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Buried Transmission Gets Real

3/11/2019

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We've been watching an idea for new HVDC transmission completely buried along existing rail and apparently so have some investors.  SOO Green Renewable Rail has new financial backing from Siemens, Copenhagen Infrastructure Partners, and Jingoli Power, the project's developer announced today.  The project can now begin efforts to get the project permitted, and attract commercial interest.  It's getting real, folks!

Why am I so excited about this?  Because it's a better idea whose time is finally at hand!  What's better?  How about no eminent domain?  With the transmission lines buried in a two foot wide trench along existing rail, and work performed from the rail, this kind of transmission doesn't become a burden on landowners.

Developers liken their new transmission idea to our fiber optic system.  I haven't heard about any fiber optic builders plowing through private property and stringing an overhead hazard that farmers have to work around in perpetuity, have you?  Of course not!  They bury that stuff along existing rights of way and don't bother anyone.  It's about time we jettison old transmission ideas in favor of new technology and new solutions that avoids the power struggle between transmission developers and landowners that routinely delays and cancels so many old transmission ideas.

Buried transmission is also a better idea from a safety and reliability perspective.

“The fact is that going underground, you don’t have wires rubbing up against trees. You are not going to have tornado impacts. It is safer and more resilient,” said Joe DeVito, president of Direct Current Development Co., which has developed the project.
You're probably not going to burn the state down, either.

We've simply got to jettison the idea that landowners must sacrifice in order to build new transmission.  SOO Green proves that they don't have to!

So, what's in store for the project next?  It needs permits from the United States Army Corps of Engineers (USACE), the United States Fish and Wildlife Service (USFWS), the United States Environmental Protection Agency (EPA), the Illinois Department of Natural Resources, the Iowa Utilities Board, the Iowa Department of Natural Resources, and various local jurisdictions.  But it doesn't plan to seek eminent domain authority, and without landowner resistance, who's going to object and slow things down?

It also needs customers.  Will investor owned utilities show interest in a transmission project that's more of a sure thing, not bogged down in contentious permitting marathons?  Or do the big utilities still want to own everything themselves?  Will a new kind of customer show up to use a new kind of transmission project?  Let's hope so, because building this transmission project raises the bar for future projects.

Why should a state sell out and permit an overhead transmission route that uses eminent domain when it can get all the benefits without having its landscape littered with linear infrastructure?  The smart states might even increase their revenue by leasing space along existing highways for new buried transmission.  What state couldn't use a new source of revenue for its road system?  States could stop being cheap dates and accepting old technology, and perhaps set their sights a little higher in the future.

Imagine, a future where high voltage transmission is buried, along with all the other linear infrastructure that transports commodities long distances.
“The successful deployment of this HVDC technology along railroads will create a market segment that doesn’t exist today, and DC DevCo believes that the SOO Green project will set the standard regarding how transmission lines are developed and constructed in the U.S.,” states Trey Ward, DC DevCo’s CEO.
Good luck, SOO Green Renewable Rail!  We'll be following this story...
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Ut-Oh, Dominion!

3/6/2019

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What happens when a utility manages to buy approval to build a highly controversial aerial transmission project that could have been buried to avoid the biggest controversy?

It blows up in their face, that's what.  And it could end up costing ratepayers millions in increased electric fees.

Dominion spent years trying to permit its Surry-Skiffes Creek transmission line project on 300-foot towers across the James River at Jamestown, Virginia.  It agreed to pay out millions in "mitigation" in order to appease opposition (of course, the mitigation will be paid by ratepayers, not Dominion), and it finally got approval.  But not all opposition was bought out and the National Parks Conservation Association continued its legal battle against the project while Dominion was busy constructing its monstrosity across the river.

Dominion turned on the power last Thursday.

On Friday, a federal appellate court ordered Dominion's permit to build the project void and returned the case back to a lower court.

Read about it here.

What's about to happen next is anyone's guess.  The court could order Dominion to turn off and dismantle the project.  Perhaps it will order changes to the project.  Either way, the cost of winning a legal permit will fall onto ratepayers.

This is absolutely absurd.  And expensive.  It probably would have been more cost effective to bury the project across the river in the first instance.

Who's to blame here?  Dominion.  And grid planner PJM Interconnection, who "ordered" the project in the first place.  But who will end up paying for their mistake?  Electric customers.

PJM, you've got to go.  You're costing electric ratepayers too much money!
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How Much Could PJM's Gaming of the System Cost You?

