because it is a merchant project without a cost/benefit ratio.  You can't just apply a number to all projects because of one generalized study.  The witness did not acknowledge GBE as a merchant project and may not even understand what a merchant project is.  Nobody asked him.  The witness thinks we need lots of new transmission as "insurance" against blackouts.  At a cost somewhere in the trillions, that's a pretty expensive insurance policy.  There are much cheaper solutions.  This witness has not done any real analysis of GBE or the economic feasibility of GBE's phasing proposal.  We might as well just stop talking about this witness because he was just full of irrelevant opinions and I'm about to fall asleep myself just thinking about him.

Next up was pro se intervenor Pat Stemme.  One of the Commissioners asked her if her pre-filed testimony was different than the spoken testimony she gave at one of the public hearings.  He had not even bothered to read her testimony before the evidentiary hearing to find out it was different!  How much testimony did this (or other Commissioners) actually read?  How much of the extensive record did the new Commissioner read before taking her seat on the bench?

And I would be remiss if I didn't comment on the Renew Missouri witness, James Owen, since he gives me the impression of being very, very, very, very, ultimately important.  So important that he was allowed to sit in the witness chair with a big attitude.  He tried to say something about the FERC complaint, but it was laughable because it was so wrong.  I don't think he actually knows anything about it.  I wonder if he's read any of the documents?  Commissioner questions were so beneath him that he actually tossed his head and rolled his eyes when informed that the Commissioners DID have questions.  Really?  This guy was way too dramatic and did not show any common courtesy to the Commission.  My mama always said that you catch more flies with honey than you do with vinegar.  And apparently Owen's taste in movies sucks.

Initial briefs are due June 30.  That's next week!  Reply briefs are due July 14.  These attorneys have their work cut out for them.  Best of luck, fellas!
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Big Green Groups Pretend They Represent Landowner Interests

6/21/2023

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After watching the spectacle of all the environmental groups aligned with renewable energy company Invenergy taking up space and advocating for Grain Belt Express at the Missouri Public Service Commission a couple weeks ago, it's hard to imagine these groups are "protecting" landowner rights.  But that's just what they are currently purporting to the Federal Energy Regulatory Commission. 

FERC has opened a Rulemaking proceeding in order to update its rules for permitting interstate transmission projects.  Although this ability was originally granted in the Energy Policy Act of 2005, several court decisions nullified it for more than a decade.  However, the Investment and Jobs Act (aka Bipartisan Energy Bill) nullified the court decisions and reinvigorated FERC's authority by directing FERC to permit transmission lines that are denied by state regulatory commissions.  The time to oppose this provision has passed.  It's been signed into law.  Now we have to deal with reality.

And reality is in shaping the existing rules to make a federal permitting (and eminent domain) process as fair as possible for landowners.  A group of transmission opposition group leaders from across the country submitted initial comments to FERC last month.  We recommended several steps FERC could take, and things it could add to its review, in order to level the playing field for landowners who find themselves involved in pitched battles to save their property through no fault of their own.  Nobody asks to have a transmission line sited on their property.  It just happens.  And then these unfortunate landowners suddenly find themselves having to hire lawyers and get involved in energy permitting.  Nothing at all fair about that.  FERC should not be making participation harder for landowners.

But a bunch of other groups also filed comments at FERC, including a whole bunch of environmental, policy and partisan political groups who think we should build a whole bunch of new transmission in a big ol' hurry.  When we wrote our comments, we didn't dwell on environmental policy and environmental requirements for FERC's new rules.  That's not in our wheelhouse.  We are not the experts at environmental policy.  We left that to the environmental groups to file comments advising FERC how it should write its environmental rules.  However, those environmental groups did not give landowners the same courtesy.  After telling FERC how they love new transmission "for renewables" and demanding that FERC enable a quick and expensive transmission building renaissance, these environmental policy and political groups proceeded to weigh in on creating fair rules for landowners and local community opposition groups.  What do these groups know about transmission opposition and landowner concerns?  Turns out nothing at all.  What do these groups know about transmission permitting cases?  Turns out nothing at all.  These groups don't know diddly about landowner concerns because it is not in their wheelhouse.  They are not groups whose mission is protecting landowners from electric transmission companies.  In fact, their missions are to "help" the environment by building more wind + solar + transmission. 

Isn't that the fox watching the hen house?  You betcha!

This week, the Impacted Landowners group filed reply comments telling FERC that it should ignore the claims of environmental policy and political groups that they represent the interests of landowners.  The landowners asked FERC to hold a listening session exclusively for landowners so they could hear our concerns without us being drowned out by a bunch of know-nothings who have their own interests at heart, not ours.
rm22-7_reply_comments_final.pdf
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What logic is there to FERC ignoring the concerns of landowners who might participate in FERC permitting cases, while shaping them to give advantage to big green political groups?  We are being marginalized by a bunch of blowhards who claim to be representing our needs but in actuality are doing nothing more than helping themselves by mowing us down.  If FERC wants to fairly issue transmission permits that are not bogged down by landowner opposition and appeals, then it must listen to landowners, not clueless policy groups who have never been involved with transmission permitting or even spoken with a rural landowner targeted by transmission.

MYOB, big green groups.  We don't want or need your "help."
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MO PSC Hearing - Part 1

6/18/2023

3 Comments

 
So far I've managed to watch the first two days of the MO PSC evidentiary hearing regarding Grain Belt Express.  I'm now starting on Day 3, with another day following that.  It's something on the order of 30-40 hours of video, so progress has been slow.  However, I realized this morning that I should perhaps break my observations down into two (or more) blogs because I already have a page and a half of notes!

Here's Part 1:

Associated Industries, which apparently consists of a group of large businesses in Missouri, claims that its members want and NEED the Grain Belt Express to purchase power from wind and solar generators in SW Kansas.  It forgets (or just doesn't know) that its members cannot purchase either transmission capacity or energy directly from GBE or generators.  Its members are retail customers of public utilities, they are not public utilities.  Retail customers (whether residential, commercial or industrial) must buy their power from the incumbent public utility that serves their area (think Ameren, Evergy, or a co-op or municipal system).  Only a public utility can purchase from a wholesaler like GBE or Kansas generators.  Then they supply their customers with what they purchase.  The decision on what supply and transmission to buy rests with the incumbent utility, not the retail customer.  The most a corporation can do is purchase "renewable energy credits" (or RECs) directly from generators.  RECs are the "social and environmental attributes" of power generation and can be completely uncoupled from the actual power itself and sold on the secondary market to corporations who want to virtue signal about how they "use" renewable power.  They really just use what their incumbent utility serves them but like to pretend they helped a renewable generator make bank by purchasing completely made up products like RECs.  My conclusion is that Associated Industries is asking for something that can never happen (direct purchase by a corporation from GBE).  If these corporations want cleaner power, they best get busy installing renewable generators at their point of use.  GBE witness Sane insisted that corporations could purchase capacity directly from GBE, but he's flat out wrong according to MO law.  Guess he didn't research that one.

