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Digging Into MPRP

7/11/2024

2 Comments

 
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Get your hip waders, folks, it's going to get deep in here!

Last night I attended the MPRP "Open House" in Brunswick.  It made the guy from Assedo pretty nervous that we wouldn't sign in and give them our information, but he said we were welcome to look around.  So, I did.  I think maybe he changed his mind later when he spied us chatting with the reporter from Fox because he found it so intriguing he needed to document it with photographs.  I saw you, dude.  Somehow, I don't think PSEG is going to be using those photos for public relations purposes.

MPRP's "Open House" was right out of the utility playbook.  Free food and beverage, free tchotchkes, and plenty of free propaganda from subject matter "experts" that sometimes couldn't stay within their specialties.  Most of them were very nice, heck, they're just doing a job.  A couple were quite snotty when they realized I knew they were blowing smoke.  And I got so far under the PJM guy's skin that he started "m'am"-ing me.  The sickest part of these open house meetings to me is always the Indoctrination Station for the kiddos.
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Don't leave your kids here coloring propaganda under the watchful eye of strangers.

The first stop was the table with the PJM guy.  Stu Widom had lots of helpful information, but didn't know much about the actual planning process, and it showed.  Got himself all tweaked when I mentioned the precedent PJM has recently set by changing the route of a different project so it doesn't affect wealthy and politically connected people in Virginia's wine and horse country.  Why don't you ask Stu about that tonight?  He likes to pretend that it was for "environmental reasons" but it was nothing of the sort!  The new route crosses the C&O Canal NHP TWICE.  Environmental my foot.  Of course, poking the rich and powerful might affect Stu's own personal environment as one of PJM's political schmoozers, so maybe that's what he meant?  He obviously wasn't there to talk with citizens, but to use his bee smoker on any angry legislators or government officials who showed up.

Next I talked to one of the land agent ladies, who pretended that's not what she was.  I asked her when they were going to release the land agents on the citizens impacted by this project and she acted all confused.  I asked her if land agents would be calling on people BEFORE or AFTER the Maryland Public Service Commission approves this project.  She assured me land agents would only contact you AFTER the MD PSC approves.  We both knew she was full of it, and my investigation of regulatory filings this morning confirms
The Project is a greenfield project for most of the project route, which poses uncertainty and risk. With an in-service date of June 1, 2027, the Project faces an aggressive timeline to execute and complete all construction activities. The Project must manage ROW permitting and land acquisition risks associated with the greenfield line routes in a compressed period of time. For instance, PSEG RT will need to obtain ROWs, rights-of-entry, easements, and temporary access agreements, and in these efforts, may encounter local opposition from landowners. 
Busted!  Those land agents will be on your doorstep as soon as the routing is completed in September.

Next was one of the routing guys who told me this project was needed to supply electricity to the local area.  I told him he was wrong, then he admitted that he wasn't the subject matter expert on that.  He suggested I go over to Stu's table to find the answer to that question.  I said I'd already been there and maybe HE should go talk to Stu.  He refused, so I suggested that he not lie to people about that anymore,

I talked with a delightful young lady at the structure/electrical engineering poster.  She showed me the selected H-frame structures and told me the poles were 40 feet apart and that it would be possible to drive farm equipment between them.  I asked her what happens if someone tried that and accidentally clipped one of the poles and it fell over.  Who would be liable?  She didn't know.  I didn't suggest that she volunteer for a farm machinery rodeo, where the power company person stands in a field with their arms outstretched and pretends to be a transmission tower while farmers see how close they can drive their gigantic pieces of equipment to the "tower" without knocking it over.

I talked with another routing lady who confirmed that paralleling existing transmission lines can actually be MORE destructive than cutting new greenfield lines.  We talked about how homes and other structures are often sited right outside transmission rights of way that have existed for decades.  Paralleling that corridor with a new 150-ft wide easement would destroy everything adjacent to the existing corridor.  She said MPRP would go around homes rather than over or through them, but had to minimize how many times its line crossed the existing line.  There was also a problem where a home stood on either side of the existing easement, preventing expansion on either side.  She didn't know what MPRP would do in that instance.  One of those homes would have to be sacrificed, that's what.  Whichever side of the existing easement has more homes wins.  However, when MPRP uses new easements, it can go around any home or other obstruction and won't have to destroy anyone's home.

And finally, I talked with PSEG's staff lawyer, who happened to be sitting at Stu's table.
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Very nice person who pretty much told the truth and had the answers to my rather unique questions.  She admitted that perhaps some of the other "experts" at the meeting may be making crap up and she had asked them not to do that.  I grilled her on PSEG's federal regulatory filings and cost recovery system.  This morning I found the documents and they mostly confirmed what she told me. 

​PSEG has applied at the Federal Energy Regulatory Commission to be granted three transmission incentives.  The first is the Abandoned Plant Incentive.  If granted, PSEG would be able to recover all its prudent expenditures on MPRP in the event that it is abandoned before being built through no fault of PSEG.  This would include if cannot get the permits it needs, or if PJM's need for the project changes.  The second is to set a preliminary debt/equity ratio of 55/45%.  This isn't anything to get concerned about.  The third incentive is recovery of PSEG's expenses related to this project once the project has an approved formula rate.  PSEG's initial expenditures will be recovered over a 5-year period once it has a recovery method.  This means that all the money PSEG has spent preparing this project for PJM, ushering it through PJM's competitive process, it's legal costs to make those FERC filings, the cost of all its contractors (routing, engineering, land acquisition, public relations), the food, the coloring books, even those cute little hardhat flashlight keychains (be sure to get one!).  Everything PSEG has already spent will end up added to ratepayer bills once it has its formula rate established.  The one made up fib the lawyer told was that PSEG was paying for all the current costs of the project out of the goodness of their hearts.  I hope she knew as well as I did that those costs were being put in an account as a regulatory asset that would be recovered (with interest) at a later date.