3/6/2019

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If you live in Pennsylvania, it could cost you $514M in increased electric bills.  If you're a JCP&L customer in New Jersey, it could cost you $102.6M.  If you're a PSEG customer, you could pay $156.3M more.  Most customer zones in PJM will pay more for their electricity if Pennsylvania and Maryland regulators approve the Transource Independence Energy Connection.  The majority of customers who would see their rates decrease from this project are located in BGE (Baltimore), Dominion (Northern Virginia) and PEPCO (Washington, DC).  The net change to region wide electric rates amounts to just $12M.  And to realize $12M net savings, PJM has ordered a transmission project that will cost more than $500M to build.  Are they nuts?  Or are they nothing more than electric Robin Hoods, robbing the poor, politically disenfranchised power zones to benefit the rich, politically connected ones?  Either way, something stinks!

Stop Transource member, land and business owner, and party to the state cases Barron Shaw tells us where that smell is coming from in a new editorial.

Everyone probably already knows Transource would cause increased rates in Pennsylvania (and if they don't, it's up to you to share your knowledge with your friends and family).  What's new is Barron's revelation about how Transource parent company American Electric Power and PJM Interconnection have gamed the Federal Energy Regulatory Commission into allowing a skewed evaluation process for new market efficiency projects, and how Transource gamed the system it had set up to make its project appear "beneficial" by essentially stuffing 10 pounds of electricity into a 5 pound bag.
So how can PJM propose a project that doesn’t really save any money, hurts Pennsylvania ratepayers so badly, and costs nearly $500 million to build? 
 
The answer can be found at the Federal Energy Regulatory Commission (“FERC”), the entity charged with regulating PJM.  FERC allowed PJM to implement a tiered system, with one set of rules for smaller projects, and one for larger projects.  Delineated by voltage, the lower tier rules allow PJM to completely ignore all zones that see increases, while the higher tier rules consider the net change to system production cost.  Transource realized that this created a loophole.  They designed the IEC to run at the highest voltage possible in the lower tier, but carry an astonishing 24 conductors.  Though run at only 230kv, the IEC has so many conductors it would have more power capacity than most 500kv lines that form the backbone of the grid.  One expert witness said it carried more power than any 230kV line he had ever seen.  Testimony showed that if the line were evaluated as a higher tier project, it probably would never have been proposed.

And if that isn’t gaming the system, then consider this: when PJM asked FERC to make the changes in the assumptions for future planned generation – the changes that affected the benefits last week – they didn’t provide much analysis.  In fact, they only gave FERC one table of examples.  Those examples showed what would happen to eight small projects with and without the proposed changes.  In all eight examples, the new rules reduced and usually eliminated the need for those projects by showing the projects no benefit.  PJM clearly was trying to tell FERC that they had historically been over-estimating the benefits of projects, and that the proposed rules would more accurately reflect lower benefits and result in fewer unnecessary projects.  But just days after the rules were changed, the IEC showed a $250M swing the other direction.  Bait and switch anyone?  You can almost hear the laughter in the PJM hallways.

PJM is a cabal of utilities interested in one objective: making money.  They have manipulated the rules to allow the proposal of a project that will lose hundreds of millions of dollars, destroy preserved farmland, and raise rates for Pennsylvania residents, all while ignoring existing alternatives.  If nothing else, this process has convinced any objective onlooker that PJM needs tighter regulation.  FERC has been too trusting, and the effects are clear.
That's right, with the help of AEP, PJM created a two-tiered evaluation system based on voltage that allowed the lower voltage projects in the bottom tier to take no notice of increased electric costs in parts of the region that wouldn't see benefit from the project.  And once that system was set in place, AEP designed (and PJM selected) a bottom tier "lower voltage" transmission project that actually moves more power than those in the upper tier that would have to balance cost decreases in beneficiary zones against increases elsewhere in the region.  Because a higher voltage project normally used to move this amount of power would not pass a cost/benefit test, Transource created a monster of a lower voltage project in order to pass the test.  One has to wonder whose interests PJM has in mind when it approves adding additional conductors (wires) to a lower voltage project in order to make it move as much power as a higher voltage alternative using less conductors.  Which configuration is actually more efficient?  Better designed?  Able to be upgraded without building new lines?  As non-engineers, we can't really say, however we can depend on the knowledge of power engineers who don't build this kind of project.  Transource IEC is truly one of a kind, from an engineering standpoint.    And this leads me to believe it's probably not the best idea.  What were you thinking, PJM?  Aren't you supposed to have the best engineering staff in our region in order to keep the lights on?  This isn't a great example.  In fact, it looks like PJM is part of some kind of conspiracy, like a cartel, or a cabal, or both.

