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Why Grain Belt Express is a Bad Deal for Missouri

11/29/2016

6 Comments

 
Public hearings on Grain Belt Express' most recent application (its third) to the Missouri Public Service Commission are set to begin next week.  Another huge public turnout to oppose the plan is expected. 

None of Clean Line's smoke and mirrors about project "benefits" has any basis in fact or logic.

Clean Line's proposed "income" for landowners is a huge fabrication.  Any payments to landowners are a lame attempt at compensation for property taken from landowners through the courts.  In exchange for payments, landowners would be trading rights-of-way across their property.  Eminent domain law requires the taking entity to compensate landowners for the market value of property taken from them.  It is not additional "income."  Income would allow a landowner to gain something valuable while losing nothing.  The truth of the matter is that Grain Belt Express is proposing to make landowners whole for property taken from them.  It's a wash, not a gain.  It's no different than Walmart showing up at your house and cleaning out your pantry and freezer and then giving you "market value" for the goods it has confiscated.  Meanwhile, Walmart has your food and can sell it to others for a profit.  There are no benefits to landowners from construction of Grain Belt Express.

Clean Line's claims of increased tax revenue for counties crossed is another disingenuous glittering generality.  In essence, it is a proposal that economic development opportunity trumps your right to own and enjoy property.  Everyone's house would generate more tax revenue if it was a Walmart.  Economic development alone is not reason enough to trample on private property rights.  This is even more true when looked at through the public utility lens that Clean Line hides behind.  Public utilities have enjoyed eminent domain authority when a project is necessary to serve the public.  It's a high burden that a utility must carry to demonstrate that its project is necessary to serve the public.  Simply stating that if property is taken and a project built that a public need will develop, is not enough to carry this burden to take property in the first place.  Especially when the "utility" is Clean Line, who has no firm customers for its transmission line.  It's all based on future speculation, and that's not good enough.

Clean Line's claims of increased tax revenue also fail to calculate any detriments Grain Belt Express will bring to affected counties.  Properties crossed by electric transmission lines lose value.  This lowers the assessed value of affected properties and decreases property tax revenue to the county.  In addition, the burden of hosting the transmission line will cost the county in increased public safety expenses, both during the invasive construction of the project and for years afterwards when the counties must purchase equipment and supplies to prepare for any transmission line disaster that may happen in the future.  For example, substation fires require different types of equipment and special chemicals to fight.  Counties could spend their entire "windfalls" supporting Clean Line's infrastructure in their locality.

Clean Line's claims that its Grain Belt Express project will save Missourians $10M a year in energy costs is not based on fact.  Although Clean Line witnesses make this claim in testimony to the PSC, there is nothing to back it up.  No analysis, no numbers.  Based on documents made public months ago, the $10M claim was concocted by Clean Line when it attempted to sell its capacity to Missouri municipalities.
Preliminary calculations, assuming existing production tax credits for wind project participation in the project, could reduce costs by as much as $10M/year or $10 per megawatt hour compared to delivery of other wind projects from SPP to MISO.
Preliminary calculations?  Clean Line's calculations, which have yet to be revealed to the public.  "Assuming existing production tax credits" assumes too much.  At the end of this year, the production tax credit will begin phase out and the subsidy for wind energy will be cut 20%.  The following year it will be cut 40%.  The next year it will be cut 60%, eventually disappearing altogether within 5 years.  Couple this with our friend Bob from the Hannibal BPW's recent statements that he has yet to contract for any wind energy to serve the City of Hannibal.  That's because the generators Clean Line says will develop to use its project haven't been constructed yet.  The only thing Missouri municipal utilities have tentatively contracted for with Clean Line is transmission capacity, not energy.  Energy must be purchased separately, and come from the specific geographic area close to Clean Line's proposed converter station in southwest Kansas.  It's not about purchasing the cheapest wind energy available in today's market, it's about speculation with unbuilt generators to supply energy via an unbuilt transmission line.  Too many variables to accurately calculate any cost savings to Missouri, since Clean Line cannot and does not sell any energy proposed to be transmitted to Missouri via its project.  How was this $10M "savings" calculated when there are no energy prices to work with?  Sort of looks like Clean Line simply made it up out of hypothetical numbers presented in a light most favorable to Clean Line.  But, hey, at least the Missouri municipalities have the option to back out of their "contract" with Clean Line at any time in the future and purchase nothing.  If cities sit around waiting for Clean Line to ship them energy from generators that don't exist, at prices that have no basis in reality, then the cities may get stuck paying much higher prices to procure energy down the road if nothing develops and they're left without enough resources to serve customers.  Coulda, woulda, shoulda... by law, utilities are required to have adequate resources under contract, not base their future service on hypotheticals.

And simply parading a collection of politicians and business interests who stand to personally profit from the construction of the project isn't support based on fact and logic.  It's based on money, pure and simple.

True grassroots opinion based on fact and logic cannot be bought.  True grassroots opposition will drown out expensive, manufactured "support" and will carry the day at the upcoming public hearings.  Won't you lend your voice?

The public hearing schedule:
 
Dec. 7, 2016: Monroe City
Knights of Columbus Hall, 424 South Locust
The local public hearing will begin at 12:00 p.m.*

Dec. 7, 2016: Hannibal
Theater Auditorium, Hannibal-LaGrange University, 2800 Palmyra Road
The local public hearing will begin at 6:00 p.m

Dec. 8, 2016: Marceline
Walsworth Community Center, 124 East Ritchie
The local public hearing will begin at 12:00 p.m.*

Dec. 8, 2016: Moberly
Moberly Municipal Auditorium, 201 West Rollins
The local public hearing will begin at 6:00 p.m.

Dec. 13, 2016: Cameron
Cameron Community Center, 915 Ashland Avenue
The local public hearing will begin at 12:00 p.m.*

Dec. 13, 2016: Faucett
Mid-Buchanan High School, Multipurpose Room, 3221 SE Route H
The local public hearing will begin at 6:00 p.m.

Dec. 14, 2016: Polo
Community Center at Stagecoach Park, 1010 Main Street
The local public hearing will begin at 12:00 p.m.*

Dec. 14, 2016: Carrollton
Rupe Community Center, 710 Harvest Hills Drive
The local public hearing will begin at 6:00 p.m.
 