First, PSEG is waiting for FERC to approve its incentives.  Afterwards, PSEG will file for approval of its formula rate and rate of return.  Bet your eyes glazed over just then, right?  Stick with me here...  A formula rate is a set of tables that calculate a yearly rate based on numbers that the transmission company plugs in from their ledger.  As things are paid for, the costs get added to certain accounts, and the account totals get transferred to the formula rate on a yearly basis.  The number that comes out the end of the formula is the amount that electric consumers pay for the transmission project on a yearly basis.  A rate of return is how much interest the company earns on its capital expenses.  That includes physical assets, like transmission lines, land they sit on, and it also includes the cost of building them in the first place.  It's heady stuff, but anyone with a little accounting experience can handle it just fine.

Once the formula rate and rate of return is set by FERC, you can help PSEG look over its costs every year to make sure they don't include any costs in their formula rate that shouldn't be charged to ratepayers.

To wrap up... I urge you to download and read PSEG's application for FERC incentives.  It may answer a bunch of the questions I have seen swirling around, such as where's the data proving need?  Why was this project selected instead of upgrading existing lines?  If you have questions, why not take them to the PSEG attorney at tonight's meeting?  She's fun to talk to.  Be nice. 

Another utility "dog and pony show" in the books.  Don't expect to accomplish much.  MPRP isn't going to be stopped at any of these meetings, but attending is your first step.  It's simply a networking opportunity.  Come hungry.  As one landowner remarked at one of these shows years ago... "We might as well eat.  It might be all we get."
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2 Comments

FirstEnergy Files For Incentives For MARL, Delays Project

7/3/2024

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The MidAtlantic Resiliency Link, or MARL, transmission project has been assigned by PJM Interconnection to two different transmission builders.  NextEra is assigned to build the majority of it, but FirstEnergy ended up with the portion that runs through Frederick County, VA and Jefferson County, WV.

Long ago, even before PJM ordered MARL, NextEra filed an application for transmission incentives with the Federal Energy Regulatory Commission.  FERC approved them back in January.  Nobody bothered to get involved and comment or protest.

Everyone's been treading water, waiting to get more information, but neither NextEra or FirstEnergy has held public meetings to share information with impacted communities.  Seems like nobody is in a hurry at all.

Remember that when PJM ordered MARL, it said the project was needed to be operating by June 1, 2027 or else there would be darkness.

Back in May, FirstEnergy finally got around to requesting transmission incentives for its portion of the MARL.  It asked FERC to grant it the abandoned plant incentive.  Grant of the abandoned plant incentive begins the tally of project costs that can be recovered if the project is abandoned (cancelled) before being built.  Anything FirstEnergy spends before receiving this incentive is only eligible to be recovered at 50%.  That would mean that FirstEnergy could only collect half of the money it spends on MARL in the case of abandonment.  The other half would come out of FirstEnergy's pocket.  Fitting, don't you think, since FirstEnergy insisted on being assigned this portion that rebuilds and expands lines FirstEnergy already owns?  However, that's not what FirstEnergy asked FERC for... it asked FERC to allow it to recover 100% of whatever it has spent (plus interest) if the project is abandoned.

FERC Commissioner Mark Christie is at war against certain transmission incentives.  FERC opened a rulemaking to examine and revise its incentives more than 4 years ago, but has punted it to the side without action, allowing the overly generous incentives to continue.  
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I'm taking this opportunity to object to FirstEnergy's request for the abandoned plant incentive.  Do they really need it, since they were so eager to have this project that they engineered some secret deal behind the scenes at PJM?  

NextEra's cost cap for MARL (as crappy as it is) did not transfer to FirstEnergy when it took over this section of the project.  FirstEnergy can and will spend however much it wants... currently estimated at $341M for a very short "rebuild" segment.  How much will they actually spend, and how soon will they spend it?  How much spending is planned *before* state approvals, which if denied can cause abandonment?  FERC should place a limit on running up the spending before project approval.

These are the comments I submitted to FERC.
er2401998.pdf
File Size: 112 kb
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And here's the worst part!  As part of their filing, FirstEnergy included a copy of its acceptance letter of PJM's designation of a portion of the MARL.  In their acceptance, FirstEnergy has changed the in-service dates for its portion of the MARL.  The Virginia portions (both in Frederick and Loudoun counties) are supposed to be in-service by June 1, 2028, delayed a year from the date PJM said they were needed.  The in-service date for the West Virginia portion in Jefferson County is delayed until June 1, 2030.  That's right... 2030!  MARL is not planned to be completed and transmitting energy until 2030!  That's six years from now!  Are Virginia's data centers going to hang around waiting to build and be connected to the electric grid for another 6 years?

NO!  They won't wait.  They will go somewhere else where they can build a data center and get electric service before 2030.  The bottom may be about to fall out of Virginia's data center craze.