Read Barron's entire editorial.  He makes it easy to understand PJM's outrageous manipulation and abuse of its authority to enrich its biggest members.  PJM needs to go!
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Signals of Subterfuge?

3/1/2019

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Missouri regulators signal readiness to OK Grain Belt Express transmission project

Does that look anything like this?
"Signal" is today's popular, but sadly overused and misused, journalistic punt.  It drives me nuts to see all this "signaling" going on, and any journalist who thinks they are clever or original by using it is actually just a lazy imitator.  Please remove this idiotic word from your stories. 

Now that I'm over the headline, what "news" does this story give us?  Couple of things, well beyond what a thinking public might surmise about possible conspiracy within the Missouri government.

First, there's this:
Invenergy has told the Missouri PSC that it plans to begin construction in 2020 and complete the project in four years.
That's right, it did.  It also told the PSC at hearing that it would begin eminent domain proceedings against 700 landowners immediately after receiving any permit from the PSC.  The witnesses' reasoning was that it must quickly begin surveying and core drilling to finish engineering of the line and landowners would not willingly give permission for that work.  Company mouthpiece Hans Detweiler told the PSC that the only remedy for uncooperative landowners was to take the right of way using eminent domain so it wouldn't need permission to enter for testing.

Hans, you dope!   Maybe you actually believe that (in which case you're demonstrating how very little you know about actually building transmission), but real transmission companies never do that.  Under most state laws, an entity with eminent domain authority has the right to enter property to perform testing prior to initiating a take.  AEP has been using this bully tactic recently, filing for court orders preventing landowners from interfering with entry and testing.  Except the landowners were not interfering in the first place.  The landowners simply refused to grant permission voluntarily and sign company release forms.  A court cannot force a landowner to sign a permission form.  It can only order the landowner not to interfere (something they were not doing in the first place).  The transmission company may risk getting on the wrong side of a local judge, but they'd probably get worse by pretending a take was necessary to perform simple surveys.

Does Invenergy have money to burn?  Why would it be spending bundles acquiring property and testing it to microsite a route when it doesn't have permits in all four states?  Until all permitting and siting is completed at the regulatory level, Invenergy would only be guessing and hoping the money it spent in Missouri would allow a route that would be contiguous with unapproved routes in other states.  And even within Missouri, Invenergy does not have a converter station site.  The option it had in Ralls County has expired and the landowner did not renew it.  As well, Invenergy does not have an approved interconnection in Missouri where it can tie into the existing transmission system operated by the Midcontinent Independent System Operator.  In fact, Invenergy isn't even in MISO's queue for study of a proposed interconnection.  Therefore, any final routing through Missouri would simply be a very expensive guess at this point... unless Invenergy doesn't plan to connect in Missouri at all and simply pay off MJMEUC and deliver nothing at all.

Is the Missouri Public Service Commission this gullible?  After nine years of Clean Line baloney before the Commission, are we supposed to believe they don't smell anything at all suspicious?  I don't believe it.  Not for a second.  I wonder what the MO PSC, elected officials, and government agencies know that they're not saying?

There's simply no way GBE will begin construction next year.  No way at all.

GBE does not have a permit in Kansas.  GBE does not have a permit in Illinois (and even if it applied today, it would be years and years before any decision would be made).  Essentially, GBE has done nothing to support a connection to PJM, and nothing to support a connection to MISO in Missouri.  GBE is an empty extension cord that doesn't connect to anything.  Who spends money building that?

And then there's this:
A company spokeswoman didn’t respond to an email seeking comment.
Right.  A company ready to begin construction on a transmission project it's been trying to permit for years receives "signals" that approval is imminent, and it has no comment.  Invenergy has failed to say much of anything in the media lately, and has refused to share any future plans.  Is it because Invenergy's REAL plan may signal something that Missouri can't permit?  There's more here than meets the eye and the only signals being emitted are a bunch of obscuring smoke.

No matter.  There's still this:
In the meantime, a landowner group says it’s not giving up its fight to block the transmission line.

“We remain committed to defending property rights,” said Jennifer Gatrel, a spokeswoman for Block Grain Belt Express.

Gatrel said there’s strong local government opposition to the project along the planned route and she believes many of the eight county commissions will refuse to sign off on needed assents allowing construction.

So, what do all these "signals" indicate?  Nothing new.  Grain Belt Express is still impossible.  Landowners are not backing down and won't be intimidated by new owner Invenergy.