*In order to be able to move equipment to the next local public hearing that same day, 12:00 p.m. local public hearings will end no later than 4:00 p.m.
 
For more very important info. please visit Block GBE-MO.
6 Comments

Can You Smell the Fear?

11/17/2016

3 Comments

 
“Mr. Trump talks about infrastructure, he talks about jobs,” said Michael Skelly, founder and president of Clean Line Energy Partners, a company based in Houston that builds transmission lines for renewable energy.

“What we’re creating are welding jobs, steel manufacturing jobs, in Kansas, Oklahoma, Iowa,” he said. “These are projects that create income for landowners, create jobs in the middle of the country.”

Smells like fear to me.  Clean Line Energy Partners talks a big game, but the very fabric upon which their arrogance and contempt for Midwestern landowners has been built over the past 7 years has been ripped asunder.  A new regime is taking shape, and no matter how Skelly tries to remake himself at this late stage, he no longer has any leverage.

There's a whole bunch of chatter from these arrogant blowhards about how Republicans support clean energy, or about how Republicans support things like jobs, infrastructure and economic prosperity.  But Clean Line's projects don't measure up.

Jobs?  Skelly thinks his overly expensive and invasive "infrastructure" projects should be built because they would "create" welding and manufacturing jobs?  Building Clean Line would be temporary, while its detrimental effects would last a life time.  For every temporary "job" created by Clean Line, many more small businesses and family farms would either be destroyed or have their productivity impacted.

And for what?  Not for the personal wealth of landowners.  Landowners have resoundingly rejected Clean Line's compensation offers in all impacted states.  Compensation... that's right, it's not "creating income" for landowners, Clean Line's offers are lame attempts at compensating landowners for their loss of property.

Energy imported via a Clean Line could impact long-time energy generation jobs in "beneficiary" states.  If you believe Sierra Club's rhetoric that Clean Line would "shut down coal plants" then along with that comes a whole bunch of displaced workers.  Are they supposed to pick up and move to the Midwest to get a new job manufacturing steel?  Or welding things for a couple of years before they're back in the unemployment line?

It's all about sustainability.  Energy should be local, and it can also be "clean."  Sustainability means that no one is harmed by an energy project.  Clean energy may be good, clean energy may be cheap.  But not when it depends on taking something from one part of the country to give it to another.  Not when it depends on building billions of dollars of monstrosities to get it to market.

So, while Republicans may support clean energy, and they may support infrastructure, it doesn't mean they automatically support gigantic and expensive for-profit boondoggles like Clean Line.  In fact, all the Trumpesque blather about "infrastructure" specifically talks about transportation infrastructure.  When it comes to energy, a Trump administration promises to
...scrap the $5 trillion dollar Obama-Clinton Climate Action Plan and the Clean Power Plan and prevent these unilateral plans from increasing monthly electric bills by double-digits without any measurable effect on Earth’s climate. ​
And furthermore, it states
He will defend Americans' fundamental rights to free speech, religious liberty, keeping and bearing arms, and all other rights guaranteed to them in the Bill of Rights and other constitutional provisions.  This includes the Tenth Amendment guarantee that many areas of governance are left to the people and the States, and are not the role of the federal government to fulfill.
Such as state transmission permitting and siting laws, which have been circumvented using the federal Department of Energy's trumped up federal eminent domain authority under Section 1222 of the Energy Policy Act?  Good riddance to bad rubbish!

It looks to me like Clean Line is on the verge of hysteria over their sudden reversal of fortune under a changing regime in Washington.  
"Election Day was a big sea change in America," Jimmy Glotfelty, executive vice president for Clean Line Energy Partners, told the TVA board last week. "But we believe that just because we've gone from Democrats to Republicans (in the White House) that does not change the need for jobs and low-cost energy in America and we believe we will provide that. We've been before this board for the past seven years and our project dynamics have not changed."
But it does change, Jimmy, and you looked pretty overwrought as you were trying to convince the TVA board that nothing has changed.  You've been trying to sell your project to the TVA for 7 years, but they've resolutely ignored you.  That certainly won't change.

Remember, whatever the shade of lipstick you slap on your pig, it's still a pig.

Clean Line is in big trouble.
3 Comments

Clean Line Deathwatch

11/15/2016

10 Comments

 
Arkansas Business reports this morning that Clean Line "preferred vendor" General Cable is likely to shut its doors before it actually manufactures any cable for the long-delayed project.
Picture
Being a "preferred vendor" didn't help General Cable.  Being a "preferred vendor" isn't useful on a project proposed by a company with no financing, no revenue, and no customers.  It's pie in the sky empty promises, and any company whose financial success depends on "contracts" with Clean Line is probably in big trouble.  This may be just the tip of the iceberg.

Clean Line got a huge kick in the jimmies last week when wind turbine-hating Donald Trump was elected President.  The company's business plan depended on eastern utilities being forced to add huge amounts of renewables to their portfolios that could only be supplied by big Midwestern wind and new transmission lines.  First it was a federal carbon tax, which never came to fruition.  Then it was state renewable portfolio standards, which ended up favoring local resources, instead of long-distance imports.  Then it was the EPA's Clean Power Plan, currently tied up in the courts and not expected to survive.  There's no incentive for eastern utilities to buy huge amounts of new transmission capacity to import hypothetical renewables thousands of miles, and it's not looking like customer interest in a "Clean Line" is going to rebound during a Trump administration.  If you think Clean Line struggled to find customers over the past 8 years, its future is even more grim now.

Despite the initial threat of mass public temper tantrums, which has now morphed into false bravado, big wind is in serious trouble.  Do they think that just saying they're already too committed to their grandiose plan to stop now is going to make a difference?  And, hey, how about those current claims that big wind is so economic that they don't even need the subsidies they think they have locked down for the next 4 years?  If big wind is so economic, I challenge them to stop taking the handouts they obviously don't need, which is estimated to cost the U.S. taxpayers $14.5B through 2025.  To add insult to injury, most of this taxpayer largesse is funneled out of the country to foreign wind companies.  On a state level, wind incentives cost state taxpayers millions to lower the cost of power that is shipped out of  state and provides absolutely no benefit to state residents.  In fact, shipping more power out of an export state causes power prices in the state to rise.  It's simple supply and demand.  Oklahoma seems to be on the brink of cutting this huge drain on its taxpayers.  Other states may soon follow suit, and add repeal or reform of renewable portfolio standards to legislative goals.  The Trump phenomenon caused plenty of Republican trickle down into state legislatures and change is pretty much guaranteed.