Commissioner Holsman made a comment indicating that he thinks compensation is a benefit to landowners.  Being paid for something that is stolen from you is NOT a benefit.  It's compensation.  There is a huge difference.

Commissioner Kolkmeyer kept going on about connecting GBE to various substations along the way between Ford County, KS and Monroe County, MO.  I'm thinking he doesn't understand the difference between AC and DC electricity.  It was painful watching GBE counsel try to explain it to him as gently as possible.  But it didn't stop the impossible questions!

GBE went on and on and on about its bi-directional capabilities.  However, it tried to avoid the elephant in the room.  The act of actually changing the power flow's direction can only be done if certain agreements are in place (permission to withdraw power and permission to inject power, and permission from customers who own GBE's capacity to use it for something else).  Having the physical hardware to do something is not useful unless the act can actually be done.  Something like this has never been done before and is going to take a lot of study at some point in the future.  Therefore, GBE's touting of bi-directional capabilities means absolutely nothing until all this future work is done.  It's like me saying I could become President, if only a whole bunch of stuff happens to enable it later.  Just being a U.S. Citizen eligible to run for President isn't enough to be taken seriously.

GBE says the agreements to actually enable bi-directional capabilities would have to be made by future customers and is not GBE's responsibility.  Staff confirmed that there are no customers that have requested this capability.

The GBE witnesses with all their "studies" of the benefits of GBE got shredded on the stand, particularly Mark Repsher, who tried really hard to defend his insertion of a fictional "carbon tax" in order to increase supposed GBE benefits.  Repsher doesn't understand the nature of merchant transmission and his "study" demonstrates that.  He kept claiming that "the future is unknown" as a way to deflect criticism, but his study also purports to predict an unknown future.  Way to impeach yourself, dude!

GBE witness denied Invenergy is contemplating building the nation's largest wind farm in SW Kansas, despite this being in the press:
[Polsky] intends to erect more than 1,000 of these enormous machines on 100,000 acres in Kansas, on what could become the nation’s biggest wind farm.
And then they got to GBE witness Rolanda Shine, who said that revenue certainty = an ability to sign contracts.  Being certain there will be revenue will only happen after a contract is signed.  Saying I own the world because I have an ability to own the world does not mean I own the world.  I would only own the world when I actually purchase the world.  How ridiculous!

She admitted that the contract with Realgy for 25MW of service on GBE is not contained in GBE's revenue models.  A later witness confirmed that Realgy was always only an "option" to purchase and not a firm contract.  Except the MO PSC used it as the basis to approve GBE last time.  Guess they got tricked and had better amend their Order.  This is why a whole new application was needed -- a lot of things presumed last time are no longer true.  The PSC has a duty to re-examine everything, not just the parts GBE wants it to change.

Then Rolanda Shine tried to explain GBE's new sale of "undivided interests" in GBE by comparing them to the sale of capacity that was in the last application.  Shine said an undivided interest is a "sale for exclusive use."  In other words, whoever buys an interest in GBE has the exclusive use of that portion of the line.  A transmission line for exclusive use of one or more parties is NOT a public use.  It is a private use.  Public use is required in order to be a public utility with the ability to take property using eminent domain.  If GBE is changing to an exclusive, or private, use for some or all of its capacity, then it should not be permitted to use eminent domain.  See section about about Invenergy's huge Kansas wind farm.  GBE could sell exclusive use of GBE to Invenergy to make it a private highway from Kansas to Missouri that no other utility could use.  That is not a public utility, nor a public use.  Until GBE has customers, it cannot be decided that it is a public utility.  The PSC must go back and re-examine this in light of new evidence.  How much public use must there be on a transmission line that is also for private use?  Let's think of a highway, where 4 lanes are for the exclusive use of special people.  The public only gets to use 1 lane, or maybe just a bike path along the shoulder.  Is that highway still a public use capable of using eminent domain to take property in order to build?  This is a dangerous and slippery slope that is probably best decided by a court.

She also admitted that GBE has applied for a federal loan guarantee from the federal government.  She said that a government bank would hold the loan.  If GBE has a guaranteed loan, then the government ends up paying if GBE defaults.  (Really the taxpayers, governments don't have any money of their own).  But an earlier witness had explained that merchant transmission means that the project's investors accept all financial risk if the project fails.  Therefore, GBE can no longer be a merchant transmission project if it takes a government guaranteed loan because the financial risk would have shifted from the company to the taxpayers.

Finally, Shine said that an "advanced stage merchant project" is one that has all its approvals and contracts in place.  Maybe someone should notify FERC and MISO because that could be really useful in the current complaint docket, where GBE claims to be an "advanced stage" project.

Shine really shined, didn't she?

Aaron White had to be my least favorite witness.  His appearance was off putting, but appearances aren't everything.  He changed GBE's claim that only 9 acres of farmland would be taken out of production and replaced it with about 19 acres.  Total.  11.5 acres for Phase 1 in Missouri, .02 acres for Tiger Connector, and 7 acres for Phase 2 in Missouri.  His calculations were based on the diameter of the tower bases.  As if a farmer could farm right up to the base of any transmission tower.  Obviously the smug Mr. White knows zilch about farming, and it showed.  Perhaps his best moment is after he left the stand and returned to a cluster of his fellow witnesses in the audience, where a big deal was made out of fist bumps and congratulations.  That was completely uncalled for and inappropriate.  Nice show of empathy, Aaron.  You disgust me.

If White was most disgusting, Jonathon Monken was perhaps the most irrelevant witness.  He said the U.S. military needed GBE.  He admitted that the military could (and has in the past) intervened in transmission cases itself, but chose not to do so in this instance.  But never fear, Monken is here to claim he sort of (but not really) represents military interests.  Nothing he said should be in the record. 

Commissioner Holsman had a bunch of questions about battery storage, storms, military and other topics near and dear to his heart but not really relevant to GBE.  Something was totally wrong with the camera directed at him that turned him a Simpsonian shade of yellow.  By the time he was done, the only thing I could think about was Groundskeeper Willie going on a rant.
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GBE witness Jennifer Stelzleni said landowner concerns from the public hearings were discussed at a meeting afterwards and GBE took some action to alleviate them but she couldn't say exactly what that action was.  She said GBE did not follow up with the landowners after they came up with this magical solution. Then she punted to a future witness.  She also said the environmental and cultural studies are not complete and probably won't be complete until next year.  So, why would the PSC approve a speculative project that has not been studied?  That's always been GBE's problem.  It is a speculative venture and approval has always been based on pure speculation and conditioned upon future things happening.  The PSC ought to tell them to go away and come back when it has customers and the rest of its ducks in a row.  I'm not sure there's any law in Missouri that requires the PSC to approve speculative projects.

