The design principles and practices that create energy resilience (or, as the Secre­tary calls it, resiliency) were first framed for the Penta­gon in 1981, and still broadly guide DoD doctrine for resilient power supplies to military bases and other facilities critical to national security. These principles do not include continued or enhanced reli­ance on inherently vulnerable powerlines hauling electric­ity hundreds of miles from remote central power stations—a system rife with single points and modes of failure re­quir­ing costly redundancies but still not fully effective, as these comments elaborate. Such grid-dependence is the largest factor preventing electric resilience.

Rather, resilient design logically starts at the customer and works back up the supply chain, seeking to make that chain as short as possible and each of its links robust, redundant, with graceful failure and quick rerouting or repair. As a lay summary of Brittle Power explained, a resilient system “has many relatively small, dis­­persed elements, each having a low cost of failure. These substitutable compo­nents are interconnected not at a central hub but by many short, robust links. This configura­tion is analogous to a tree’s many leaves, and each leaf’s many veins, which prevent the random nibblings of insects from disrupting the flow of vital nutrients.”

Thus the NOPR’s obsession with continuity of fuel supply to generators—even if 2.1–2.4’s rebuttals below were invalid—ignores the grid. Yet any rational treat­ment of electric reliability and resilience must focus primarily on the grid.
 
The Electric Power Research Institute long ago estimated, and modern data agree, that roughly 98–99% of power failures originate in the grid, and ~90–95% of those in the distribution grid. As the NOPR’s §II(A) rightly notes, Ameri­ca’s grid compris­es 707,000 miles of high-voltage transmission lines, 55,800 substations, and 6.5 million miles of local distri­bu­tion lines. All are interruptible by high winds, lightning, ice storms, tree limbs, cars crashing into power poles, squirrels, birds, operator errors, fires, solar storms, electro­magnetic pulses, cyberattacks, or rifle bullets.
 
As I write this, about three million Puerto Rican American citizens face months of further blackout, with only 16% returned to service after three weeks, because a hurricane destroyed their grid, even though their 98%-fossil-fueled utility has ample and available generating capacity with adequate fuel on hand. The NOPR is irrelevant to them and to the other Americans blacked out in Texas by Harvey, Florida by Irma, the Virgin Islands by Irma and Maria, etc. Hurricane Maria’s grid destruction in Puerto Rico alone has already about doubled in 2017 the total outage cus­tomer-hours experienced nationwide in 2016.
 
Yet the NOPR says and does nothing about the brittle grid connecting power plants to customers—only the virtual non-problem of how big a pile of coal sits at each plant. The NOPR does vigorously seek to prevent and reverse the competitive mar­ket exit of outdated plants typically sited half to several states away from cus­tom­ers, hence inherently vulnerable to grid failure. The NOPR’s effort to reverse the market-driven decentralization and diversification of historic grid depen­dence would weak­en national security: since grid failures dominate total failures, any electricity strate­gy that perpetuates and increases reliance on remote central power plants, no mat­ter how reliable they are, will increase vulnerability and reduce resilience.

The goal is to alleviate congestion on the high-voltage electric grid, and benefit customers in the region, including parts of Pennsylvania and Maryland, Transource said in a news release. 

Abby Foster, a community affairs representative for the company, said typical farming practices in both counties will be able to continue in the rights-of-way. She also said that based on the feedback from the community, Transource will use a monopole structure for the towers, instead of the lattice structure which was in the original proposal. 
“By including community members in the siting process, rather than engaging them after decisions were made, we were able to consider and accommodate many landowner requests,” said Transource Director Todd Burns.

Foster added that over the next couple of weeks the company will contact  landowners with property on the proposed route. She said during this time, owners can raise issues like potential crop loss during construction or access roads that need to be built, and negotiate compensation.
 
"They're really looking to minimize and reduce any impacts that might occur to any agricultural practices," Foster said on behalf of Transource.

The company, which has almost 40 employees, has no current source of revenue.

“You would think in eight years, you would have sort of a lull, but it’s a sort of a mad dash every day to move these projects forward,” Skelly said. “It’s more like an Ironman [Triathlon], not a marathon. It’s more like a decathlon, but it goes on for eight years.”

... neither TVA nor any other utility has signed a contract to buy the power the project would transmit.

Skelly said that while landowners’ opposition to transmission projects is “understandable,” the pushback from within the industry is more frustrating.
...................
Pointing to Commonwealth Edison’s opposition to the Rock Island project in Illinois, he said, “Why are they doing that?..."

Clean Line has worked hard in Missouri to gain community support for Grain Belt.

“You have to build alliances,” Skelly said. “We’ve got support from labor groups, environmental groups, business groups, from political leaders … doing these projects without building those types of alliances would be really, really difficult.”