Policy moves with the speed of a glacier in Washington, DC.  It's taken 8 years for the present administration to greenwash big wind into existence.  Over the next 4 years, the new administration is going to systematically dismantle and cripple it because it can't perform without subsidies and favorably biased policy.  Big wind probably won't survive because economics and better ideas will remake our energy future in the short term.  The void must be filled, and progress waits for no man.  Midwest wind powering the entire country was never a good idea and it's doubtful it can sustain itself during this period of uncertainty.  Right now, we're all in a holding pattern, waiting to see what happens, and utilities are no different.  But they will adapt and quickly find new ways to tweak policy to complement their bottom lines, without big wind.

Adaptation probably won't include paying a premium for new transmission lines.  Factually baseless, bogus claims of big wind front groups and their sycophants cannot stop the inevitable.
If you’ve never heard of the Global Sustainable Electricity Partnership before, join the club. It has the potential to influence rapid change in the global energy sector...

The exclusive organization (by invitation only) characterizes itself as “an entity with a unique operational knowledge of the electricity sector:”

Among the group’s four main recommendations is this one:

"Make urgent progress with innovative research, development and demonstrations of advances economically viable technologies that will reduce greenhouse gas emissions and accelerate the efficient generation, delivery and end ‐ use of electricity."

That goal dovetails neatly with U.S. Department of Energy initiatives under the Obama Administration. Many of these are already under way and are virtually irreversible. In some states they enjoy strong support from Republican policymakers. One good example is the 720-mile Plains & Eastern transmission line. It will deploy GE transformer stations for the economical delivery of 4,000 megawatts of wind power, sourced from wind farms located in the “red” state of Oklahoma.

These big city sycophants are only kidding themselves if they think that "recommendation" insures Clean Line will survive.  Clean Line is the antithesis of the stated goal.  It's not economic and it is not efficient new technology.  The U.S. Department of Energy's goals will change considerably under new leadership, putting its Sec. 1222 ad hoc "program" in jeopardy. What has been a corrupt process under the current administration is not "virtually irreversible." I hope lying to themselves about where Clean Line is headed provides the safe space they need for their cry-in.  The reality of Clean Line is that it is also "enjoying" strong opposition from Republican policymakers in "red" states, such as Arkansas.  Even in Oklahoma, where the Governor has previously been supportive, continued financial support for wind exports is on the chopping block. 

The globalization of America has come to a screeching halt.  Only one company in the mentioned "Partnership" is an American company, and it only supports big wind if it can make some big bucks building and owning its own little cash cow wind projects.  There's no room in there for Clean Line Energy Partners.  Maybe they should start courting the other foreign "partners" and move their operations overseas?

They're dead here.  Middle America is tired of having its fate dictated by greedy foreign corporations and their elite policy wonks in Washington, DC.
I fear all we have done is to awaken a sleeping giant and fill him with a terrible resolve.
Isoroku Yamamoto
Damn right.
10 Comments

Meanwhile...

11/9/2016

6 Comments

 
...down at Clean Line headquarters...
Whatever your day is like, remember to be kind.
6 Comments

"Clean" Line's Dirty Little Secret

11/2/2016

4 Comments

 
I have a very good friend who always puts the word "clean" in quotation marks when writing about a certain transmission line.  She's been doing it for years.  She knew something Clean Line has only publicly admitted recently... that "Clean" Line's transmission projects would carry dirty energy.

This really isn't news.  It was first reported by the folks in Arkansas several months ago when they found "Clean" Line marketing their Plains & Eastern "Clean" Line to eastern utilities as a way to ship fossil fuel power between regions and expand its market.

Now "Clean" Line admits its Plains & Eastern project will only carry wind energy an average of 60% of the time, and is marketing the other 40% of its capacity as an arbitrage opportunity to be resold to shippers of other kinds of power.

"Clean" Line is so desperate for customers right now, they don't care what the line is used for, as long as someone, anyone, buys some capacity.

Let's take a look at Mario Harturdo's recent presentation at a United States Association for Energy Economics conference.  He expounds on the Mid-South and Southeast's "strong demand for renewable energy."  Except that can't be right.  If there was a "strong demand" then maybe "Clean" Line would have had customers pushing and shoving to get in line to purchase its capacity for years.  Instead...
So, what's the problem?  "Clean" Line can only sell capacity on a hypothetical transmission line that can't get off the planning page.  Sure, utilities will add renewables to their portfolios, but the utilities want firm pricing and the assurance that the resource will be there when they need it.  "Clean" Line can provide neither.

Here's "Clean" Line's "business model."
Converter stations function as on- and off-ramps; generators connect to the on-ramp and load- serving entities receive low-cost wind power at off- ramps

Clean Line will sell transmission service to shippers via long term transmission contracts -
Those who use the line, pay for it

Except it's only "low-cost wind power" approximately 60% of the time.  Shippers?  What shippers?  I haven't seen one generator develop and market themselves as a Clean Line shipper.  But, but, but... "Clean" Line had so much "interest" to its open solicitation in 2014, and everyone was just waiting for DOE participation to get their deals arranged within mere days or weeks of the March decision.
Clean Line Energy has lined up firm commitments for about 100 MW thus far, but it has term sheets for more than 3,500 MW that outline key terms for negotiating with customers following DOE’s decision, Kottler told TransmissionHub.

Although the project has a couple agreements with utilities to take wind power through the transmission line if it is built, many utilities and interested companies have been waiting for DOE’s ruling before making such commitments, Michael Skelly, president of Clean Line Energy said during the March 25 conference call.

“We’re seeing vast and strong indications of interest” and Clean Line Energy will firm up commercial support for the project in the coming days and weeks, with the DOE decision an essential part of moving those discussions along, Kottler said.

Many parties in the Southeast have been waiting for DOE’s decision to reach a deal with wind project developers, Skelly said during the conference call. During a 2014 solicitation, more than 15,000 MW of wind projects expressed an interest in using the Plains & Eastern project to move energy to markets in the South and Southeast, he said.