​Here's what FirstEnergy's acceptance letter looks like:
potomac_edison_designated_entity_acceptance_letter.pdf
File Size: 339 kb
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Once the in-service date for PJM's transmission projects starts slipping, it often keeps slipping... right off into oblivion.  It can be delayed if expected load doesn't show up (but goes elsewhere). It can be delayed if the utilities run into permitting problems, such as taking a state denial in a NIETC to FERC for permitting.  It can be delayed if the utilities have difficulty procuring project components; there is a huge supply chain issue for transmission components right now.  It can be delayed if there are issues with land acquisition.  It can (and will) be delayed even further.  And, as I said in my comments...
MARL’s in-service date is already slipping. Why is that relevant? Because the electric grid abhors a vacuum. When a planned transmission (or generation) project fails to come online when needed, other projects will take its place. That’s exactly what happened with the PATH project, and what is likely to happen with the MARL project, including the Potomac Edison portion that is the subject of this filing. 
Giving these transmission companies the greenlight to spend as much of our money as they want before they finally abandon MARL many years in the future is not just and reasonable.
This transmission project may never happen, but PJM and the utilities involved feel they should pursue it anyhow. Is that because there are no other options? Or is it because there’s no harm done to them if it fails. All the burden of failure falls on ratepayers, and this encourages the utilities to take more of a chance than they would it they had some skin in the game. Utilities shoulder no risk, while collecting all the rewards. 
​

Consumers have zero control over the project’s risk factors, but they are the ones left holding the bag when it fails. As consumers, we simply cannot afford to continue to financially cover the failures of grid planners and transmission developers simply because we are the one entity without a voice in incentive awards. 
FirstEnergy has asked FERC to approve its incentive request before July 15.  Once consumers have thus insured the reimbursement of FirstEnergy's project spending, then maybe FirstEnergy can actually start working on MARL.

But what happens if FERC doesn't grant this incentive?  Will FirstEnergy still want to build its part of the MARL?  Or will it have to go back to PJM for revision?

​Stay tuned...
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Maryland Energy Security

7/3/2024

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by Patti Hankins, Harford County Maryland ratepayer
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Pennsylvania State Senator Gene Yaw wrote to the PJM Board of Managers on June 14, 2024 in response to a letter the PJM BOM received from the Governors of Illinois, New Jersey, Maryland and Pennsylvania  regarding FERC Order No. 1920.  Senator Yaw is the Chair of the PA Senate Environmental, Resources and Energy Committee. Senator Yaw states in his letter:
"We must recognize that many of the challenges we face today which are accelerating very quickly — namely concerns over sufficient transmission capacity, loss of electric power generation and the inability to site and build new baseload-power generation — are tied directly to poorly-thought out state public policies which have prioritized political considerations above the needs of consumers.
For example, while many states surrounding Pennsylvania have touted their climate goals and reductions, they have conveniently ignored that they have achieved many of these goals simply by shutting down their in-state generation. As a result, they rely on imports of electricity from states like Pennsylvania, which is the largest electricity exporting state in the nation, increasing transmission costs, line loss due to distant transport of electricity and increased risk of blackouts or brownouts."

"Other state policies have upset the balance of competitive power generation by subsidizing

preferred energy resources — many of these resources incapable of providing baseload power generation on demand — or threatening coal and natural gas generation with onerous carbon taxes.
For example, just the prospect of Pennsylvania entering the Regional Greenhouse Gas Initiative (RGGI) has cost the commonwealth billions of dollars in private capital investment and thousands of jobs, and at the same time failed to demonstrate any commensurate environmental benefit to the public. Too often energy policy is being hijacked to serve politically expedient objectives rather than to meet the most fundamental objective that it should serve: ensuring the lights go on when
we flip the switch."
Maryland's energy public policy and efforts by the Sierra Club of MD have threatened the energy security of Maryland consumers. The forced closure of the Brandon Shores Power Plant by the Sierra Club has resulted in an emergency transmission project to send electricity from PA to MD via Harford County. Over 1 million BGE customers have been placed at risk for having reliable electricity for their basic needs. Maryland's energy policy focuses on wind and solar generation. Both are intermittent energy sources that are completely dependent on Mother Nature. Our Maryland Governor and progressive leaders in the House of Delegates and Senate are just fine with shutting down baseload-power generators in our State. Where do they think the power is going to come from? BGE touts the Brandon Shores Retirement Mitigation Project as "Good Energy at Work" with a website named "good energy in progress".

So baseload-power generation, namely coal, natural gas and nuclear are good if they come from Pennsylvania but bad when it's home grown in Maryland? How many Pennsylvania extension cords are going to be needed to keep the electricity on in Maryland? We know that the PJM 2022 Window 3 projects will bring another extension cord from the Peach Bottom Nuclear Plant's substations to be colocated with the Brandon Shores "good energy" project. And another extension cord from Chanceford Township in York County, PA to Frederick County via Northern Baltimore County and Carroll County. And yet another extension cord from Hunterstown, PA to Carroll County. What happens when Pennsylvania runs out of power generation to send?


Pennsylvania is now starting to see data centers and Bitcoin mining companies locating near generators in the State. In March, Amazon Web Services purchased a 1,200 acre data center campus adjacent to the Susquehanna Steam Electric Nuclear Station. This acquisition allows AMS to purchase energy directly from the Station.

And just this month Bitfarm, a Bitcoin mining company announced it would locate in Sharon, PA where it would have access to an abundant energy supply. Bitcoin mining like data centers uses massive amounts of power. 

Maryland has become much too dependent upon Pennsylvania for its electricity generation. I ask each Maryland state legislator, what steps will you take to secure Maryland's energy supply before it's too late?
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Whoopsie!  GBE Bites Off More NIETC Corridor Than It Can Chew

7/2/2024

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Everyone is incensed by the U.S. Department of Energy's preliminary 5 mile wide National Interest Electric Transmission Corridor (NIETC) that was magically centered on Invenergy's proposed Grain Belt Express transmission line.  How and why was that preliminary designation made?  And for what purpose?