And now I'm diving back in to the video... more to come.
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PJM's Stupendous Plan To Build New Transmission in WV, MD, VA and PA

6/16/2023

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Perhaps sensing a ripe opportunity, PJM Interconnection has opened a project window to solve multiple thermal overloads in the 4-state area.  PJM says all these overloads are caused by:
  1. Proliferation of data centers in Northern Virginia that have caused increased load.
  2. Generator deactivations - i.e. closing of large baseload fossil fuel electric generators in the DC and Baltimore suburbs.
  3. Need for bulk electricity transfers from places where plants have not closed (i.e. West Virginia, Pennsylvania.)
  4. Offshore wind.
  5. New planning procedures.
A map of the overloads looks like this:
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PJM's new procedures call for competitive transmission proposals.  Instead of awarding a massive project like PATH to its favored incumbent transmission owners in a smoky back room, PJM is now required to post a "problem" window to solicit possible solutions submitted by any company.  PJM publicly posts solutions without identifying who proposed them, then makes a decision on which idea best solves the problem.  Except in this instance, the problem was so large it drew solutions consisting of 72 Proposals from 10 entities, of which 7 are incumbents and 3 are non-incumbents.  16 Projects are upgrades, while 50 are Greenfield.  Greenfield means new transmission (or substations) on new rights-of-way.  There are projects proposed all over the map, from eastern Maryland to northern Virginia to southeastern Pennsylvania to eastern West Virginia.  I'm only going to concentrate on just a few for this blog.

First, here's a PJM map showing existing substations and transmission lines.  You're going to need it to follow along on the written routes.

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Black Oak - Doubs Greenfield 500kV Transmission Line

The project starts at Black Oak and heads east, paralleling the existing Black Oak - Bedington corridor, for ~6 miles. The line continues east for approximately 10 miles but strays away from the existing corridor due to infrastructure build up that has occurred around the corridor in this area. The line then heads southeast where it parallels the existing Hampshire to Ridgeley 138kV corridor for
approximately 16 miles. At this point the rebuild of the existing Hampshire to Stonewall 138kV line begins. The line will be upgraded to 500/138kV double circuit. The route follows this corridor until it meets up with the Stonewall Substation. At this point the route follows the existing Stonewall to Millville 138kV line. This line will be rebuilt to 500/138kV for its entire length. After the Millville substation the route follows the Millville to Doubs 138kV transmission line. This line is rebuilt to 500/138kV until a few spans outside of the Doubs substation. The 500kV circuit diverges from the 138kV centerline and connects into the 500kV Doubs substation. 

Most high-voltage transmission projects will
require a state siting approval. To begin the siting approval process, Proposer plans to hold
pre-application meetings with the regulatory agency to introduce Proposer and the Project, as well as confirm its understanding of the process. Shortly thereafter, Proposer will simultaneously begin collecting siting data and start its outreach efforts so that public siting input is incorporated at the earliest stages of the Project. Once the Proposer identifies a preferred site/route and at least one viable alternative site/route, Proposer will carry out environmental and detailed engineering work in order to establish a highly- detailed Project plan to support the siting applications.

The project will feature a right of way width of 175 feet for the green field portion of the project. The ROW will parallel existing corridor for the first ~31 miles (the greenfield portion). For the rebuild portion, the transmission line should fit in the existing corridor, however the transmission operator may decide to expand the right-of-way.

The proposed line will cross over the Black Oak to Bedington 500kV transmission line., The proposed line will cross over the Black Oak to Junction 138kV transmission line in two locations., The proposed line will cross over the Double Tollgate to Millville 138kV transmission line., The proposed line will cross over the Hampshire to Ridgeley 138kV transmission line in three locations., The proposed line will cross over the Mt Storm to Doubs 500kV transmission line in three locations.

The preliminary design for the single circuit transmission line utilizes tubular steel monopole structures with davit arms and v-string insulators in a delta configuration. The 500kV transmission line will utilize triangular spaced triple-bundle 1272 kcmil "Bittern" ACSS/TW MA3 conductor and two optical groundwires. The preliminary design for the double circuit 500/138kV transmission line utilizes tubular steel monopole structures with davit arms and v-string insulators in a delta configuration for the 500kV circuit and davit arms and I-string insulators in a horizontal configuration for the 138kV circuit. The 500kV transmission line will utilize triangular spaced triple-bundle 1272
kcmil "Bittern" ACSS/TW MA3 conductor and the 138kV transmission line will utilize a single 1272 kcmil "Bittern" ACSS/TW MA3. The structure will contain two optical groundwires.
Check the map.  This project will cross through Jefferson County, WV and rebuild the current 138kV line to double circuit with a 500kV.  It also proposes to snake through the congested area on the mountain that PATH had so much trouble trying to find a right of way through.  It's just too narrow with many houses just outside the right of way.

Here's another... but this one is a lot more convoluted and has many different parts.  First of all, it proposes a new Bartholow substation.  It doesn't give the exact location, but wasn't PATH's ginormous substation located on Bartholows Road?  It's somewhere in the vicinity but they aren't sharing that yet.
45F1 - New Bartholow Substation - 12 terminal

AC Air Insulated Substation (AIS): New proposed 500 - 230 kV Substation. New Breaker and a Half (BAAH) 500 kV switchyard with three (3) bays, six (6) line terminals, twelve (12) 500kV, 5000A, 63kAIC Breakers, two (2) shunt 150 MVAR capacitor banks, one (1) -300 to +500 MVAR Static VAR Compensator (SVC), two (2) 500 - 230 kV transformer banks. New BAAH 230 kV switchyard with three (3) bays, six (6) line terminals, eleven (11) 230 kV, 5000A, 80 kAIC breakers.



Environmental constraints identified are manageable through implementation of an environmental avoidance, minimization, and mitigation strategy incorporated at the beginning of the routing/siting process. Co-location with existing utilities and other infrastructure was prioritized to the greatest extent practicable to minimize the environmental impact on the landscape. The proposed site crosses no national wetland inventory (NWI) wetlands or waterbodies. Fatal flaws have not been identified for proposed site. A cultural resource professional assisted with the siting process to identify and minimize impacts to known areas with historic sensitivities. An investigation to further identify and evaluate historic properties will be conducted to determine the presence of archaeologically or historically significant resources. Federally listed species have been identified with potential to occur in the area including listed bats, but no critical habitat was identified in the area of the substation site. If suitable habitat is identified or regulations change, agency coordination and species-specific surveys will occur. The project intends to adhere to tree removal seasonal restriction windows to avoid and minimize impacts to protected birds and bats, such as the northern long-eared bat, bald eagle, and other common raptors. Erosion control best management practices and setbacks will be engineered and utilized to prevent sedimentation from leaving the site for the protection of aquatic species and to avoid water quality impacts. There are no unique or sensitive environmental concerns or impacts with the proposed substation site that cannot be addressed.