And after all this false bravado, Clean Line has yet to announce agreements with any customers.  And Harturdo's October presentation at USAEE tells the story... Clean Line "will sell" transmission service.  Not that it has sold it, or that it's in the process of selling it... but that it "will" at sometime in the future.  How long is everyone supposed to wait for this to happen?  How many more years do landowners in Oklahoma, Arkansas and Tennessee have to have this cloud on their property while Clean Line tries to sell transmission service to all the folks it previously claimed were anxiously chomping at the bit to sign up?  I'm thinking maybe Clean Line exaggerated, and that maybe there really isn't that much constructive interest in the project.

So, "Clean" Line seems to have changed the product they're marketing to appeal to a wider customer base.  Instead of marketing itself as a "clean" 100% wind energy transmission line, now the company claims it will be "clean" only 60% of the time.

Plains & Eastern can transport market power when the wind is not blowing
Average line utilization from wind power will be around 60%
Remaining capacity available for SPP market power delivery to MISO or PJM
Possible use of unused capacity:
• Solar
• Arbitrage opportunities

SPP market power?  I'm guessing they mean electricity from coal and gas-fired power plants in the Southwest Power Pool region.  And do you know what that means, Sierra Club?  It means your precious "Clean" Line will be extending the life of, and expanding the markets for, coal-fired power plants in the SPP region, to the tune of nearly half of its 4,000 MW capacity.  That's nearly 2,000 MW of coal-fired power plants that would stay online because "Clean" Line is built, instead of gradually being squeezed out by additional wind power being added to SPP's market.

And of course it means the name "Clean" Line is no longer honest.  I think we need to help them come up with a new name for their company so they can rebrand.  How about "60% Clean" Line?  or "Really only half-Clean Line, because we always exaggerate"?  Maybe they should go with the simpler "Rich investors' cash toilet"?  I've even got the perfect slogan - "Flush your climate change guilt away and cleanse your soul!"

And let's talk about that arbitrage thing... "Clean" Line thought it was so special, it gave arbitrage its own page in their USAEE presentation.  What is arbitrage? 
the simultaneous buying and selling of securities, currency, or commodities in different markets or in derivative forms in order to take advantage of differing prices for the same asset.
In other words, making money out of thin air.  The arbitrager isn't manufacturing a product or adding value... it's simply buying cheap and reselling it to someone else at a higher price.  "Clean" Line is now marketing its transmission line as an "arbitrage opportunity."
Arbitrage opportunities exist between RTOs that are connected through P&E even when including additional transmission service

Utilizing unused capacity to take advantage of these arbitrage opportunities create additional value to the owner of the transmission capacity

Market power arbitrage could yield up to $60 million a year, assuming perfect execution on unused capacity up to 1000 MW of OK-TN service and 500 MW of OK-AR service over the entire project

Positive market power price differentials are valuable when delivering SPP power to PJM or MISO, whichever is higher priced, including non-firm transmission costs and losses, and negative differentials are valuable when delivering PJM or MISO power, whichever is lower priced, to SPP including non-firm transmission costs and losses

So, the "perfect executioner" would buy capacity for the sole purpose of using it to trade power between regions in order to take advantage of cheap power and artificially inflate prices.  Isn't this how Enron got into trouble?  "Clean" Line is suggesting that its customers should buy its capacity for the sole purpose of selling a cheap commodity into a higher priced market.  It's not about reversing climate change, it's about a greedy way to make money taking advantage of electric consumers.  The $60M produced by "arbitrage" comes out of the pockets of electric consumers.

"Clean" Line's presentation demonstrates that it's nothing but a cash cow dressed in a green sheep costume.  And it's also an admission that this company is still having a very hard time finding customers for its pipe dream.

"Clean" Line will never happen without customers.  Despite the company's claims that it is "negotiating" and "building" its project, it can't build anything until it has customers.  That was one of the significant conditions in the DOE's "Participation Agreement."  The DOE requires the company to have firm customers (as opposed to hypothetical "interest" or open ended "contracts" that allow escape) before DOE will participate in land acquisition.  This means that "Clean" Line is on its own acquiring easements, and the vast majority of landowners have refused to grant easements.  Only after Clean Line has firm customers will the DOE attempt to negotiate with landowners voluntarily.  My understanding is that landowners will have a whole new opportunity to negotiate directly with DOE before eminent domain use is even considered.  Clean Line is stuck for now, because it has no authority to condemn property (and neither does the DOE, according to the lawsuit filed by Arkansas landowners).

And speaking of the Participation Agreement, it sort of looks like Clean Line's 60% "clean" admission violates the Agreement.

8.27 Renewable Energy Transmission. At any time during which any Transmission Services Agreements are in effect, the Clean Line Entities shall use all commercially reasonable efforts to ensure that at least 75% of the total Electrical Capacity covered by all Transmission Services Agreement that are then in effect to be covered by Transmission Services Agreements used for the transmission of renewable energy resources; provided that, to the extent the transmission of energy from non-renewable resources is required by Applicable Law (including pursuant to any open access tariff rules), such events would not render the underlying Transmission Services Agreement from being disqualified toward the 75% threshold.

The DOE requires at least 75% of the capacity be used for renewable energy, not the 60% Clean Line is now claiming will be used for renewables.  Of course, it does say "commercially reasonable efforts" shall be used.  I guess this means that "Clean" Line's renewable transmission pipe dream is not commercially reasonable.  In other words, not only can't they produce it, they also can't sell it.

Instead of focusing on the real problem of Clean Line's lack of customers, the company is dishonestly trying to make landowners think its project is being built so they will feel trapped into signing easement agreements. 

"Clean" Line's lack of customers makes it dirtier and dirtier with every day that goes by.
4 Comments

Ut-oh, GE!

11/2/2016

0 Comments

 
Well, whoop-de-diddly-doooo, Clean Line belched another huge cloud of public relations smoke yesterday designed to cover up the fact that it's going nowhere fast.

Clean Line has entered what it describes as a "partnership" with GE to build three AC/DC converter stations for its beleaguered Plains & Eastern Clean Line project.  Partnership?  I don't think so, because it sounds more like Clean Line simply hiring a supplier.... a supplier it has no money to pay.
This will be GE’s first HVDC project in the United States since acquiring Alstom’s energy portfolio last year. This addition to our portfolio was critical.
GE... trying to breathe new life into bad ideas.  This project, so "critical" to GE's business, has a long, long way to go before building anything.  I wonder if GE has read Clean Line's "Participation Agreement" with the U.S. DOE that requires the company to have financing in place before proceeding?  In order to get financing, Clean Line would need customers.  There are no customers for Plains & Eastern.  Where does GE think Clean Line is going to get the money to pay them for 3 converter stations?