Skelly has said seeking DOE authority for the Grain Belt and Rock Island lines is an option but not his first choice because it is slow and costly.

Clean Line spokeswoman Sarah Bray said Bluescape is now the company’s “principal investor,” although National Grid, ZBI and the Zilkha family have retained equity stakes.

Rock Island Clean Line: The Illinois Supreme Court opinion said that Rock Island Clean Line is not a public utility, and therefore may not use eminent domain to acquire land for its project. The Court reasoned that since RICL had claimed it has not asked for eminent domain authority, that it didn’t need it and should proceed to build its project without eminent domain authority. I urge you to read and report on the actual Opinion, instead of taking the loser’s view of the case as a fact. See http://www.blockricl.com
In addition to not being a public utility in Illinois, RICL has also been denied the ability to ever use eminent domain in Iowa through new legislation passed last year. See https://www.iowastopricl.com

Grain Belt Express: The Illinois Supreme Court opinion on RICL determined it was not a public utility. If RICL isn’t a public utility, than neither is GBE, which is an identical project that also runs through Illinois. There is currently an appeal in the Illinois 5th District Court, an opinion can come at any time. The issue in that appeal is whether GBE was a public utility at the time it applied for its CPCN at the Illinois Commerce Commission. If RICL cannot be a public utility even after receiving a (since vacated) CPCN, than GBE cannot be a public utility before it even applies. GBE is denied for the third time in Missouri, and the opponents also filed an appeal in the Western District Court of Appeals. It is unclear which court will hear the appeal, and unlikely that the Western District will be overturned. Remember, the Western District’s opinion has already been examined by the Missouri Supreme Court and let stand. These are all fatal issues for GBE.

Plains & Eastern: The Arkansas delegation met with Rick Perry again just recently. Maybe you should ask them what they think, instead of asking Skelly what they think? While Skelly reports they have bought right-of-way, he failed to mention that right-of-way acquisition stopped months ago, and a land agent told a landowner that Clean Line was stopping all land acquisition because it had “bought too much right-of-way.” Skelly also forgot to tell the reporter about the recent rejection of Clean Line’s offer of $80M to the Cherokee Nation in exchange for rights to cross the Arkansas River. Without the Cherokee Nation’s permission, P&E is sunk. The reporter also completely failed to mention the ongoing Federal court challenge to DOE’s presumption that Section 1222 gives it condemnation authority. An important hearing is coming up next month.

The current market design in ERCOT primarily places the responsibility for system costs on ERCOT customers. This docket has revealed that the Southern Cross DC tie will result in additional costs to ERCOT, which include extraordinary costs that arise specifically from the Southern Cross DC tie, the Garland line, and the Garland or Oncor substations. Because the customers of exported power are not ERCOT customers, under the current market design and rules, they will not bear any responsibility for the extraordinary costs specific to the Southern Cross DC tie, Garland line, and Garland or Oncor substations that they impose on the ERCOT system. Southern Cross believes that those customers—and therefore Southern Cross—should get a free ride as to these extraordinary costs. The Commission disagrees and determines that the public interest demands that ERCOT ratepayers should not bear any of the costs associated with the Garland line, the Oncor substation, the Garland substation, or the Southern Cross DC tie that are properly borne by others.
The costs that a user of the ERCOT system causes cannot be determined simply by focusing on the costs of the facilities on the last forty miles of a multi-thousand-mile network. There is little doubt that additional facilities will be required in ERCOT because of the electricity flowing over the Southern Cross DC tie. Southern Cross believes that the costs of those facilities should be borne by customers in ERCOT, not the out-of-ERCOT customers that cause those costs.  And Southern Cross opposed even an investigation into whether revisions to the current ERCOT cost-allocation method were needed. Southern Cross attempts to justify this free-ride position based on theoretical benefits that this project will provide to ERCOT.

The Commission agrees, however, that no party met the burden of proof to prove what benefits, if any, Texas ratepayers will enjoy as a result of the Garland line and the Southern Cross DC tie and concurs with the ALJs that any benefits are questionable.  This is one of the issues that will be evaluated by ERCOT and if subsequent investigations show any benefits, then any such benefits could be reflected in the new market-design rules. The record in this case does not justify a free ride for these questionable benefits.  Texans are in the process of paying billions of dollars for the newly constructed CREZ transmission lines, and for substantial other facilities, that are integral to transmitting electricity to the Garland line and the Southern Cross DC tie. As proposed by Southern Cross Transmission, the Garland line would simply interconnect with these CREZ lines and reap benefits without paying its fair share of costs.