The Company is committed to working with all interested stakeholders through a robust public outreach program to address/respond to community concerns and inform the public about the project to the greatest extent practicable. The Company believes a well-designed public outreach program can have numerous benefits, including fostering a cooperative relationship with landowners and other stakeholders, expediting the regulatory permitting process, and assisting with project development. In general, the purpose of the community outreach plan is to gain community support for the project. In the affected communities, the Company’s public outreach plan will educate the public and relevant stakeholders on specific project details to enable timely regulatory approvals and construction activities. Elements of the public outreach plan will include the following: 1) Identify potential issues at an early stage by engagement with key community stakeholders at the outset; 2) Broaden the community engagement process to identify potential and relevant community benefits that can facilitate community support for the proposed project; 3) Develop a broad base of community support for the proposed project before the regulatory agencies; and 4) Develop a comprehensive administrative record documenting the community outreach process that can be presented to the regulatory agency or, in the event of a legal challenge, to the appropriate court. The outreach plan proposes to dedicate considerable time and resources in engaging the community, and specifically the affected community during the planning process to identify highly sensitive areas that have the least amount of cultural, environmental, and social impacts on the community. The plans will reflect avoidance of impacts rather than mitigation. However, in some cases, if avoidance is not possible, then the Company will involve the community in providing appropriate and practical mitigation measures. The Company will commence its public outreach activities following project award.

Of course, a new substation needs new transmission lines, and there are several proposed:
40AB1 - New two single circuit 230kV transmission lines from new Bartholow substation to new Grisham substation

General route description
The route is approximately 35 miles long. The component is two single circuit 230kV transmission lines to satisfy contingency requirements with utilizing a shared tower, however the towers can be designed in such a way that they are staggered and offset as to utilize the same ROW width as a double circuit 230kV transmission line. This provides the reliability of two single circuits and the permitting and constructability requirements similar to a single double circuit tower installation. Starting at a new dead-end structure at the new Bartholow substation, the route follows the existing Doubs - Brighton 500kV transmission ROW west - southwest for almost 8 miles, expanding the existing ROW. Minor adjustments may be needed for reducing impacts to buildings and residences. The route turns south where Bennet Creek intersects with the existing Doubs - Brighton 500kV transmission ROW and then routes on the eastern side of Sugarloaf Mountain for about 12 miles before then co-locating with the existing Doubs - Goose Creek 500KV transmission ROW. The route follows the existing transmission ROW on the eastern side, expanding the existing ROW, with slight deviation at the Leesburg Water Treatment Plant to avoid impact to operations at the facility. The route shifts underground on the north side of the Potomac River at the Leesburg Water Treatment Plant to reduce viewshed issues with crossing the river and spatial constraints on the south side of the river. The lines remain underground along the Doubs - Goose Creek 500kV ROW corridor until returning to overhead construction around the southeast corner of Crosstrail Blvd and Harry Byrd Hwy. The lines follow the Harry Byrd Hwy until turning south on the east side of Loudoun County Pkwy. The lines shift to the west side of Loudoun County Pkwy near the intersection with the Washington and Old Dominion trail to avoid conflicts with the 1757 Golf Club. The lines then share a common double circuit transmission tower for remaining duration of the route as it is less than 1 mile and is advantageous to utilize a double circuit tower for cost effectiveness.

The Project is located in the valley south of the Potomac River in Loudon County, traversing north through Montgomery and Frederick Counties in Maryland. A former agricultural region, Loudon County is now densely developed with commercial buildings and planned residential communities within commuting distance to Washington, D.C. Some industrial facilities are located to the south of the project area. Slopes are gentle, approximately 4%. The project terminates on the north side of the Potomac River in Frederick, Maryland where the topography is generally rolling. Elevations range from a low of near sea level along the Potomac River to about 875 feet. The river valley’s topography includes little steep terrain, but some steep gradients do exist adjacent to the river. These land elevations and the degree of slope have influenced land use in the watershed. The region’s relatively flat topography has made it easily accessible for development and agriculture in some areas next to the river and its tributaries.
The new right of way will have its own corridor for approximately 60% of the route length. The right of way will be an expansion of an existing transmission line corridor for approximately 35% of the route length. The right of way width will be 60 feet and it will accommodate 2-230kV lines. Approximately 5% of the route will be underground in narrower and congested areas where overhead construction was considered not feasible. Where underground transmission line segments are not sited by permits issued by the Authority Having Jurisdiction, a 40 ft wide right of way would be required for construction.

The proposed structures for each of the two proposed lines will be single circuit 230kV steel monopoles (TVVS-230) in a vertical conductor configuration. Any proposed dead-end structure will be a steel monopole. The portion of the route proposed to be underground will utilize duct bank construction with 3-cables per phase and splicing vaults at regular intervals.

43e - New 230kV transmission line from new Bartholow substation to existing Mt. Airy substation

The route is approximately 5 miles long. Starting a new deadend structure at the new Bartholow substation, the line routes northeast along the northside of the existing Conastone to Brighton 500kV transmission ROW. The line follows the existing ROW for about 4.25 miles before turning north, routing to the Mt Airy substation and then terminating at the substation.

The project is located in the Piedmont Upland portion of Maryland’s Frederick County. The Frederick Valley, through which the Monocacy flows, is nestled between the Catoctin Mountains to the west, and the lower Parrs Ridge to the east. The river valley’s topography includes little steep terrain, but some steep gradients do exist adjacent to the river. These land elevations and the degree of slope have influenced land use in the watershed. This section is underlain by metamorphic, igneous, and sedimentary materials, related to volcanic activity that occurred in Precambrian time. The region is comprised of rolling upland with herringbone texture and underlain with siltstones and quartzites.

The new right of way will be an expansion of an existing transmission line corridor for approximately 90% of the route length. The right of way will have its own corridor for approximately 10% of the route length. For approximately 1 mile, the right of way width will be 45 ft, for approximately 3.3 miles, the right of way will be 60 ft and will accommodate a portion of component 47ad within it. For approximately 0.5 miles the right of way will be 40 ft wide.
The majority, approximately 80% of the proposed structures will be single circuit 230kV steel monopoles (TVVS-230) in a vertical conductor configuration. Approximately 20% of the structures will be double circuit 230kV steel monopoles (TVVS-230DC) in a vertical conductor configuration. Any proposed dead-end structure will be a steel monopole.