A NIETC's purpose is to designate a geographic area where one or more transmission projects serving the "national interest" can be sited.  A transmission project inside an NIETC can apply for a federal permit and eminent domain if its state application is denied.  NIETCs are a way to overturn a state decision you don't like.

But GBE claims to have all the state approvals it needs.  So, why the corridor?

Why is it 5-miles wide?

And what ever happened to GBE's Environmental Impact Statement being prepared by the U.S. Department of Energy's Loans Program Office to facilitate a "get out of debt free" card provided by taxpayers if GBE cannot repay its loan?

All these questions (and more!) were answered recently, and the answers did not come from DOE.  DOE has put its interactions with greedy transmission developers under lock and key.  No, the information came from another (anonymous) source whose accuracy can be trusted.

The Midwest Plains Preliminary NIETC was submitted to DOE by GrainBelt Express (GBE) as a National Interest Electric Transmission Corridor because of the federal funding opportunities that a NIETC designation opens up, as well as the potential last resort option of the use of federal backstop siting authority in States where the initial state approval is currently under appeal, such as Illinois.  The corridor was originally submitted as five miles in width because GBE thought that it had to be at least wide enough to encompass two lines. 

Because of all the stink you made, GBE has submitted comments to DOE requesting that the corridor be substantially narrowed to no wider than is necessary to site just the GBE line. 

But would a narrow, specific "corridor" that only enables one transmission line actually be something that DOE can do?  It positively smacks of government graft.  Wouldn't a wider corridor give the DOE plausible deniability?  It seems like the DOE was only too happy to create a 5-mile wide corridor (which is supposed to be based on DOE's factual transmission needs study, btw, not greedy requests).  Who knows what DOE will do with this corridor in the fall.  Will they stick with their 5-mile wide corridor, or will they prove that they are nothing more than a corporate puppet by granting GBE's second request to narrow the corridor just wide enough for GBE?

If designated this fall, this NIETC will have to undergo a federal Environmental Impact Study, just like the one GBE is already involved in required by its request for a government loan guarantee.  But the study already underway only studies the very narrow GBE corridor.  It doesn't study a 5-mile wide NIETC.  If the NIETC is any wider than GBE itself, then GBE's EIS will have to go back to start.  But perhaps that is required in any instance, since the basis for the EIS and governmental action will have changed completely between a government loan guarantee and a NIETC.  You could probably litigate on changing purpose in midstream for a long time.  Maybe GBE will have to fund two separate EIS reports, one for each purpose?  Each EIS takes a minimum of two years.

Meanwhile, back at the DOE, the right hand has no idea what the left hand is doing.  Don't these gals ever see each other in the hallways and stop to chat?  Maybe not because they are all likely "working from home".  I hear that nobody answers the phone at DOE HQ anymore.  Is any work being done in that empty building we pay for?

DOE says the LPO (Loans Program Office) will publish the draft EIS for public review and comment this winter.  DOE is plunging ahead with the EIS for the loan, while not even acknowledging another one has to be done for the NIETC designation.  At least they're only wasting GBE's money with this duplication of effort.  Carry on, ladies!

And here's another thought brought on by the preliminary NIETC designations.  GBE's western terminus will be in Ford County, Kansas.  We've been told that for years.  The story goes that GBE will ship all that untapped wind energy in Kansas to "where it's needed most" (Mars?  Polsky's imagination?  Lifestyles of the Rich and Famous?).  GBE is now asking for approval of two "collector lines" in southwestern Kansas for wind AND solar projects not yet built.  See KCC docket 24-GBEE-790-ST available at this link for more info.

Kansas, huh?  Then what is the Plains - Southwest NIETC for, and why does it reach its cold little finger up into Ford County Kansas?  Is it trying to export even more Kansas wind, or is it importing wind from other states that will be shipped through Kansas on GBE?
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Kansas officials who have been falling all over themselves to give GBE whatever it wants because they think it's going to cause massive economic development in Kansas may end up with a massive Dodo bird egg all over their faces if it turns out that Kansas is just being used as another "fly over" state facilitating Invenergy's profit.  Who remembers that Invenergy owns "the country's largest wind farm" in the Oklahoma panhandle?  Whose idea was this Plains - Southwest corridor, and who is going to profit from it?  Invenergy's giant wind farm was planned and construction began (to preserve tax credits) way back in 2018 as part of AEP's ill-fated WindCatcher project that was supposed to connect Invenergy's wind farm to the Tulsa area via a new transmission line AEP wanted to build.  AEP did not receive approvals for that scheme and the project was cancelled.  And there was Invenergy with the country's biggest wind farm in process and no transmission line to serve it.  Invenergy bought the remnants of Clean Line's Grain Belt Express later that same year.  Kismet!

Anyhow... maybe, just maybe, the longer this debacle goes on, the GBE koolaid that some of the project's biggest cheerleaders ingested seems to be wearing off.  Wakey, wakey, little officials!  There's a wolf among your sheep!
2 Comments

Illinois Coalition Files Appeal of GBE's Negotiated Rates at the DC Circuit Court of Appeals

6/29/2024

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A coalition of Illinois landowners and Farm Bureau made good this week on their threat to appeal a recent FERC decision approving "continued" negotiated rate authority for the Grain Belt Express.

A couple months ago, FERC made an incomprehensible decision to rubber stamp GBE's request for "continued" negotiated rate authority, and then ignored the Illinois group's request for rehearing simply because it ran out of time.  In my opinion, FERC will find itself between a rock and a hard place trying to explain how its decision was logical to the court.  There's still time for FERC to change its mind and bolster its contradictory order, but that window is closing fast.