I wonder if GE has heard about the lawsuit filed in federal court that alleges the U.S. DOE exceeded their statutory authority in their review and agreement to "participate" in this project?  Does GE know that the U.S. DOE does not have the authority to condemn and take easements for a Section 1222 project?  And without easements, there's no place for Clean Line to build anything.

Yeah, good luck with that, GE.

But, hey, at least GE beat rival Siemens to a worthless contract with a company that can't get its projects off the ground.  After years of patsy Siemens stumping for Clean Line in Arkansas, Clean Line dumped them and inked a contract with their rival.  And how awkward are things going to get in Houston, doing business with two rival companies?  Clean Line announced years ago that it had signed an "exclusive agreement" with Siemens to develop, design and implement the converter stations for its Rock Island project.  Now that Clean Line and GE have become the Plains & Eastern converter station Bobbsey Twins, is Siemens' Rock Island converter station "agreement" about to be reneged?  I'd have to think that GE must have given Clean Line a much better price for the Plains & Eastern converter stations than Siemens, and, if so, why is Clean Line content to pay more for Siemens converter stations for Rock Island?

Ahhh... the kerfuffles that can ensue when a company signs "exclusive agreements" to obtain supplies from vendors years in advance of final engineering.  Who does that?  Probably not the majority of transmission owners, who prefer to source a project competitively when they're actually ready to build and have financing in place to back up any contracts that they sign.

Or is this just the tip of the iceberg?  Will we now see Clean Line jettison a whole bunch of "exclusive agreements" when the rubber finally hits the road?

And I do wonder if GE will be required to use local labor to build the converter stations?  Since GE's real muscle is the former French company Alstom (gobbled up in 2015), will the actual components be built in France and merely shipped to U.S. sites for assembly by GE contractors?

None of this ridiculous fanfare about GE contracting to supply the converters is even necessary.  Other transmission owners don't need to drum up media interest every time they sign a contract with a supplier.  Clean Line does it because it allows them to hide behind a cloud of smoke and pretend their projects are making headway, instead of answering the hard questions, such as:

Where are the customers?
0 Comments

WV PSC Follows Utility Lead

10/28/2016

1 Comment

 
It's really not surprising that our West Virginia Public Service Commissioners continue to fail at leading utilities to act in the best interest of the state's consumers.  In a state where Public Service Commission appointments are looked at as political favors, an ill-informed and uninspired regulator continues to march to the beat of utility profits.

Recently, the WV PSC dismissed a petition filed by its own staff and the WV Consumer Advocate to require electric utilities Mon Power and Potomac Edison to issue a Request for Proposals before buying another generator from its parent company in an intimate and opaque non-arm's-length transaction.

The WV PSC found the petition "premature" because the companies have not yet filed an action to purchase more generation.

The PSC previously rejected a motion by the same parties to require the companies to issue an RFP for new generation it claimed would be needed in its Integrated Resource Plan last year.

The PSC contends that the requirement to file an Integrated Resource Plan does not allow the PSC to approve or reject a utility's plan, therefore it must powerlessly follow a utility's lead.  The PSC also contends that the companies' promise to issue an RFP for new generation that was part of its settlement in the case that allowed its last inter-company purchase of generation has not been triggered.  The WV PSC sits trussed up on the floor like a prisoner, unable and unwilling to act in the best interests of West Virginia's electric consumers, completely useless.

It's word soup and double standards that has the PSC ineffectually sitting on their hands.  The last time the companies needed to purchase generation in an internal transaction (Harrison), they claimed there just wasn't time to issue an RFP because the need was way too urgent.  If that was the case, then the utilities had not planned correctly.  The settlement that allowed the purchase of Harrison required:
If the Companies determine in any annual PJM Base Residual Auction (“BRA”) that their combined capacity obligations for the delivery year covered by the BRA (“Delivery Year”) exceed the Companies’ owned or contracted-for capacity resources for the Delivery Year by 100 MW or more (“Capacity Shortfall”), then not later than the end of the calendar year following the BRA, the Companies will develop an RFP for capacity resources to address the Capacity Shortfall and submit the RFP to the Commission and the Parties for their review and comment. The RFP will allow proposals from both supply-side and demand-side resources.
Everyone hoped that the companies would honor this commitment.

However, the companies turned around and filed an Integrated Resource Plan contending a generation shortfall.  In that filing, the companies used a different method to calculate the shortfall that did not depend on PJM's Base Residual Auction.
Mon Power’s Long Term Load Forecast indicates a capacity shortfall starting in 2016, with the shortfall exceeding 700 MW by 2020 and extending to over 850 MW by 2027.
While PJM's auction may not require the companies to acquire more generation, the companies used a different method to calculate a shortfall, and then claimed that it was not required to issue an RFP because PJM's auction didn't indicate the same shortfall.

And the WV PSC let them get away with it!  If the PSC wants to use the companies' method to calculate generation needs, then it should never have approved the settlement stipulation that used PJM's method.  Conversely, if the PSC approved the stipulation that used PJM's method for calculating generation needs, then it should never have allowed the companies to use a different method in its Integrated Resource Plan.  They simply can't have it both ways!  Either they have a generation shortfall, or they don't.  The WV PSC needs to quit dithering and sitting on its hands.

FirstEnergy has made it perfectly clear that it intends to make Mon Power and Potomac Edison purchase the Pleasants power station.
We will continue to seek opportunities both within the competitive realm and the states to further de-risk the business and convert megawatts from competitive markets to a regulated or regulated-like construct.

We also plan to work with the West Virginia Public Service Commission when they are ready to address the generation shortfall included in Mon Power's integrated resource plan.

So we previously filed the IRP. It showed a need for generation going out a couple of years from now. But that case right now is concluded. So there is nothing that would, unless we were to file something, initiate something, that would come out of that case. So we would be looking as we go forward and continue to monitor the forecast for that company to see how we might want to present something consistent with the IRP in terms of bringing additional generation to Mon Power.

Michael Lapides - Goldman Sachs & Co.

Got it. So there's no formal like RFP process that's about to kick off or that will be undertaken in 2016 or 2017?