47abc - New 500kV transmission line from new Goram substation to new Bartholow substation

The route is approximately 61 miles long. Starting a new dead end structure at the new Bartholow substation, the line routes northeast along the north side of the existing Brighton to Conastone 500kV transmission ROW. The line follows the existing ROW for about 49 miles and then turns north where the Otter Creek to Conastone 230kV transmission ROW coincides with the Conastone to Brighton 500kV transmission ROW. The line then follows along the west side of the Conastone to Otter Creek 230kV transmission ROW until it reaches the new Goram substation where it terminates.

The project is located in Maryland’s Frederick, Carroll and Baltimroe counties east of the Monocacy River. The Frederick Valley, through which the Monocacy flows, is nestled between the Catoctin Mountains to the west, and the lower Parrs Ridge to the east. The river valley’s topography includes little steep terrain, but some steep gradients do exist adjacent to the river. These land elevations and the degree of slope have influenced land use in the watershed. The region’s relatively flat topography has made it easily accessible for development and agriculture in some areas next to the river and its tributaries. The project continues north into the Piedmone Upland area of York County, Pennsylvania, characterized by rolling hills and valleys, generally with gentle to moderately steep slopes. However, steeper slopes with narrow valley bottoms dominate near the Susquehanna River. Many higher ridges are underlain by more resistant bedrock such as quartzite. This Section was formed by fluvial erosion and some peri-glacial wasting and averages about 600-700 feet in elevation. The drainage pattern of the area is considered to be dendritic. Slopes in the range of 0-8% are common throughout York County.

The proposed structures will be single circuit 500kV steel monopoles (TVVS-500) in a vertical delta configuration. Any proposed deadend structure will either be a 3-pole, one phase per pole configuration.

There may be more we haven't found yet.  PJM's plan is to review the submitted proposals and provide more updates at the July TEAC meeting.  PJM is targeting Dec 2023 Board Approval – Oct and Nov TEAC 1st and 2nd reads.  Hopefully PJM will provide a full list at the July meeting, along with its preliminary evaluation and ranking of proposed projects.  None of these ideas have been accepted and ordered by PJM yet, but... get ready... they could be.

It's been really quiet in our area since PATH died but now the push is on nationally to double or triple the amount of transmission built.  For every transmission line you see now, there will be two new ones.  That's a lot of transmission!  And if you haven't been following along for the past decade (the Post-PATH era of peaceful rebuilds and upgrades) there are many new laws and policies that will come into play this time around.  Just to name one... Congress gave FERC the authority to site and permit new transmission located in a National Interest Transmission Corridor (NIETC) in the event that a state denied a permit.   Getting a NIETC is easier than ever now.  The U.S. DOE will be handing them out like candy to any transmission developer that requests one.

Let's hope PJM remembers the black eye we gave the last transmission proposal that attempted to site here and moves on to other pastures.  We've also expanded our opposition team by connecting with other groups that successfully fought proposed transmission lines on the eastern half of the map and don't want to see more.  It's going to be the motherlode of opposition.

For now, keep your fingers crossed... and get reacquainted with your opposition self.  It's coming.

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WAKE UP!!!

6/15/2023

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Alarm bells are ringing for the Missouri Public Service Commissioners who showed their disrespect for the people of Missouri and the awesome power of their office by napping through the Evidentiary Hearings for Grain Belt Express last week.
Apparently the only ones not caught asleep on camera by the audience were the ladies of the Commission.  I might have actually excused the new lady with the tiny baby for accidentally dozing off, but not these three old crows.

This is what the impacted landowners saw when they took time away from their busy schedules to travel to Jefferson City to watch the few who hold so much power over the taking of their private property make a fair and just decision.

I've only watched the first day of the hearings so far and some of the questions I've heard make me wonder if these characters actually know anything at all about energy and transmission.  Commissioner Kolkmeyer asked GBE about connecting its project to other substations between Kansas and Missouri.  GBE's counsel had to condescendingly explain that GBE was direct current and could not connect except at special converter stations that are very expensive to build. 

What?  This is transmission 101.  GBE has been before the Missouri PSC for at least a decade, and Commissioner Kolkmeyer has been a Commissioner since 2021.  Has he not learned the basics yet?

And speaking of learning the basics, I see the brand new Commissioner's first day on the job was sitting on the bench at this hearing.  Somehow she was nominated, confirmed and sworn in in a record 4 days, 2 of which were Saturday and Sunday.  How does that happen?  Why did the Governor appoint someone who has no education or experience in energy or regulation?  Are PSC seats just handed out like party favors to a favored few without any expectation that the appointment is one that serves the interest of the public?  Or was this new Commissioner put there just in time for GBE for a completely different reason?

I've seen a lot of corrupt state regulatory agencies in my years doing this.  Congratulations, Missouri!  You've made my list.

The people of Missouri deserve better than this when their homes and livelihoods are threatened by out-of-state companies seeking to take their properties in order to further corporate profits.  The people of Missouri, at the very least, deserve Commissioners who can stay awake during important hearings.  Impartial ones who understand the testimony and the purpose of regulation are a plus.
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Missouri Fights Back!

6/15/2023

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It's starting to become a common story... bucolic farm community is blindsided to find out that one of their own has sold the rights to their property to a wind or solar developer.  In some stories, it's several someones.  By the time the community at large finds out about it, the damage has been done.

These big out-of-state (and sometimes foreign) development companies swoop in to the community and begin to systematically destroy it with huge wind and solar installations and their necessary high voltage electric transmission lines.

This story is currently playing out in Audrain and Callaway Counties in eastern Missouri.  Known as one of the most productive farming areas in the state, it is proposed to be covered by 12,000 acres of new solar "farms" and a 30,000 acre wind "farm."  It's also home to the new Burns Substation, where all this new generation will connect with the Grain Belt Express Tiger Connector so it can all be shipped for use hundreds of miles away in eastern states.

Grain Belt Express is perhaps the catalyst for this unprecedented destruction, making new electric superhighway opportunities for greedy energy speculators racing to see who can score the most taxpayer subsidies first.

Opposition to this invasion has been forming, and now they have a brand new website that pulls together a whole bunch of useful information for residents.

You can even get a bright yard sign to spread the word, or perhaps a t-shirt that says "No Farms - No Food - No Future."  I've already ordered my own.

Check out the website and be sure to sign up for the email newsletter so you can be the first to know what's happening and what you can do to make it stop.
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What's for dinner?