Perhaps FERC didn't think that the Illinois group would actually file an appeal.  Basing the legal durability of its decisions on whether or not FERC thinks the appellant has enough money and skills to file an appeal (and therefore making bad decisions that affect parties without means) doesn't always work out so swell.  Sometimes those parties  win the stare down contest and FERC ends up trying to defend the defenseless before some judges.  I might actually feel sorry for the FERC attorney who gets handed this dud, if it didn't cost so much time and money for the appeal to be filed.

​Here's what the Illinois group filed.
petition_for_revew_final_w_exh_a.pdf
File Size: 516 kb
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In October 2023, GBX filed with FERC its Application for Amendment to Existing Negotiated Rate Authority (the “2023 GBX FERC Application”), for which FERC opened its Docket ER24-59. Absent from the 2023 GBX FERC Application is any mention of its failure to obtain FERC’s prior approval under FPA Section 203 for the 2020 upstream ownership transfer of GBX to Invenergy. GBX instead continually characterizes certain noncontroversial changes to its transmission project as amendments to its existing negotiated rate authority. Because FERC never approved the upstream ownership transfer of GBX to Invenergy under FPA Section 203, after the January 2020 closing of that transaction GBX had no negotiated rate authority to amend.
​

While FERC claims in its Order that it is reviewing GBX’s negotiated rate authority de novo based on its current ownership structure (Order, ¶71), it plays right along with GBX, dismisses as irrelevant GBX’s failure to obtain prior FPA Section 203 approval for the 2020 upstream ownership transfer, and expressly recognizes GBX’s continuing negotiated rate authority (Order, pg. 27). FERC thus backdates GBX’s negotiated rate authority to January 2020. 

FERC’s recognition of GBX’s negotiated rate authority as continuing from any time prior to February 29, 2024 not only gives the lie to its claim that it has conducted a de novo
review of that authority, it is a patently unlawful retroactive approval of an upstream ownership transfer that closed more than four years before FERC issued the Order.
What happens next?  The Court will assign a procedural schedule that allows for initial and reply briefs, and may set the case for oral argument before the Court.

Stay tuned!

Bravo to the Illinois group for questioning what FERC wrote in its Order and filing an appeal!
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NIETCs Panned by Public

6/29/2024

4 Comments

 
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Thousands of citizens across the country gave the U.S. DOE their thoughts and opinions about the potential designation of multiple National Interest Electric Transmission Corridors (NIETCs) across the country this week.  And it seems like nobody thought it was a good idea, except a handful of clueless congress critters playing politics.  I'm going to bet they didn't ask any of their constituents who would be impacted by NIETCs what they thought about it, and they suck up to the political teat at their own peril at the ballot box.

​This is probably my favorite line from all the comments I managed to read before they got sucked down into DOE's black hole.  This comment comes from the Inskeep family in Kansas.
​There hasn’t been a land grab and human expulsion to this degree since the Native Americans were slaughtered indiscriminately and herded off their land.
Congress, the U.S Department of Energy, and the DC political machine never considered the thousands of people impacted by their desire to turn rural America into energy slaves for their glistening cities, nor put it into the context of how it will be remembered by the history books.

The midwestern state farm bureaus submitted excellent comments, and the Missouri Farm Bureau wrote this opinion piece.

These are the Missouri Farm Bureau's comments.
mofb_comments_doe_nietc_phase_2_-_final_062424.pdf
File Size: 311 kb
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And these comments came from the Illinois Farm Bureau and a collection of impacted landowners in that state.
landowner_alliance_comments.pdf
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Further east, I submitted these comments on the designation of multiple NIETC segments in West Virginia for the purpose of shipping coal-fired power to Virginia's "data center alley" via new high-voltage extension cords.
Sacrificing West Virginia’s environment and imposing new costs on its struggling consumers for benefit of Virginia’s economy and the profits of the corporations who operate there is the epitome of environmental and economic injustice. Virginia ranks tenth in the list of average salaries by state, with an average annual salary of $65,590. West Virginia ranks 48th on the list, with an average annual salary of $49,170.13 West Virginia is never going to economically catch up with surrounding states if its citizens are forced to pay a significantly larger share of their income to support the economic development of surrounding states. 
Read the whole thing here:
nietc_phase_2_comments.pdf
File Size: 3212 kb
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A citizen asked DOE where they could read all the comments that were submitted.  DOE's response was
​Thank you for your inquiry. DOE will not be making comments received regarding the preliminary list of potential NIETCs publicly available.
This is not a transparent process.  DOE is most likely up to no good, but how can we know for sure when the public is shut out of a process that could take their land and destroy their economic well-being?  What happened to "transparency" and "public participation"?  It's out the window.

Nevertheless, you inserted yourself into a process where you were not welcome.  It's the only thing you can do when your government is holed up with special interests and planning to take what's yours.  The legal challenges will come later.  Thank you to everyone who participated!

What's next?  The DOE plans to issue its decision this fall with "draft" designation reports.  You'll be allowed to comment on these reports, but DOE will have already made its decision and you'll be in the position of trying to change their mind.  Where has democracy gone?

For each corridor that receives a draft designation, the DOE will have to undertake an Environmental Impact Study, which is a multi-year process where they are required to involve the public.  But we already know what DOE thinks of public comment, right?  They have made that plain.  They are in a real big hurry to railroad this process forward before the election in November.  Don't forget to vote!
4 Comments

Maryland Piedmont Reliability Project

6/21/2024

15 Comments

 
Well, here's another particularly noxious transmission project weed!  The so-called "Maryland Piedmont Reliability Project" or MPRP.  This industry loves its acronyms!