This isn't over yet.  Carry on.
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Follow The Money:  $258M Smells Like A Backroom Deal

2/28/2019

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Okay, now I've officially seen everything.  A foreign, investor owned utility is complaining about "a pretty nasty ad" that exposes its backroom deal with Maine's Governor to sell the state's pristine wilderness for $258M in payola.
CMP has drawn attention to the ad this week, calling it part of a well-funded, dark-money campaign against the project.
Dark money?  An investor owned utility is pointing at a low budget internet ad campaign and calling it dark money?  Investor owned utilities are the kings of dark money!  They dole out millions in political contributions each year with the hope of influencing laws and policy in states where they do business.  They spend buckets of money hiring the top public relations spinners to lie to their customers with smiles on their faces.  They create front groups and fake "coalitions" to advocate for their money-making transmission project ideas.  And, as CMP has so aptly demonstrated in the past week, they create monetary compensation packages to be traded for political support.  Fact:  Maine Governor Janet Mills has publicly supported the New England Clean Energy Connect project because the state and some private interests have been promised $258M in payouts over the next 40 years.

So, "wahhhhh, wahhhhh" CMP, let me call you a wahhhmbulance.  You're such a lily white, downtrodden, paragon of virtue being attacked for your extra large heart and spirit of charity by some big, powerful, "dark" interests who spent a whopping sum on attack ads, reported to be somewhere between $500-$999.  That's dollars.  Five-hundred dollars.

$500 vs. $258,000,000.  Yup, CMP, you poor, poor victim.

And, oh my gosh!  The ad has had 100,000 to 200,000 impressions, the number of times a post is displayed.  Why, I'm offended.  Soooo offended that this ad
has been viewed over 116,000 times on YouTube!  If I was a total geek who had no real evidence of anything but wanted to spin an opinion piece to make it look like CMP is a poor, poor victim of "dark money" interests, I'd dig up stuff like...  As of Wednesday, the highest number of impressions, 12 percent, has come from men, ages 25-34. The next-highest, 11 percent, from women ages 55-64.  Because this would matter greatly in making my point.  Or covering up the fact that I really had no point.

I mean, don't watch this ad

because it increases the impressions and amount of "dark" money spent by Satan and his anonymous henchmen attacking the purity of Janet Mills.  Just look at her, even her jacket is white as snow!

We definitely have to stop the internet spread of this ad
because CMP says it's "dark money" and anonymous.

Even though it is clearly marked as paid for by Stop the Corridor, CMP and Janet Mills need to know where this coalition got its $500 to run the ad.
Maybe we can arrange a double reveal?  Stop the Corridor can show how it raised $500 and CMP can reveal how it raised $258M?  Maybe throw in a little spreadsheet of all CMP's political contributions, lobbying, and memberships for the past year or so?  Probably the public (and CMP's customers) would rather see that than some bake sale records and copies of personal checks for small amounts.  CMP may be surprised how easily citizen opposition groups can raise $500 - $999 to run ads like this:
Please don't do anything that increases the online impressions of this ad.
Central Maine Power doesn't want you to.
Stop it!
Stop it right now!
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Big Transmission is Still Dead

2/27/2019

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Since that article, Clean Line Energy (remember them?) has sold off a couple pieces and seems to be otherwise winding down. Hopefully someone will write that history.
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Is it an adjective, or a noun?  The history of Clean Line Energy Partners being history has already been written.  It's been written by thousands of Midwestern landowners who objected to having their homes and businesses bisected by a new transmission corridor.  It's been written by state utility commissions in eight states.  It's been written by courts in multiple states.  It's been written by state legislatures passing laws to thwart it. 

It's also been written on this blog.

Anyone who needs to "remember" Clean Line Energy Partners now probably never needed or wanted them in the first place.  What happens if a company "winds up" and nobody misses them?  Was it all just a colossal waste of $200M?

Yes.  Big Transmission is still a colossal waste of time and money.  Big Transmission is still dead.

Steve Huntoon revisits some of his earlier prognostications in this article in RTO Insider.  Huntoon debunks NREL's pseudo-study promoting the building of a "national grid" (a utility fantasy born in the early 2000's), concluding that such a concoction would cost ratepayers more than $50B.  Is that in today's dollars?  Including return, O&M, and taxes?  Or is that one of those stunningly misleading "total cost of building the line" lowball figures that has no correlation to how much money ratepayers actually pay?

At any rate, Big Transmission's song remains the same.  Big Transmission is still dead.
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Transource Shoots Itself In The Foot At Hearing

2/24/2019

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Maybe it was just the thrill of getting a last minute piece of evidence admitted into the record that made Transource do it?