Leila L. Vespoli - Executive Vice President, Markets & Chief Legal Officer

Correct. There's no time line associated with that. We would initiate it when we believe it to be the appropriate time.
FirstEnergy management arrogantly tells its investors that it alone controls the timeline in which the WV PSC may examine its upcoming request to have Mon Power and Potomac Edison purchase more generation from the parent company.  Only FirstEnergy will decide when the time is appropriate to create another "urgent need" that the PSC must approve without initiating a fair and transparent competitive process.

The WV PSC needs to stop behaving like FirstEnergy's dog on a leash and start doing its job as a regulator tasked with balancing public and private interests to effectively serve the state's consumers.  Maybe the political appointees at the PSC need to find out what their job actually entails?  I think they all need to read this book.
The decisive regulator makes decisions (1) required by the public interest, (2) when the public interest requires it, (3) regardless of discomfort felt, (4) using a logical method and an active approach.
As long as the WV PSC continues to behave like a lapdog, FirstEnergy will continue to toss West Virginians under the bus for benefit of its company and investors.
At this time, however, we do not see any short-term solutions to the current challenging market situation. Longer-term, we do not believe competitive generation is a good fit for FirstEnergy and are focused regulated operations. And we cannot put investors and our company at risk as we wait for the country and PJM to address the issues with the current construct.
Our PSC should be refusing to put West Virginians at risk!  Let's hope they figure out what it is they're supposed to be doing before we're stuck with another costly, outdated generator.
1 Comment

Wind War

10/25/2016

1 Comment

 
The wind industry is at war with itself, and the prize is your energy dollars.

Buoyed along by "green is good" propaganda, big wind players battle with each other to capture a bigger share of your monthly electric bill.  At its most basic level, it's not about stopping climate change, it's about getting rich by capturing the political market for green energy.  Being first to build and secure customers makes a winner in today's wind war.

The amount of energy we use hasn't changed much over the last decade.  While we have more electronic gadgets than ever before, they use less electricity.  Power hungry manufacturing operations have been shipped overseas.  Any gains are offset by increased efficiency and conservation.  While traditional electric utilities are struggling, a new crop of wind energy peddlers have emerged to claim that they can shut down fossil fueled energy plants and completely remake our energy system.  This isn't necessarily true, and the price to do so is mind boggling.  We simply can't afford it.

While that debate publicly rages, big wind's internal war doesn't receive much notice.  Land based wind is at war with offshore wind to fuel eastern renewable energy requirements.  While offshore wind may be more expensive to build, it's conveniently located close to eastern load.  And while land based wind may be cheaper to build, it requires billions of dollars worth of contentious new transmission lines to get to eastern markets.

Land based wind has enjoyed quite the hey day over the past decade, but populations near land based wind's most prolific locations have reached saturation.  There's only so much wind our energy system can reliably use.  The companies who struck it rich cluttering the Midwest with wind farms, and pocketing billions in tax subsidies for their efforts, now need to create new export markets for their product in order to continue shaking the energy piggy bank for all it's worth.

Offshore wind has struggled over the last decade, with high prices and political opposition to local energy infrastructure.  The east coast has enjoyed plentiful cheap energy for the past 100 years at the expense of states in the Ohio Valley, who were only too eager to plunder their own communities to become energy exporters.  Now that the will to continue to foul their own nest has softened in the Ohio Valley, eastern states must look elsewhere for energy.  What's closer and more reliable than their own backyard?  Government-created wind maps consistently show greater wind energy potential offshore.  Offshore wind has greater potential.  "Offshore wind resources are abundant, stronger, and blow more consistently than land-based wind resources."  The only thing missing has been the political will to get started.

America's first offshore wind farm is scheduled to go online this month off the coast of Rhode Island.  And Rhode Island is reveling in the economic benefits of producing its own renewable energy, rather than sending its energy dollars out of state to import power from other areas.
The wind farm is a construction story, involving three of Rhode Island’s major ports — in Providence, Quonset, Point Judith — and more than 300 blue- and white-collar workers.

Jen McCann, the director of United States coastal programs at University of Rhode Island’s Coastal Resources Center, says the northeast is “considered the Saudi Arabia for wind.” J. Timmons Roberts points to the fact that Rhode Island imports more than $3 billion a year in fossil fuels to meet its energy needs. “So that’s $3 billion pouring out of our economy to Pennsylvania for fracked natural gas, or to Texas or Saudi Arabia or Venezuela,” he says. “Think of how many jobs you can make for $3 billion,” he says. The United States Department of Energy is already doing some of those calculations. In a recent report, the DOE has predicted the United States will have 32,000 offshore wind-related jobs by 2020 and more than 170,000 by 2050.
But DOE is no hero.  The political agency has been fomenting the country's wind war by also supporting the building of transmission to import Midwestern land based wind to eastern states, like Rhode Island.  In its attempt to support an "all of the above" energy portfolio, DOE has placed itself in the position of political kingmaker by creating advantages for land based wind in order to make it more marketable.

While offshore wind digs in a toehold, Midwestern wind ratchets up a hysterical campaign to capture budding eastern renewable markets through the building of thousands of miles of new high voltage transmission lines to the east coast.  Calling themselves "the Saudi Arabia of wind," Midwestern states are eager to export their wind energy to the east and suction economic development and energy dollars out of those states.  The Midwestern media continues to pump out propaganda insinuating that the Midwest is a superior energy source and that new transmission to export it will rebuild an aging transmission grid to increase reliability.
A wind resource map, published by the U.S. Office of Renewable Energy, illustrates the windiest real estate in America. A vertical violet streak down the nation’s midsection indicates persistent, intense winds concentrated in places like western Kansas, Oklahoma, and Texas. And a private company, called Clean Line Energy Partners, plans to tap that for electricity it can immediately transport to utilities requiring a bolus of alternative energy in their portfolios.  

Clean Line Energy Partners, LLC — established in 2009 and headquartered in Houston —  has laid out five 600-kilovolt, direct current power transmission lines across the U.S. CLEP aims to bolster our aging national power transmission grid starting with The Plains & Eastern Clean Line that's designed to deliver 4,000 megawatts of wind energy from western Oklahoma to the Tennessee Valley Authority for distribution to southeastern markets.