In 2023, regional grid manager PJM Interconnection devised a suite of new electric transmission projects designed to import new electricity supplies to new data centers in Northern Virginia, and for Frederick County's new Quantum Loophole project.  Data centers use so much electricity, it's equivalent to large cities sprouting up overnight in previously rural places.  New cities need new power supplies, especially because Maryland has been closing all its baseload power plants that run on fossil fuels.  Before Maryland's recent plant closures under their "clean energy" plan, the state was importing 40% of the energy it used.  Now, it needs even more imports!  We're heading toward more than 50% of Maryland's electricity being imported from neighboring states via new high-voltage transmission lines.  The only two states in the PJM region that generate more electricity than they use and can export to Maryland are West Virginia and Pennsylvania.  The MPRP is importing electricity from southeastern Pennsylvania.  Other new transmission projects are exporting electricity from West Virginia's coal-fired plants to Loudoun County's "Data Center Alley.  It's nothing more than a series of enormous electric extension cords for data centers.  In PJM's planning process, it looked like this:
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Frederick County was sleeping the sleep of the uninformed throughout the planning and approval process at PJM.  And now it has manifested.

The project was assigned by PJM to New Jersey utility Public Service Enterprise Group.  Why them?  PJM put its new project requirements out for bid, and PSEG submitted the best project for PJM's needs.  PSEG also offered a certain price for the project.  There's more to this, but let's stop there for now.  Since PJM approved this project and assigned it to PSEG last December, PSEG has been busy devising a route for the project, and now they have finished and want to share it with the public.

PSEG will be holding public "open house" meetings across the project area early next month.  See website for details.  The "meeting" is hardly an actual meeting though.  It's a series of information stations the public is supposed to file through, and you may be handed a card to fill out with your thoughts at the end of the meeting.  Each little station will be populated with PSEG representatives, and you can ask them questions.  But there is no formal presentation or Q&A session where everyone can hear each question and answer.  Go ahead... ask different representatives the exact same question and get wildly different answers.  This is why utilities hold these kinds of meetings.  They will tell you what they think you want to hear, and not be held accountable for any of it.  The main purpose of the "meeting" is to introduce preliminary route maps to the impacted community and receive feedback that could help guide the final route that PSEG files for approval of the Maryland Public Service Commission.

This preliminary route map is floating around social media.
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Not a lot of detail, but it's a damn sight better than PJM's initial map as far as determining where they expect this project to go.  At the open house meeting next month, PSEG will have the detailed aerial maps that you want to see.  The maps may present numerous short route segments that can be pieced together to create a route.  They may ask what you think of them.  Most people will reject routes that impact them, and may be tempted to champion routes that do not.  But, throwing your neighbor under the bus to save yourself is never a good strategy.  The community must come together to oppose ANY of these routes.  If data centers need new electricity supplies, they need to build new power generators near the data centers, instead of plowing through communities that won't receive any benefit.  

The MPRP will likely need new rights-of-way 150-200 feet wide for its 500kV transmission line.  The company will ask landowners to sign easements for a one-time "fair market value" payment for just the land in the easement.  This gives PSEG the right to use your land, but you will still own it and pay taxes on it.  The easement payments are compensation for land you can no longer use, they are not a windfall or profit.

The MPRP website is chock full of propaganda and small bits of information that impacted landowners need to really investigate.  For instance, the website says:
​The MPRP is a 500,000-volt (500 kV) transmission line designed to respond to growing electric needs in Maryland and the surrounding region. Transmission reliability is key to supporting Maryland’s energy future.
They don't tell you that the project is only necessary because of enormous new data center load.  If we didn't build the data centers, or if we built new electric generation near the data centers, this transmission line would not be necessary.   It's not for you, it's for data centers.  This project also has NOTHING to do with clean energy.  It will actually increase carbon emissions in neighboring states that will have to produce more power using fossil fuels in order to import it to new data centers in Maryland and Virginia.

​Here's another:
  • Will PSEG want access to my property before I agree to grant an easement for the project?
  • ​PSEG may request prior access to conduct preliminary work such as a survey, delineate wetlands and/or conduct an appraisal to determine the amount of land needed and the value of an easement. In that case, the land owner will be asked to sign a right of entry document allowing PSEG onto the property for only these limited purposes.
State law allows utilities to access property for limited survey purposes before easements are signed.  However, PSEG wants landowners to sign a document permitting all sorts of surveying and testing, including things that may harm your property, like core drilling.  Think twice about signing this document and giving PSEG unfettered access to do whatever it wants on your property before they have paid you a dime.  Maryland law already gives them access for surveying that doesn't harm your property.  You don't need to sign any document or give them further permissions.

I also didn't notice the words "eminent domain" on MPRP's website, but that's exactly how they intend to acquire land from unwilling landowners.  Easement offers are nothing more than coercion... sign and take the money... or else.  When there's no opportunity to say no, it's not voluntary land acquisition.

PSEG's website, its open house meetings, and its permission forms and easement agreements are written in the company's best interest, not yours!

The best use of PSEG's open house meeting will be the opportunity it gives you to meet new folks who are similarly affected by this project and to exchange contact information and hold further meetings among yourselves to share information of interest to landowners who want to defend themselves against this transmission project.  PSEG is not from here, it doesn't know your community, and at the end of the day it doesn't care what happens to it.  They can't see it from their house in New Jersey!

It's time to circle the wagons, Frederick County!  Later this year, PSEG may file an application with the Maryland Public Service Commission.  When that happens, you have the right to intervene and become a party to the case that can submit testimony and cross-examine utility witnesses with the goal of convincing the MPSC to deny a permit for this project.  There will also be public hearings held by MPSC where you can speak out against it.