Citizens to Stop Transource reports LATE-NIGHT EVIDENCE SUBMISSION PUSHES AN ADDITIONAL $200M IN COST ON PENNSYLVANIANS.  At hearing on Friday, Transource presented a brand new piece of evidence and then attempted to shoehorn it into the record.  It's a pretty cheap trick.  Evidence must be examined by all parties over a period of time that allows for discovery and consultation with experts.  The impetus for this last minute evidence appears to be a recent FERC order that removes potential new generation from the market efficiency evaluation.  Because PJM's new generation queue is chock full of possible new generators, and the vast majority of generators proposed never actually get built, FERC felt it was best to exclude these generators from market efficiency evaluations.  And because exclusion of these proposed generators increases the supposed "benefit" to electric ratepayers in Washington, DC, and increases the IEC's cost-benefit ratio, Transource thought it was a good idea to get this info. into the record.

Where did you think you were on Friday, Transource?  Did you think that your limo had dropped you off in Washington, DC? 
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I can see the confusion though, and I am completely sympathetic.  I understand that utilities routinely arrive at regulatory hearings in black, chauffeured vehicles that also double as funeral conveyances, but if you were in DC you'd probably have been riding in a series of black Lincoln Town Cars.  Pay attention, Transource!  You were in Pennsylvania on Friday!

As Citizens shares, Transource's new exhibit increased electric rates for Pennsylvanians another $200M!  (In order to translate the exhibit to match increased costs to the actual location of PJM "zones," you'll need this map also).
The new figures raise the projected electrical rate increase in Pennsylvania rates from $350M to over $500M (NPV over 15 years).

The new simulation projects $982M in electrical cost reductions for the DC market, but $969M in increases elsewhere,
including over $514M in electric rate cost increases in Pennsylvania alone.
This also means that the actual amount of "benefit" to the PJM region as a whole (when both increases and decreases are averaged out) is just $12.5M.  For a project that is going to cost ratepayers hundreds of millions!  This is the stupidest thing ever!
If all benefits and costs were to be included, the total benefit of the project would be negative $439M NPV over the next 15 years. 
That's a negative number, which means that instead of receiving a financial benefit, we're all going to be paying more!  This is market efficiency?

At any rate, there Transource was in Pennsylvania, asking Pennsylvanians to take a look at it's sturdy new cost benefit ratio number!  Look!  It provides over $900M in benefits!  Except a look at the worksheet clearly shows that only those zones that showed a benefit (cost decrease) were included in the calculation.  For those zones that showed an increase in electric costs, Transource disregarded them and did not include in their "benefit" numbers.

Is it because Transource believes that the Pennsylvania PUC doesn't care about increased costs to Pennsylvanians and instead focuses on benefits for a handful of the most wealthy counties in the U.S. (not in Pennsylvania, BTW)?
Citizens to Stop Transource VP Barron Shaw stated: “Transource doubled-down on their bet that Pennsylvania would approve a project that effectively drains low-priced electricity from Pennsylvania in order to subsidize the wealthiest counties in the nation.  This project was bad before, and it is even worse now.  The PUC would be nuts to approve this project.”
Really stupid, Transource.  Really stupid.
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American Electric Power Destroys Farmer's Land While He Attends Hearing To Save It

2/22/2019

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How low will you go, AEP?  While farmers opposing its unneeded, uneconomic Transource transmission line were attending the first day of the Pennsylvania PUC administrative hearings to decide whether or not to permit the project, AEP sent its out-of-state contractors in for a joyride across their land.  And this is the destruction they came home to yesterday...
And Transource agents lied, flat out lied, to the landowner and told him they would be out on a different day.  This is no coincidence.  Transource did its trespassing and destruction with full knowledge that the landowner would be elsewhere, trying to protect his property from exactly this.

How in the world can anyone (especially regulators) believe all this company's promises about taking care of the land it disturbs and paying for damages when this is what happens when simple core drilling to examine tower sites is done? 

This is the reason a utility should never be permitted to trespass on private property before its project has been approved by regulators and it has a permit in hand.  The destruction and safety issues will continue and get much worse.  And for what?  So ratepayers in Washington, DC can save 20 cents on their electric bill?  This project will never be approved.  American Electric Power lies to landowners and wantonly destroys their property.  This isn't a company you'd want as a tenant on your land in perpetuity.

And one more thing... here's the landowners showing up at the PA PUC hearing yesterday in a rented school bus that they paid for.
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And here's Transource, its high-priced lawyers, and AEP corporate stuffed suits arriving at the same hearing like movie stars in a Mercedes limo.  I'm surprised there wasn't a red carpet, although maybe the driver just hadn't unfurled it yet.  Who paid for that?  I did.  You did.  Struggling electric consumers in numerous states paid for these clowns to ride in style.
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This travesty simply has to end.  We can't afford it.