6/14/2023

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The New York Times is on a biased roll.  It keeps writing ridiculous and uninformed articles and opinions about "permitting reform" and electric transmission.  It refuses to publish any dissenting opinions or responses, such as this thoughtful piece from a New Jersey consumer group.

Instead, the NYT just doubled down with a second article singing the praises of Grain Belt Express.  The article purports that the opposition to the project is merely concerned about it being an "eyesore."

I'd like to give the reporters a few eyesores of their own, such as this blog and going to bed without supper a few times.
Communities have various reasons for blocking these projects. Landowners might worry about the government seizing their land. Power lines, wind turbines and solar panels can be eyesores in places that rely on beautiful vistas for tourism. Such projects can damage the environment by displacing wildlife or cutting down trees.
These poor, little New York City dwellers don't seem to know where their food comes from.  New transmission projects across working farmland remove land from production and pose various impediments to modern farming, preventing the efficient and economic use of land to produce food.  It's more than just an "eyesore", it impacts their business and their income.  And it also impacts the amount of food they can produce to feed arrogant and biased big city reporters.  Who is going to volunteer to go hungry for each acre of productive farmland that is destroyed by industrial wind and solar and new transmission rights of way?  Probably not these reporters, who must think their food is created at the Walmart factory.

These reporters also have many of their "facts" incorrect.  Let's examine a few:
With its open plains and thousands of miles of wheat fields, Kansas is one of the windiest states in the U.S. That makes it a great place for turbines that capture the wind and convert it into electricity. But too few people live there to use all that power.
So in 2010, developers started planning a large power-line project connecting Kansas with Missouri, Illinois and Indiana. They wanted to move the clean energy generated in Kansas, from both wind turbines and solar panels, to states with much bigger populations. That would let more communities replace planet-warming fossil fuels that have contributed to the kinds of wildfires and unhealthy air that have blanketed large swaths of North America this week.

Have they bothered to look at a wind resources map?  There are better wind resources located off both coasts and in the Great Lakes.  Why would they build in Kansas, miles from "people who use all that power" and not in those better resource areas located conveniently near all those power sucks?  They may not even need transmission to do that.  But they don't want to because they don't want that infrastructure in their own back yard.

No community can replace fossil-fuel baseload generation with intermittent wind and solar from thousands of miles away if they want the lights to go on when they flip a switch.  Renewables cannot follow load.  Load follows renewables.  The communities would still need a power source that could produce when it is needed.  There is absolutely no evidence that fossil fuels caused Canadian wildfires, or any others.  On the west coast, electric transmission lines actually cause wildfires.  The "unhealthy air" actually reduced solar production by an incredible 50%.  It's a circular argument.  Which came first?  The chicken or the egg?
Thirteen years later, however, full construction has not yet started on the project, known as the Grain Belt Express. Why? Because in addition to federal permission, the project needs approval from every local and state jurisdiction it passes through. And at different times since 2010, at least one agency has resisted it.
Full construction has not yet started because Grain Belt Express changed ownership, and then changed its project, including the route, requiring new state permits.  It also had to change the law in Illinois to grant itself public utility status and eminent domain in the counties it intends to cross.  The only "federal" permission the project needed was a conditional order to negotiate rates with potential customers.  That was granted in 2014.  The problem is, there have been no customers, aside from a small coalition of Missouri municipalities who signed a contract to purchase "up to" 200 MW of the project's 5000 MW capacity.  That's less than 5%.  The federal permission to negotiate rates also required former owner, Clean Line Energy Partners, to hold an "Open Season" to advertise its project's capacity to potential buyers.  Clean Line then had the ability to negotiate with those buyers and make a compliance filing demonstrating that it fairly negotiated with buyers who responded to its Open Season.  Clean Line held an Open Season in 2015, but no buyers were ever announced and no compliance filing was made.  New owner Invenergy says it is negotiating with potential buyers, but it has yet to hold a proper Open Season.  It also failed to notify the Federal Energy Regulatory Commission of the change of ownership and the change of project capacity, as required by the 2014 Order.  Seems to me that all delays were of GBE's own creation.
One way to get at that problem is to do what experts call permitting reform. The issue has recently gained national traction, and President Biden and Speaker Kevin McCarthy, the House Republican leader, discussed it during debt-limit negotiations last month. Local and state governments are considering changes, too.
The goal is to streamline the approval process for energy projects so they can avoid the fate of the Grain Belt Express. As long as such projects languish, Americans will keep using existing coal, oil and gas infrastructure for their energy needs.

Federalizing transmission permitting is not going to solve the delays detailed above.  And it will not make GBE find the customers it needs to make its project economically viable.  Recently, GBE has applied with the federal Department of Energy for a loan guarantee to construct its project.  Permitting reform will not make the DOE grant the loan.  Only sheer ignorance would make the DOE grant a loan guarantee to a project with few customers and little revenue with which to pay back the loan.
The case for a permitting overhaul is that the current system has gone too far. Existing policies have helped protect the environment, landowners and tourism. But they have also become a burden that slows projects far longer than is necessary to ensure safeguards. Reform, then, would be about finding a better balance.
And though changes could allow more fossil fuel projects, they would probably enable far more clean energy projects, experts say. With public attention to climate change, technological breakthroughs and hundreds of billions of dollars in federal spending, clean energy is expected to become cheaper and more competitive than fossil fuels. So developers will be much more likely to build a clean energy project than a fossil fuel one — if they can get the permits.

So now we need to destroy the planet to "save" it?  I'm thinking it's more about certain special interests filling their pockets than saving the environment.

One astute citizen proposed that for every megawatt of renewable energy or transmission constructed in rural communities, the transmission lovers construct an equal amount of transmission and generation in their own backyard.  I'm a little more jaded though... I want to make them feel the impacts of the destruction of the productive farmland that feeds them.  No dinner for you tonight!  You saved the planet today instead!

Grain Belt Express is a lot more than an "eyesore" to the thousands of rural landowners who are facing the taking of their property to construct an overhead transmission line across their productive land.  These landowners participated in and watched with great interest last week when the Missouri PSC held hearings on GBE's new project.  These farmers should have been working their land last week, not watching a hearing.  I'm still trying to catch up on watching the hearings and will probably have a lot more to say about them when I finish.

The New York Times reporters should go to bed without supper a few evenings, just to see what their brave new world is going to be like.
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More Changes to Grain Belt Express?

6/4/2023

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This just in... a citizen detective in Missouri has uncovered Invenergy's plans to build "the nation’s largest installation of wind turbines" in Kansas.
The company also has planned a Kansas wind farm that would be the nation’s largest installation of wind turbines. The project would see 1,000 wind turbines installed across 100,000 acres of Kansas farmland.
Let's see... the nation's largest wind farm seems to be located in the same state where the nation's largest transmission line begins.