Meanwhile, get engaged and stay current on project news.  Talk to your neighbors and others in the community who may be impacted.  Make a plan. Maybe I'll see you at the open house...
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Propaganda at work

6/21/2024

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Lots of new transmission projects in the PJM region due to PJM's Window 3 that needs to import electricity into Baltimore and Northern Virginia due to the closing of the Brandon Shores and Wagner coal-fired power plants, and the building of new data centers in Northern Virginia and Frederick County, Maryland.  They have been in the works for over a year, but are just now being rolled out to the public, and they are sprouting like weeds!

Do you think that the utilities could respect the impacted communities and just tell them the truth without varnish and propaganda?  Do they think we're all idiots who can be easily led to love our own destruction?

Introducing.... "Good Energy At Work" on BGE's "Good Energy In Progress" website.  Couldn't the PR team agree on what the "good energy" was doing?  Branding fail!!!

What kind of corporate hubris compels BGE to believe it can avoid all community opposition with such a simple branding effort?

What is "good energy?"  And furthermore, what is "bad energy," and how shall we make a comparison?  Good vs. bad... the sheeple will pick "good" every time, right?  Except it's just too damned simple, unlike the community that will be impacted.  It's supposed to make you love these transmission projects without digging any further than knowing that they are "good" because the utility tells you so.  Sorry, BGE, when the impacts from these projects begin to happen in the impacted communities, the people will feel like they've been lied to.  What's good about transmission construction?  It's a major project that will severely impact all abutters to the existing easements.  Construction noise, workers coming and going to (and within) the easement.  Large equipment being brought in, and trampling everything in its path.  Helicopters and cranes.  Whup, whup, whup, beep, beep, beep, *kablam* (if explosive splicing is employed).  Is such a simple word as "good" going to blot all that out?

Bad energy must be the existing transmission system that the community has grown used to and spends little energy contemplating.  Bad energy is using electricity from a local coal-fired power plant.

So, good energy must be community impacts from new transmission meant to supply electricity from another source.  What source is that?  It's not being produced in Maryland.  It's coming from Pennsylvania's fleet of gas, coal and nuclear power plants.

How is dirty energy produced in Maryland bad, when dirty energy produced in Pennsylvania and imported to Maryland over expensive and invasive new transmission lines is good?  That's right, your new "good energy" is going to cost you more, and it's no cleaner than the electricity you were using before.

Good?  I suppose it's all in the propaganda used to lead the sheep to believe these new transmission projects are somehow "good" for them.  It probably won't work.

It is so simple, it's insulting.  They're treating the impacted communities like toddlers.  But it's not like it's the first time a transmission company tried to pull the wool over the eyes of the impacted community with silly branding slogans.  Not too long ago, a transmission company in the Midwest tried something similar with the branding slogan "Positive Energy."  It failed, in a hilarious way.  This one will, too.

I wonder how much ratepayer money was tossed to a PR company to come up with such a silly proposal?  And what's next in the "good" department?
0 Comments

Landowners Are Not a Problem That Needs Solving

6/16/2024

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Academics who have never had a transmission line proposed across their property are at it again, writing their idiotic "reports" that claim to find the reason why transmission projects draw opposition and are not successful.  I've seen many versions of this "save the transmission world" report, and exactly none of them have gotten it right.  I think it's because they are inherently biased to think that transmission is "good" and "desperately needed."  They believe, deep down in their highly educated souls, that impacted landowners are simply speed bumps on the road to transmission "progress" and that they can figure out new ways to make landowners either acquiesce, or advocate for new transmission to cross their properties.  It's nothing but a psy op.

Nobody likes new transmission across their property.  NOBODY!  Anyone who said transmission was a great idea is either not affected, or their advocacy is being purchased with favorable treatment and ego-stroking (and cash helps, too!).

This new report (see "How Grid Projects Get Stuck" at the bottom of the page) makes conclusions about why the Grain Belt Express stalled out for so long and thinks it has now been successful.  Complete lack of accuracy!  GBE is in as much trouble now as it's ever been.  It's got its corporate head shoved too far up the Biden administration's rear end, hoping for government favors to pull itself out of the dumpster.  How much of our tax dollars will the federal government waste on a project that has never been needed?

And, speaking of need, the researchers did not seem to understand what they were told about lack of need for GBE, no matter how much people tried to educate them.  GBE, as a merchant transmission project, has not been found needed by regional transmission organizations for reliability, public policy, or economic reasons. If it had any of those benefits and its cost was less than the benefits it offered, a RTO would have ordered the project.  No RTO ordered GBE because there was no need for it, not because they are biased against outsiders.  If it's not found needed by an RTO, it is not needed.  Everyone (but the researchers) understands that.  GBE was a speculative venture, a value proposition that never could find any customers who thought it provided enough value to sign a contract.  When a project is not needed by a regional transmission planner, and it can't find any customers that think it's an economic value, then it's a completely unnecessary project.  It is like McDonald's eyeing your front yard -- GBE wants to take your front yard so it can build a transmission project for one simple reason -- PROFIT.  Not because it's needed, or because it provides economic value.  Incumbent utilities may be for profit, but they are also public utilities with an obligation to serve.  GBE is not a public utility.  GBE is only trying to create profit, not serve consumers who need electricity.

The researchers honed in on the disrespectful way Clean Line treated landowners, even mentioning the "Marketing to Mayberry" episode.  Skelly gets faulted for his approach to local governments and elected officials before landowners were even notified.  That pretty much set the tone, didn't it?  How different things might have turned out if Skelly approached landowners first and actually paid attention to their desire for the project to be sited along transportation corridors and buried.  It would be operating right now, if it had attracted customers.  Instead, Skelly and then Invenergy, just kept dumping hundreds of millions of dollars into a plan that was badly conceived from the beginning.  GBE didn't listen to landowners.