Shame on you, American Electric Power!
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Buzzwords, Bluster, and Baloney:  Stirring Up Grain Belt Express

2/18/2019

1 Comment

 
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Languished, obstacle, move forward, favorable, finish line, ambitious, momentum, demand, key, tax credit, renewable, next steps... what do these words have in common?  They're tired buzzwords used to describe tired transmission ideas to a tired public who has stopped caring.  Ya know, if it wasn't for the St. Louis Dispatch energy reporter's own personal greenwashed beliefs, there wouldn't be a "story" here.

What's wrong with this article?  It's misinformed, propaganda-driven malarkey that relies on glittering generalities  and opinion.  It's not "news."  It belongs on the Editorial page, not in "business news."
The proposed multistate transmission line, Grain Belt Express, has languished before Missouri regulators for years — with their at times controversial rejections representing the last major obstacle to sending Kansas wind energy east along an intended 780-mile path.
A bigger obstacle to sending Kansas wind energy east is Illinois.  It seems like the reporter is completely oblivious to the court decision in Illinois that vacated the Grain Belt Express permit in that state.  GBE is back to start in Illinois and it is highly unlikely that it will ever be permitted.  The Illinois Supreme Court has serious concerns that Clean Line's merchant, negotiated rates business model does not meet the definition of a public utility.  If it's not a public utility, it doesn't need a permit from the Illinois Commerce Commission.  Clean Line is free to build any transmission it wants in the state, but it may not use a public utility's eminent domain authority to do so.  The same concern has been briefed in Missouri.  Grain Belt Express will not serve all customers equally, which is a hallmark of public utility status.  Without all of the requisite qualifications, Grain Belt Express cannot be a public utility.
While the overall decision on the project’s approval remains the bigger matter before the PSC, the regulatory body announced this month that it was also warming up to begin the separate process of approving its sale.
Warming up?  What the heck does that mean in a regulatory context?  GBE and Invenergy have applied for Commission approval of the sale.  The PSC has set a hearing to determine a procedural schedule.  It does not imply approval.  It merely illustrates the timing differences here where the companies want the PSC to issue a permit to a project based on new ownership BEFORE it has approved said ownership.  It bolsters the argument of Missouri Landowner Alliance that the PSC cannot approve the project based on the qualifications of Invenergy because Invenergy does not yet own the project.
Some outside experts in Missouri speculate that Invenergy’s bid to take over the project can only help its odds of getting across the finish line.
Outside experts?  Renew Missouri is a party to the PSC case.  Invenergy is the applicant.  These are INSIDERS.  And there is no "expertise" here.  It's talking heads spewing glittering generalities and misinformed, self-serving opinion.

James Owen:  this guy has shot himself in the foot so many times by spewing falsehoods in the media that nobody even listens anymore.  If Invenergy wants to buy the project that's proof there's value to the project?  The only proof there is that Invenergy has some sort of scheme in the works to leverage some parts of the project to serve its quest for profit.  The Invenergy/GBE deal is contingent upon successful permitting in Kansas and Missouri.  It is not contingent upon successful permitting in Illinois and Indiana, nor successful transfer of GBE's FERC negotiated rate authority to proposed new parent Invenergy.  If Invenergy intended to build GBE as currently proposed, all those conditions would be present in the contract.  They're not, therefore Invenergy does  not need Illinois or Indiana permits, nor negotiated rate authority, for whatever scheme it may cook up with the carcass of GBE.
She declined, however, to give updates or estimates about Invenergy’s anticipated, or hopeful, timeline for the project.
“I think it’s premature for us to be talking about timelines right now,” said Conley. “When we have a decision in that case (from the PSC), then we can really consider timelines and development and what the next steps for the project are.”