Further, Southern Cross argues that the DC tie will not cause a substantial increase in ancillary services needed in ERCOT, and that no change in the current manner that ancillary costs are assigned is necessary.  Southern Cross argues that the DC tie should get a free ride on these extraordinary costs also. The Commission agrees that this is a highly technical question and has requested ERCOT to evaluate this matter. The Commission also agrees, however, with ERCOT and other parties that additional ancillary services will likely be required to support the operation of the DC tie, and at certain levels, that requirement may be significant.  And, as with the other extraordinary costs discussed in this Order, it is appropriate that the cost causer be responsible for the costs, not for ERCOT customers to bear the costs of others. The Commission does note that Southern Cross softened its position some by agreeing that it could and would provide reactive-power service through the DC tie.

One benefit offered by Southern Cross is the lowering of the price of electricity in ERCOT during high-load periods.  However, Southern Cross Transmission's analysis does not appropriately account for the effect on the ERCOT energy market, which sends market signals through scarcity pricing when electricity resources are becoming scarce. Distortions to ERCOT's market signals could prevent the energy-only market from appropriately responding to shortages, leading to inadequate resources in this market. This risk to ERCOT's market structure and the grid's reliability must be assessed and addressed through recommended changes.

Who benefits from the project? For this project, PJM projects $622 million in cost savings for consumers in 10 power zones. Those zones are listed below and displayed on the map to the right. Generally speaking, when low-cost electricity is introduced into the market, it helps drive the overall competitiveness of the electric grid for all power zones.

Benefiting Power Zones Identified by PJM:

American Electric Power Co., Inc, Allegheny Power Systems, Baltimore Gas & Electric, ComEd, Dayton Power and Light Company, Duke Energy Ohio and Kentucky, Duquesne Light, Dominion, East Kentucky Power Cooperative, Potomac Electric Power Company.

The high-voltage electric grid operates across towns, counties and state boundaries. As such, the benefit of this project is not confined
to geographical boundaries. Customer-driven improvement projects in one area of the grid can benefit customers on another part of the electric grid. For example, recent improvements made in Indiana and Westmoreland counties, more than 100 miles away, improved how the grid operates in York County.

“Anytime you have legal clouds pending, you’re not going to spend a lot of time with that uncertainty,” said Lawlor. “We’ll see how the decisions play out before we put a lot of people to work building the project.”

The ruling, Clean Line director of development Mark Lawlor said last week, would discourage renewable energy development in Illinois.
“It is clearly a setback, and a signal not only to our investors, but to other developers, on the tremendous amount of legal barriers in Illinois,” said Lawlor. “It goes beyond Rock Island. It goes beyond Grain Belt.”

The lawsuit seeks to require 36 generating units at 19 plants in upwind states to install the same scrubbers and other air-cleaning technology that Maryland requires plants within its borders to install.

Maryland's electricity consumption exceeds its net generation. Almost half of the power consumed in the state comes from the PJM Interconnection, the Mid-Atlantic regional electricity transmission grid.

The already-strong demand for imports of low-cost wind energy into the mid-South and Southeast would likely increase if and when states in the region are subject to regulations limiting greenhouse gas emissions from power plants. EPA’s Clean Power Plan, published in October 2015 and scheduled to mandate compliance beginning in 2022, aims to “continue progress already underway in the U.S. to reduce CO2 emissions from the utility power sector” and is part of a suite of air quality improvements sought by other national environmental regulations. These improvements could be accomplished through retrofitting of older generation plants, plant retirements, and an increasing reliance on local or imported low-carbon generation including renewables. The Department’s Energy Information Administration (EIA) estimates that the Clean Power Plan would result in strong growth in renewable generation, particularly in regions currently lacking robust renewable portfolio standards such as the Southeast. Implementation of the Clean Power Plan would also shift the regional fuel mix away from baseload capacity with on-site fuel supplies (such as coal, nuclear, hydroelectricity, and oil) towards capacity that tends to utilize real-time fuel delivery (wind, solar, and natural gas).  Overall, wind generation is projected to play a major role and become increasingly economically competitive. Although the EIA’s analysis did not look at the degree to which such a fuel mix would be imported to the Southeast or conduct a detailed model of the transmission system, it did find that “[c]ompliance with the proposed rule could necessitate significant investment in electric transmission system infrastructure to integrate renewables from remote areas.”

To be sure, wind power delivered by the Project will compete with other sources of renewable energy in markets in the mid-South and Southeast. But such competition is healthy, and ultimately benefits consumers and the renewable energy sector as a whole. Indeed, new transmission links such as the Project create value through their ability to foster healthy competition among generators. As the Commission has observed: “New interconnections and transmission service generally meet the public interest by increasing power supply options and improving competition.” The Commission has also explained that “as a general matter, the availability of transmission service enhances competition in power markets by increasing power supply options of buyers and sales options of sellers, [resulting in] lower costs to consumers.”