This is a lie.  As the DOE's own maps indicate, offshore wind is a superior source of wind energy.  Furthermore, reliability of the transmission grid is a non-political function of government regulators who plan and order needed transmission.  None of Clean Line's proposals have been vetted by grid planners and are not included in any plan for grid reliability.  We don't need independent actors "bolstering" grid reliability for their own profit.  But DOE believes it has found a "need" for one of Clean Line's projects, although it has no role in planning the transmission grid.  Our grid isn't as rickety as outfits that stand to profit building extraneous transmission want you to believe.  Our grid is more than adequate, and upgrades are performed when needed.

Eastern states are already thick with west to east transmission lines that have imported Ohio Valley power to load centers for decades.  With a new source of power located within 10 miles of shore, very little transmission work needs to occur to interconnect offshore generators to the existing system and begin shipping power from east to west.  The tricky part may be bringing offshore generation to interconnection points on land.
...Narragansett officials resisted plans for the wind farm’s cable to run underneath its town beach. Deepwater Wind, the company building the wind farm, eventually got clearance to send the cord under Scarborough State Beach instead.
If each offshore wind farm requires its own onshore connection, it's going to be expensive.  And we're soon going to be choked with underwater cables.  A better idea was announced way back in 2010.  The Atlantic Wind Connection proposed an offshore "trunk line" of its own running parallel to the east coast, with just a handful of onshore connections.  Offshore generators would connect to the trunk line, instead of going to the trouble and expense of building their own cables to shore.  But what's happened to this idea?  It's been torpedoed by eastern grid planner PJM Interconnection, who got too busy protecting the financial interests of its incumbent utility members, who fear losing market share to offshore wind generators.

Who's protecting consumer interests here?  It's not the wind industry.  It's not the U.S. DOE.  And it's not regional grid planners.  In many instances, it's the consumers themselves.  Landowners across the Midwest are firmly opposed to the taking of their homes and farms to make way for thousands of miles of new transmission headed to the east.  Opposition has delayed these bad projects for years and is showing no signs of weakening any time soon.  But consumers in eastern states need to do their part, too.  We should be encouraging and supporting  the burgeoning offshore wind industry which will bring economic development to our states and keep our energy dollars at home.  Let's end this wind war in our own best interests.
1 Comment

Clean Line Closing in on Darkened Lounge Journalism

10/19/2016

5 Comments

 
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Well, isn't that nice?  Clean Line's Mark Lawlor got all chatty with the Missouri Times, who tried to create the fantasy that the Grain Belt Express transmission project is pretty much approved by the Missouri Public Service Commission.

Nothing could be further from the truth.

"Clean Line closing in on final order with the PSC"
appears to be the work of a journalist who doesn't understand the PSC process and prefers to present only one side of the story.  Clean Line isn't "closing in" on anything.  The parties (including those who oppose the project, because even if the story doesn't mention them, they still exist) are merely jockeying for position to develop a procedural schedule.  Big. Stinkin'. Deal.  This does not mean that the process has officially even started yet, but once it does, other parties will have opportunity to present evidence to the Commission and argue their position.  The positions of the opposition were enough to convince the PSC to deny GBE's first application in Missouri.  Nothing much has changed.  Except the propaganda... Clean Line is pouring that on real, real thick.

Does Clean Line think that the MO PSC is going to be swayed by propaganda and third party advocacy, instead of evidence and law?
The Grain Belt Express Clean Line wind energy project has made significant steps towards getting the final green light from the Public Service Commission.
Since the case hasn't even started yet, it remains to be seen if Clean Line's newest application will do anything to convince the PSC to approve the project.  Who decided "significant steps towards getting the final green light" have happened?  The Missouri Times?  Clean Line?  I'm sorry, but the only entity who can decide that is the MO PSC, and they haven't decided anything yet.  And what's this about a "final" green light?  This implies that a preliminary "green light" has already happened, and that's just not true.  It's been nothing but RED lights for Clean Line in Missouri so far.

And do you know why GBE "stalled" in July?  Because it filed an improper application in June that was rejected by the PSC.  "Stalled" isn't quite the proper word, denied is more apt.

So, the only "news" here is that the Missouri Times mistakenly believes "the case has officially started with the commission."  That's not news.  I'm pretty sure everyone already knows that.  And... wowzers, on the edge of your seat, folks... the PSC gave the go-ahead to finalize a public hearing schedule.  It doesn't mean the schedule is set or anything.  It means the parties are still arguing about it.  This is not news either.

So, Mark is excited.  I hope you're all excited, too.
“It wouldn’t make a lot of sense to build a line around Missouri,” Lawlor said, adding that he is confident the PSC will rule fairly on the merits of the project, not the factor. “They’re going to judge the case on its merits and whether it meets the standards that Missouri has under its statutes. They will ask, ‘Is there a need for the project and is it it in the public interest?’ We have put forth a strong argument that there’s a need.“
I'm also confident the PSC will rule fairly on the merits of the project.  And that GBE has done nothing much to create any "need" for its project.  Because, at the end of the day, Clean Line's "contract" with Missouri cities isn't binding.  The cities can elect not to participate at a later date, like when they find out that the purported wind energy they are going to have to purchase from another party in order to use GBE's capacity is much more expensive than Clean Line originally quoted.  Because Clean Line does not sell energy.  It can't price energy.  It can only sell transmission capacity, which amounts to an empty extension cord not plugged into any energy source.  Who buys an extension cord that's not plugged into anything and hopes a cheap generator gets built later on?  And guess what?  The lights will not go out in any Missouri city if Clean Line is not built.  And the cities can't even claim any savings from a Clean Line... because any savings are purely speculative at this point.  Without contracted energy, the cost to the Missouri cities is nothing but a big, fat, guess.  So, no need, no public interest, not a public utility. 

And all that blather about what some "Fortune 100" companies want is also a load of who shot John.  If these companies want renewable energy, there's nothing stopping them from buying it.  Right now.  Today.  And if they're really considering opening new facilities in locations where renewable energy is available, the prudent thing to do would be to locate the facilities near renewable energy generators, not in places where they have to pay transmission charges on a "clean" line.  We don't "need to do them" so the companies can pay extra for transmission.

And then Lawlor piles on some condescending "concern" for Missouri.  Don't be fooled... Mark's primary concern is turning a profit for his company, not providing electricity to Missouri.
While Indiana and Illinois signed onto the project before Missouri, Missouri was always seen as the most integral partner of the project. Lawlor says that belief can cause some to believe Missouri would not get much benefit out of the project, even though Missouri would get roughly 500 MW from wind energy as a result.