Is that right, Beth?  You can't reveal Invenergy's actual plan for GBE until after the PSC approves the wolf in sheep's clothing?  Then why was it that two Invenergy witnesses told the PSC at hearing last December that the company would have to begin eminent domain proceedings against 700 landowners immediately after approval, and well before it had all state permits in place to build the original concept?  Invenergy admitted that there have been discussions about ending the project in Missouri, or taking a different route around Illinois.  Invenergy doesn't intend to build Grain Belt Express all the way to Indiana and then sell capacity through negotiated rates, does it?  The only thing "premature" here would be letting Invenergy's cat out of its bag and demonstrating its true intentions to the MO PSC before it makes a decision on the project. It's a lot easier to beg forgiveness than seek permission, isn't it, Invenergy?
The project would be accompanied by the large-scale construction of new wind energy generation in western Kansas. Although about 85 percent of electricity distributed by the project would be destined for other states, it would power approximately 200,000 Missouri households. The PSC, even in denying the project through certain legal interpretations, has agreed that it is in the public interest, and would save Missouri customers millions of dollars by promoting access to cheap wind energy.
This is the reporter's opinion.  There are no facts here.  Building a transmission line does not ensure construction of any generation in any specific location.  Eight-five percent will not be destined for other states.  If GBE would have a capacity of 4,000 MW, then 15% would be 600 MW.  GBE proposes 500 MW for Missouri, if it can find customers for that much.  Instead, it only has purported customers for up to 200 MW, which is 5%.  And of that 200 MW, only a bit over 100 MW has actually been "sold" to municipalities in Missouri.  And where does the 200,000 households come from?  Did the reporter add up all the participating municipalities to get that figure, or did he just harvest it from some GBE propaganda?  So, more than 95% is destined for other states currently.  And of that 95%, only 50 MW, or just over 1%, has been tentatively sold.  And since a merchant project cannot be built without customers (customers who would pay much higher rates than those loss leader rates offered to Missouri municipalities), any prognostication about who would buy the capacity and where they would be located is pure speculation and fairy tale.  Also, it matters not what the MO PSC did on an entirely different matter.  GBE has changed significantly since its prior application, and the PSC's opinion may have changed significantly as well.
Picture
The transmission project would be the biggest, by far, that the Chicago-based company has ever undertaken. The company has developed more than 400 miles of combined transmission lines in its history, Conley said — just over half of the distance that Grain Belt would cover.
But what kind of transmission lines has Invenergy developed, Beth?  They've all been short generation tie line segments built without eminent domain authority.  This is a comparison between apples and oranges.  Invenergy has no experience with open access transmission lines with negotiated rates using eminent domain authority.  All Invenergy's transmission lines are private use for the company to sell its product.  Are we supposed to infer that GBE would just be another one of those, albeit more than 700 miles long?  Great!  But no eminent domain authority would be appropriate for that kind of project.  And besides, Invenergy has not applied to build any transmission project.  The PSC cannot approve this project as something Invenergy is building because Invenergy does not own it.
But for any prospective wind energy developer, the end of 2020 has long been a key point on the calendar.
After that point, production tax credits for completed wind projects begin to phase out. Even without receiving the full tax in their entirety, Clean Line officials previously said they felt the project would be cost-effective, thanks to technology and declining costs. Invenergy shares that belief, Conley said — full tax credits or not.
Does this reporter not know that Clean Line isn't eligible for, and will not receive, any tax credits?  There are no tax credits for transmission lines, and GBE cannot be built in time for any new wind to be built that qualifies for the credit.  It sounds good, but it's pure fiction, certainly not "news."

Perhaps this reporter should have attempted a balanced piece by talking with opponents to the project?  It's almost as if there is no opposition at all.  Failure to recognize the opposition does not make it disappear.  It only makes this article look biased.  And what's up with that graphic?  It shows three Clean Line projects, two of which have been officially cancelled, without any recognition whatsoever by the reporter.

This article is opinionated garbage.  The St. Louis Post-Dispatch needs to do better.
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PJM's Got Nothing

2/12/2019

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In this last blog in the Transource Pennsylvania Surrebuttal Testimony series, let's take a look at the testimony filed by the three witnesses for the state Office of the Consumer Advocate.

The testimony of Scott Rubin was pretty quick.  It sure looks like PJM's got nothing in the way of facts that challenges Mr. Rubin's testimony about the increase in costs to Pennsylvanians that would come with a Transource IEC project.  What PJM's witness does is try to confuse allocation of project costs with economic benefit.  It's all just smoke and mirrors and Rubin creates a great example demonstrating that alleviating "congestion" causes increased costs for customers on the unconstrained side of the congestion.
I agree with Mr. Herling that if a project can be devised to cost-effectively eliminate the transmission constraint, the entire cost of that project should be borne by customers in Town B. As a matter of cost allocation, that is the fairest way to allocate the cost.

Where PJM and Transource are incorrect, however, is in ignoring the increase in costs in unconstrained areas when determining the benefits of a project. By using only the decrease in costs on the constrained side of the congestion point to determine the benefits of a project, PJM and Transource greatly inflate the benefits of the project, making an uneconomical project look economical.
There are no "special people" who deserve to have their rates lowered by raising them elsewhere, but that seems to be what Mr. Herling believes.  By looking only at cost decreases in the Washington, DC-metro area, and ignoring cost increases to Pennsylvania and other zones, PJM picks winners and losers in the electric rates game.  Cost increases should balance out cost decreases when determining "benefit" to the whole region PJM serves.