Is Grain Belt Express really a "public use" transmission line, or will it be repurposed to serve as Invenergy's private use generation tie line to transmit energy from Invenergy's largest wind turbine installation to an interconnection point with the public grid in Missouri?  That would be what's known as a "generation tie line", or in industry parlance "ICIF"  (Interconnection customer's interconnection facilities).  An ICIF doesn't need to offer its transmission capacity to other companies.  It can keep it all for its own use.  Of course, such a facility is not a "public use" so it cannot, under law, use eminent domain to acquire property.

Is there a reason GBE has not sold any more capacity other than the "up to 200 MW" to Missouri municipalities that greased its first permit from the PSC?  Is GBE saving its capacity for Invenergy's largest wind installation?  Are there more changes coming to GBE after it gets approval and acquires all the land it needs to build GBE?
1 Comment

Are You Ready To Rumble, Missouri?

6/4/2023

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The Missouri Public Service Commission's evidentiary hearing for the Grain Belt Express Tiger Connector (and other big changes to GBE's permit) begins at 9 a.m. Monday morning.  You can either show up at the PSC in person, or watch the festivities online.  If you show up in person, be aware that this is a formal court-like proceeding.  The audience must use their court room manners (no shouting, clapping, or disruptions of any kind.)  Also, there is no opportunity for the audience to participate, they are silent observers.  Have all the stare down contests you like, but keep your lips zipped.  If you watch online, like I do (either live or on replay), it's a lot less stressful because you can shout the most appropriate insults at the biggest idiots you encounter with absolutely no harm done.  If I was more industrious, I'd make a video out of it, similar to those folks who draw huge audiences making videos while they play video games.  Who wants to watch a video of me ad libbing insulting tunes at PSC witnesses?  Insults are so much nicer when you sing them.

All the parties have filed their position statements.  It's a short listing of what the party believes the evidence will show to the Commission, and how the party believes the Commission should decide.  Rather than plow through the mountains of filings at this point, this is where you should start.

Missouri Landowners Alliance says the project should be rejected because it is not economically feasible and there is no proven need for it.  GBE has not even sold the full 500 MW it first offered in Missouri, so why would it need to increase the capacity to 2500 MW?  In its Order approving the project several years ago, the PSC said GBE was economically feasible only because it could sell capacity at a higher price to utilities on the east coast.   Now GBE wants permission to build just the Kansas and Missouri portions of the project, with the portion that goes to the east coast coming later, maybe.  Also, GBE has filed a complaint against regional grid operator MISO at the Federal Energy Regulatory Commission contending that MISO did not include a completed GBE in its future planning scenario, even though the rules say MISO should not.  To summarize this problem, GBE is mad that MISO's future transmission plan competes with GBE, therefore GBE seeks to stop MISO from planning and ordering other transmission lines.  Being made obsolete is a natural development for a merchant transmission line that stalls for more than 10 years.  MISO cannot depend on GBE being built because GBE can always cancel its project at its own initiative, even today.  MISO needs to plan a reliable transmission system.  It cannot plan around speculative projects.  MISO is going to build its new projects anyhow, and all ratepayers will be responsible for the cost of those reliability projects.  It's undeniable that GBE has jumped the shark -- other options have become available, and they are not carrying GBE's huge debt baggage that has accumulated over the last decade so they are certainly going to be cheaper.  As the MLA said, "If Grain Belt is attempting to eliminate competition from MISO, there is reason to question Grain Belt’s financial viability."  The MLA is opposing the separation of GBE into two "phases", where it builds the Kansas-Missouri section independently from the Illinois section.  The MLA says, "Several Grain Belt witnesses contend that its proposed phasing plan would expedite the benefits of Phase 1 for Missouri.  Yet not one of their witnesses mention that the plan would also expedite the collection of Grain Belt’s profits."  BINGO!  MLA opposes changes to the landowner compensation for the Tiger Connector.  GBE wants to change 110% fair market value (FMV) plus a big payment for each structure on your land to 150% FMV without structure payments.  This simply does not work out to higher compensation for every landowner, as GBE contends.  It depends on the value of your property and the number of structures.  It could mean a decrease for certain large landowners.  MLA says landowners should be given their choice of which compensation package is more beneficial to them.

The Missouri Agricultural Associations have a different take on things.  Maybe they're still trying to make up for that disasterous eminent domain legislation they negotiated on behalf of landowners last year.  That whole thing reminded me of former Gov. Jay Nixon "negotiating" a landowner protocol with GBE on behalf of landowners that he never actually consulted.  Personally, I have had enough of unaffected groups negotiating on behalf of disenfranchised landowners.  At any rate, the Ag groups say not only should the original permit not have been issued, it should not be amended now.  "Relocation from Ralls County
and/or constructing the project in two phases will not change the fact that this project will only be viable by selling power at a price that no one is willing to pay."  The Ag groups say GBE should comply with the legislation it negotiated with GBE, and it wants to give away something else on behalf of landowners now.  I haven't even heard a landowner mention this, and nobody seems to know about it.  Came right out of left field, like most of the giveaways in last year's legislation.  "The Agricultural Associations would also support modifications that require Grain Belt Express to offer landowners ongoing shares of ownership in Grain Belt Expressand/or Invenergy as an alternative to cash compensation to give landowners an opportunity to share in the profit stream generated from land taken by Grain Belt Express."  WHAT???  INSTEAD OF cash compensation?  Sorry... no.  It should be IN ADDITION TO cash compensation.  Why would any landowner give his property away for a share in a company that he hates?  This is what happens when you don't consult the people you supposedly "represent."

The Staff of the PSC is another party with a position.  Although the Staff is part of the Commission, it is the professional part.  It is the engineering and legal staff that evaluate applications that are filed and make recommendations for the appointed Commissioners.  The Staff are the people with actual education and experience regulating utilities.  The appointed Commissioners often don't have any experience at all with utilities and often are nothing more than political creatures rewarded with a cushy job and high salary.  It's not what you know, it's who you know.  Commissioners are not obligated to listen to the wisdom of their professional staff, who try diligently to keep the Commissioners from making huge mistakes.  But the call of politics often overwhelms common sense and the Staff is batted aside as an inconvenience.  What a thankless job they have!  The Staff's main position is that the phasing of the project should be denied.  It's either the whole project from Kansas to Indiana, or no project at all.  Staff also wants GBE to either follow the Eminent Domain legislation negotiated by the Ag Associations last year, or not.  GBE cannot pick and choose whether to follow it or not based on what's beneficial to GBE.