“Some folks get distracted this is something going through Missouri, the reality is that this is delivering power to Missouri,” he said. “From day one, it was just going to be a Kansas to Missouri line, but we found the Missouri grid couldn’t take that much power.

“Missouri’s key to this whole thing and we hope and expect we can bring those benefits to the state,” Lawlor said.
Missouri will only "get" roughly 500 MW of Clean Line's capacity if load serving entities actually purchase it.  Clean Line isn't giving "benefits" away for free.  If there are no purchasers, there are no "benefits."  And so far there are no firm purchasers.  Clean Line isn't delivering anything to Missouri, or any other state, without firm customers.  In fact, Lawlor forgot to mention that Clean Line's speculative "contract" with Missouri cities also proposes to sell capacity to the cities to export their dirty coal-fired power to other states.  If 500 MW comes in, and 500 MW goes out, what does Missouri get?  Fooled, that's what they'd get.

If Missouri is the key, Clean Line is in a heap of trouble.

So, what is it about The Missouri Times that makes them publish these kinds of stories?  The Gateway Journalism Review took a good, hard look at the Times earlier this year, and found a bunch of unpaid bills, unpaid taxes, and an editor who "was convicted by a Cape Girardeau County jury of three counts of felony forgery. In that case, he was accused of forging checks for an account for a highway expansion project."
A reporter attempted to interview Faughn about his companies’ money troubles. The Missouri Times is headquartered at 129 East High St. in Jefferson City. A reporter found Faughn there at the top of a two-story walkup, inside a darkened room resembling a lounge.

Faughn was standing behind a bar in the room with a laptop computer in front of him. Liquor bottles stood on shelves on the wall behind him. Black and white photos of politicians covered the other walls of the room.

Faughn declined a face-to-face interview. He said he would consider written questions sent by email. Questions were emailed March 17. Faughn acknowledged receiving them March 21, but said he could not respond until next week.

Faughn, the former mayor of Poplar Bluff, launched the Missouri Times in 2013 with former Missouri House Speaker Rod Jetton. Faughn was Jetton’s former campaign manager. Jetton has since severed ties with the operation.
Oh, I see.  This is the kind of publication that publishes glowing stories about Clean Line "closing in" on PSC approval.  It all makes sense now.
But what I really want to know, after reading this story, is when GBE is denied by the MO PSC for the second time, will Clean Line will finally go away?  After all, the story says a "final order" of the PSC is about to happen.  A final order on GBE's first application already happened, but the company has yet to go away.  Let's hope this time final means final.
5 Comments

FERC Ordered to Pay Legal Fees in FOIA Dispute

10/7/2016

3 Comments

 
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Lawyers and their document games!  Lawyers often resemble broody hens when documents are requested, and they have any number of tricks to play when finally placed in the broody cage by a judge.

This week, U.S. District Judge John Bates ordered FERC to pay over $60K in legal fees to STS Energy Partners to reimburse them for their cost of suing the Commission to force the release of documents requested through FOIA.  Although the lawsuit eventually inspired FERC to cough up the requested documents, Judge Bates found that FERC's document games should have been solved without STS Energy having to resort to filing a lawsuit and incurring legal fees.
FERC did show some recalcitrance and at least “appeared” to “withhold” the segregable portions of requested documents “merely to avoid embarrassment or frustrate the requester,” or simply to avoid the time-consuming work of separating information that could be properly withheld from information that could not.
 According to the decision, the story goes like this:

STS Energy submitted two FOIA requests to FERC "seeking to 'shin[e] light on FERC’s recent and punitive efforts against small power market traders for engaging in legal and ubiquitous activity in the PJM Interconnection (“PJM”) wholesale electricity market'."  FERC withheld some responsive documents.  STS filed suit to seek release of the withheld documents, and eventually FERC settled with STS to release the information.  However, attorneys for STS had to spend over $60K in legal fees to get to that point.

FOIA laws provide for the recovery of legal fees when the complainant prevails in a FOIA suit.  The court examined whether STS was eligible to recover legal fees.   The standard for the court is: 
The D.C. Circuit has instructed this court “to consider at least four criteria in determining whether a substantially prevailing FOIA litigant is entitled to attorney’s fees: (1) the public benefit derived from the case; (2) the commercial benefit to the plaintiff; (3) the nature of the plaintiff’s interest in the records; and (4) the reasonableness of the agency’s withholding.”
On the first factor, FERC claimed that there was minimal public value in releasing the documents, that they represented "provincial concerns not shared by the public at large."  However, the court found that media and Congressional interest in the information, even if drummed up by the litigants themselves, demonstrated significant public interest in the action.

On the second and third factors, FERC claimed that STS Energy, while not technically the subject of records requested, was “deeply intertwined with the entities that FERC is investigating,” including Powhatan Energy Fund, LLC.  FERC reasoned that because STS Energy was "intertwined" with the Powhatan, the subject of one of its market manipulation investigations, the firm had a private interest in the disclosure of the records.  FERC believed that the requests by STS were part of Powhatan's litigation strategy and that the company "used FOIA requests to circumvent the fact it has not been entitled to obtain discovery from FERC in the pending litigation."  That's right, Powhatan was not entitled to any discovery while FERC was conducting its investigation.  The first opportunity for discovery may have come after the investigation was completed, if the company had elected to try the matter before a FERC administrative law judge.  Instead, Powhatan elected to try its case in court.  Once at court, FERC claimed that the court was restricted to simply reviewing FERC's decision, and that Powhatan was not entitled to discovery or adjudication of the facts leading to FERC's assessment of penalty for market manipulation.  That matter is still pending.  However, back to the case at hand, where the court found that the two firms were "intertwined" and that there was a "private interest" in requesting the records. 

On the final factor, the court found that FERC didn't have sufficient reason for withholding the documents.  FERC defended its conduct in withholding as "good faith" because it eventually released the records without a court order.  However, FERC did not release the records before legal fees were incurred.

This left the court with weighing four factors, two for, and two against.  The court ultimately determined that the fourth factor carried the greatest weight.  It was FERC's game playing trying to avoid release that caught them in the end.

Lawyers that go all broody over documents rarely win.  And now it's going to cost FERC $60,168.19.
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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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