And speaking of the whole region, Mr. Rubin confirms Barron Shaw's testimony that if the IEC were a regional project, it would not come anywhere near meeting PJM's cost-benefit threshold of 1.25:1.

Mr. Rubin also corrects Mr. Herling's $866.2M estimated savings number, which it appears Mr. Herling plucked from thin air.
The most recent information provided by Transource shows that using PJM’s incorrect assessment of benefits (that is, looking solely at zones that would have reduced power costs) results in reduced congestion costs with a net present value of $707.29 million over 15 years. Moreover, as I explained in my direct testimony and as that same schedule shows, the total benefit to PJM (the sum of zones with reduced power costs and those with increased power costs) is only $17.05 million over 15 years.
And Mr. Horger's number is even worse.
 In other words, a project with a 15-year cost of almost $500 million would produce just $260 million of system-wide production cost savings over that same time period. This is a further indication that the Project is not economical and should not be constructed.
Mr. Horger should have quit while he was ahead.
Under PJM’s methodology for higher-voltage market-efficiency projects, system level production cost savings would receive a 50% weighting in determining the project’s benefits. The other 50% would be made up of savings in the benefiting zones. If that methodology were used for this project, it would result in the Project’s 15-year discounted “benefits” being calculated to be: (50% x $260.13 million) + (50% x $707.29 million) = $483.71 million. This is less than the Project’s 15-year discounted cost of $498 million, meaning that the Project would fail to provide a benefit-cost ratio of 1.0, let alone PJM’s required ratio of 1.25 or higher. Thus, if system-level production cost savings were considered, as Mr. Horger posits, PJM’s own methodology would result in the project failing the benefit-cost test.
Are the judges supposed to be impressed by PJM's magic math?  Or will they instead be swayed by simple, logical explanations they can follow?

And then there's Mr. Cawley, who opines that Pennsylvanians are not "entitled" to benefit from transmission congestion and that their increased costs should be ignored.  He even goes so far as to call notice of increased costs "self-interested parochialism."   

As if the decreased costs for Washington, DC at the expense of Pennsylvania ratepayers isn't "self-interested parochialism" in its own right?
And this is testimony in the Pennsylvania PUC proceeding.  End of story.
OCA Witness Geoffrey Crandall seems to have the same problem as other witnesses where PJM "misunderstood" and misstated his testimony, and then attempted to respond to things Mr. Crandall never said.  Does this trick never get old with PJM (or maybe it's AEP, the source of all PJM's testimony)?  Fact:  PJM never considered non-transmission alternatives to the IEC, although they exist in plenitude right in the back yards of the ratepayers experiencing the congestion costs.

And then we get to OCA witness Peter Lanzalotta, who also seems to have been victim to PJM's "misunderstanding" game.
Mr. Weber appears to state that my testimony recommends that the Eastern portion of the Project should be replaced either i) by new lines in existing transmission ROWs or ii) by additional circuits on lines already owned by PPL. The first part of this contention is completely incorrect. My direct testimony addresses the use of additional circuits on lines already owned by PPL. It does not address the installation of new transmission lines on new towers along existing ROW. My direct testimony points out that PJM did not evaluate the use of additional circuit positions already available on transmission towers owned by PPL. I do not develop an alternative to the facilities in the eastern portion of Project 9A. I only present the recommendation that use of additional circuits on transmission towers already owned by PPL be evaluated as part of an alternative to the proposed facilities in the eastern portion of Project 9A.
And PJM tries to defend its broken competitive planning process by sharing that it doesn't keep an inventory of existing circuits with room to add new, and besides it can only select an option from those that were submitted in its project window.  Poor, poor PJM, trapped and prevented from doing logical, cost effective planning.  *sniff, sniffle, wahhh* 
PJM is so busted... PPL submitted testimony with multiple options for using existing lines.  Maybe it's time for PJM to pull its head out of the sand?

After reading all this testimony, I can only conclude that PJM has nothing with which to prop up the Independence Energy Connection in the face of the simple, logical testimony of its opponents.  Trying to muddy the waters and confuse the judges just isn't working.  I have every confidence in the PA OCA and the Stop Transource folks to continue their excellent work and prevail at the evidentiary hearings beginning next week.

The IEC has been nothing but a huge waste of time and money.  Let's stop the bleeding.
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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

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