Grain Belt Express wants everything... it wants Tiger Connector approved so it can take land from new landowners in Audrain and Callaway Counties.  It wants to build only part of the project before committing fully to the whole thing.  It wants to pick and choose how it treats landowners to be most beneficial to GBE.

The Missouri Energy Commission (formerly MJMEUC, and not to be confused with the Public Service Commission) believes GBE's permit modifications should be approved.  It mentions that in it's sweet deal for "up to" 200 MW of transmission service on GBE and a separate contract with a wind farm in Kansas for actual energy, that it has managed to re-sell 136 MW of service to Missouri cities.  It forgets to mention that that 136 MW number has not changed since 2015/16.  Even though MEC can resell another 64 MW of GBE service, there have been no takers in 6-8 years.  I'm pretty sure there are no other takers.  Contemplate, PSC, contemplate.

The position of the "Clean Grid Alliance" (formerly American Wind Energy Association but then they got chummy with big solar so they created a big alliance for all their big subsidies) sort of gives away the secret we've been wondering about for a while.  CGA says Tiger should be approved because, "The r
equested amendments and potential for more solar resources using the project provide more benefits to Missouri; increasing the Certificated Project’s public interest benefits."  Wait... more solar using the project because of Tiger Connector?  I don't remember that being anywhere in GBE's testimony.  So, Tiger Connector is being built for the express purpose of exporting new solar generation from Callaway County to the east coast?  Tiger is not for the purpose of importing energy from Kansas?  Or Tiger is for importing renewable energy from Kansas while simultaneously exporting renewable energy generated right there in Callaway?  Wouldn't it be a lot cheaper for Callaway (and Missouri as a whole) to actually use what they produce, instead of paying a bunch of transmission fees to supposedly move the energy around?  Isn't that what is actually going to happen?  If GBE injects 2500 MW of electricity in Callaway and withdraws 2500 MW of electricity in Callaway, who's to say any energy actually went anywhere?  Plenty of dollar bills will go in Invenergy's pocket, but the electricity is a complete wash.  Electrons are all the same.  You can't tell one from another.  There aren't any tiny license plates that say "Kansas" or "Missouri" on the back of them.  P.T. Barnum would be so proud!

Sierra Club's and Renew Missouri's positions are nothing more than boring cheerleading and unsubstantiated claims that GBE is the second coming of their clean energy god.  What is annoying though is where they may take a position that GBE's landowner compensation is reasonable.  Stay in your lane, bloviating turbine huggers.  Your opinion about landowner compensation means absolutely NOTHING.

Same could be said for Associated Industries of Missouri (aka the unions).  The unions took the same position on each separate issue. "The
evidence supports each of the amendments to the CCN currently held by Grain Belt Express and such amendments are in the best interest of the public and necessary and convenient for the public service. The Commission should approve the amendments."  What do the unions know about any of this?  Nothing.  They just support the project because they think it will provide jobs for their members.  But, is that speculation or actuality?  I don't remember a project labor agreement being announced.  What guarantee is there that Missouri union members would be given jobs building GBE?  And, even if they were, is a temporary job for a union member a good reason to take private property from another citizen?   The unions even attempt the same position on GBE's landowner compensation package.  Again... stay in your lane, union workers!

So, what happens now?  A judge will preside over a court-like proceeding where opening statements will be made, witnesses will be cross examined, evidence will be introduced, and briefs will be written.  The judge will make a recommendation to the appointed Commissioners.

Then the Commissioners do whatever they want and pay back their own political favors.  Although supposedly "independent" after being sworn in, they still owe a debt to the one who appointed them and who may reappoint them after their term is up.

You might be interested to find out just how hard Invenergy is lobbying for transmission at the federal level.  It had a hand in both the "Bipartisan Infrastructure Bill" and the "Inflation Reduction Act" that have usurped state authority to permit transmission and supercharged federal authority over transmission.  There's probably a Missouri Elections Commission counterpart that shows how much Invenergy has been spreading around to Missouri politicians.  All that money will be working hard for Invenergy next week in Missouri.  Another lesson in sausage making!

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American Genius:  Combining highways and electric transmission

5/26/2023

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Picture
Missouri is proceeding with a study of upgrading its Highway 36 into Interstate 72 in conjunction with the widening of Interstate 70, which runs through Kansas, Missouri and Illinois.

The study is going to cost Missouri taxpayers $2.5M.  Upgrading the highways is going to cost them even more.  What if there was a way to pay for these road improvements that didn't involve taxpayer funding?

Such an opportunity has existed for over a decade now, but Missouri lawmakers refuse to consider what's right in front of them.  What if Grain Belt Express was required to site its project buried on the edges of the new road right-of-way, instead of building it overhead on new rights-of-way across private property?  Instead of paying landowners millions of dollars in compensation payments for ruining their land, what if GBE simply paid the state those millions to use its road right-of-way?  The road improvements could get done faster and cheaper, and GBE would not have to struggle to acquire land from citizens against their will.  GBE would only have to negotiate with one landowner, the highway administration.

It's pure genius... a fitting use for Highway 36, which has been dubbed, "The Way of American Genius."  It practically writes its own press release.  You're welcome.

But, but, but, you say, there's a million reasons why GBE cannot exist with highways.  But, really there isn't.  All those old excuses have been dispelled by up-to-date research, science, and implementation.

READ the information provided on The Ray's website.  This non-profit organization has a mission to build "a movement to build net-zero highways."  It makes ever so much more sense to combine new highways with new transmission with new technology to create a useful system that not only doesn't cause new burdens on private landowners, but delivers so many benefits that we will find useful in the future.

The article about Highway 36 says,
Riggs said he hopes MoDOT’s study looks at ways to make the future interstate “agriculturally friendly” to farmers can co-exist with freight traffic. In addition, he wants the upgrades to include electric vehicle charging stations.
What if those charging stations could be built along the highway using the DC power carried by GBE?  I know, brain explosion, right?  Maybe you want to let Rep. Louis Riggs, a Hannibal Republican, know about The Ray's work so he can use that information to make sure the new Highway 36 builds for the future, instead of the past.  You can contact him here. 

There's nothing stopping Grain Belt Express from changing its plan to route its project buried along a new Highway 36, except that they don't want to.  GBE has poured tons of money into its last century plan to build a DC transmission line overhead across over 200 miles of private property in Missouri in parallel to the existing Highway 36, even though better ideas were right there all along!  Any extra cost for the company is entirely GBE's fault because it chose to pursue an outdated project model when new research and discoveries pointed to better solutions.

We need to tell everyone about the possibilities of modern highways and modern transmission working together to propel us into a bright future!
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    About the Author

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

    About
    StopPATH Blog

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

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