The things the researchers think GBE did wrong ultimately don't mean anything though because they picked up on the wrong things, things that wouldn't have made a difference in the long run.
  • Regulatory institutions are stacked against new players.
  • Public and regulators' understandings of public interest and public need enable parochialism. 
  • This case highlights a fundamental mismatch between the scale of costs and benefits for long-haul transmission infrastructure. 
  • The traditional model of community engagement, centered around mass meetings and evaluation of alternatives, failed to satisfy either the developer or the community. 
  • Community members are aware of alternative process models and technologies, and they anchor their judgments to their knowledge of these alternatives.
  • Public opinion favors incumbent entities and processes.​
What?  Poor, poor, rich little Michael Skelly.  Everyone was against him!  As they should have been!  He was only interested in plundering for profit.  Landowners have no use for him, and sent him packing back to Houston.  And did our slick willie friend learn anything from his failure?  I doubt it, judging from this article about his new company trying to build a transmission line through Montana.  SSDD.  You can almost smell the failure wafting its way from that article,

State regulators have a duty to consider the public impacts of new transmission.  That's not parochialism, that's doing their job.  State regulators don't work for merchant transmission companies, or electric consumers in other states.  They only work for the public in their jurisdiction.

Projects without benefits will never be accepted by impacted landowners.  Even projects with some supposed benefit for "the public" don't matter when it's your home and your money on the line.

Yes, the utility model of keeping the public uninformed until the project and its routes are set in stone is unhelpful.  Transmission developers that operate in secret fail in public.  But what's the alternative?  Would developers approach communities and ask them upfront what kind of project they should build?  That is unlikely because the whole public engagement process is built on an enormous misconception.  Developers (and researchers) believe that if they can only "educate" (propagandize) impacted communities, that they can turn opposition into support.  That is NEVER going to happen.  Nobody wants a transmission line. NOBODY.  Self preservation is always stronger than bullshit.

The road to success is staring transmission developers, big green transmission advocates, and their government flunkies right in the face.  It's a transmission project that does not need any new land.  No new land, no eminent domain, no impacts, no opposition.

First of all, we should build new power generation near the power load.  When new transmission is needed, it must be routed on existing linear easements, such as road, rail, or underwater.  Building a gigantic network of transmission lines for the sole purpose of connecting wind and solar projects to load in distant cities, and trying to use transmission to make up for the intermittent nature of these unreliable sources of electricity is not going to save them.  Remote wind and solar is an infeasible money pit.  The only thing it's been successful at is making the rich richer.

Landowners who don't want new transmission lines on their property are not a "problem" to be solved.
0 Comments

DOE's NIETC Information Inadequate for Public Comment

6/15/2024

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The Kansas Heartlander asks if residents are informed enough to comment on the U.S. Department of Energy's National Interest Electric Transmission Corridors proposal?

No, no they are not.

Last week, Missouri Senator Josh Hawley sent a second letter to Secretary of Energy Jennifer Granholm asking for clear and complete information on the NIETC proposal so that his constituents will be informed enough to make comment.  Senator Hawley also requested a 45-day extension of the comment deadline.

​Senator Hawley said...
​Constituents in my state have rightfully complained that the proposal lacks essential information needed to adequately provide comments on the plan. The maps provided are simply not specific enough. Landowners should be notified if the proposed route is going to touch their land. Instead, they are left to guess whether or not their land could be taken by the federal government. And they can only be sure that the corridor is on their land when it is finalized. 
That's because the only information the public has is a vague, not to scale map with a line drawn on it.  And the DOE has done nothing to notify citizens that they may be in a corridor.  DOE has done shockingly little press on its proposal to conscript the land of millions of Americans and turn it into high-voltage electric transmission corridors.  If not for the knowledge of a handful of watchdog citizens, DOE would be getting away with it!

It's not like DOE doesn't have the information, it's just that DOE refuses to disclose the information it used to draw its vague maps.  DOE solicited "recommendations" for corridors from greedy transmission developers back in December 2023.  DOE needs to share the information it received so that citizens can base their comments on the same information DOE will use to evaluate this proposed corridor for designation.  Citizens are drawn into a duel without any weapons.  It's absolutely shameful!

A future NIETC designation is a land use planning decision that changes the use and marketability of land in perpetuity.  Who would buy a home in a NIETC if a future transmission line is planned to destroy it?  Who would buy land and build a house in a NIETC that is subject to federal eminent domain?  How can farmers plan improvements to their businesses when they have no idea if they will even get their investment back?  It's bad enough that Missouri farmers have been threatened with Grain Belt Express for more than a decade, now the DOE is planning more transmission within a 5-mile swath of their remaining properties.  On top of that, there is no compensation offered by the DOE for property taken by a NIETC.  It's private property taken for public use, without just compensation.  The Fifth Amendment to the Constitution prohibits such a taking.  It also prohibits depriving citizens of life, liberty, or property, without due process of law, and DOE is shutting down all due process for citizens impacted by its corridor proposal.

Senator Hawley is not afraid to stand up to the DOE and demand due process for citizens.   But why are the rest of our elected officials asleep?   Bravo, Senator Hawley, and thank you for your work!  I hope other Senators are brave enough to join you!
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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.

    StopPATH Blog continues to bring you energy policy news and opinion from a consumer's point of view.  If it's sometimes snarky and oftentimes irreverent, just remember that the truth isn't pretty.  People come here because they want the truth, instead of the usual dreadful lies this industry continues to tell itself.  If you keep reading, I'll keep writing.


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