“If a bill like this were to become law, it would kill jobs by creating significant barriers to the many businesses in Arkansas, and other states, that build American infrastructure, as well as raise electric power costs. Denying American consumers access to the lowest-cost clean energy resources is never good policy,” the company said.

“The project has received supportive comments from thousands of Americans, including more than 3,000 Arkansans. Over 200 organizations and associations … have embraced the Plains & Eastern Clean Line because it will create jobs, provide low-cost energy, and result in cleaner air,” the company said.

To: [email protected]
Subject: Violation of Code of Conduct

Well, I had an interesting encounter with some Clean Line people this morning.  A surveying crew came to my house this morning.   Of course, they would not admit to working for Clean Line.  I later received a call from a Clean Line representative, asking for permission to enter my property and denying any knowledge of the surveyor crew.

You can read my description of today's events below, but here is the summary.  A survey crew tried to gain access to private property by misrepresenting themselves and a Clean Line rep denied the crew works for Clean Line.

Two surveyors came to my house, asking for permission to enter property that I rent from my neighbor just to the north of my property.  One of them told me that my neighbor had referred them to me.   This fellow told me he was working for the Arkansas Game and Fish Commission and he wanted to shoot the corners of the AG&F property which is adjacent to my neighbor's property and my property.  I quizzed him about who he worked for.  He told his company was under contract to do the work for the AG&F.  (Later, I called my neighbor and she said the fellow told her he was doing work for the AG&F.)  I asked for written proof of who he was and that his company was doing work for the AG&F.  He did not have any proof, not even a business card.  I told him I would have to see proof of who he is and who he is working for.  I apologized for the inconvenience.  I told him Clean Line was trying to get access to our property and for all I knew he could be from Clean Line.  

I asked the surveyor if he was doing work for Clean Line and he said no.

I contacted the manager of the AG&F management area.  He said the AG&F did not have a survey crew checking the property lines.  He said he was aware of a Clean Line crew doing an environmental survey in the area.  
 
As soon as the two surveyors left, I started trying to call the AG&F manager.  While on my cell phone, I received a call on the land line.  I asked the caller to call back.  About an hour later a Clean Line rep called, asking for permission to enter my property.  He said he was the person who tried to call earlier.  I told him about the incident with the surveyors and he denied knowing anything about a survey crew trying to get access to my property.  He said it was a big coincidence that he just happened to call a few minutes after the survey crew left.

To recap.  The survey crew said they were doing work for the AG&F.  The AG&F said the surveyors were not working for them. Clean Line is trying to get private property access to do their environmental survey.  It stretches the bounds of credulity to imagine that the survey crew does not work for Clean Line.  The incident is compounded by having a Clean Line rep deny any knowledge of it.

Is this the vaunted Code of Conduct the Department of Energy had in mind when it entered into unholy matrimony with Clean Line?

 During our conversation, the CL rep said he didn't know anything about a property line survey crew.  The only surveys he knew anything about were the environmental surveys. When I told him I didn't believe him, he told me he was a born again Christian and he wouldn't lie.

From: "Lawrence, Christopher" <[email protected]>
Date: June 14, 2016 at 11:01:44 AM CDT
To: Landowner
Subject: RE: Violation of Code of Conduct

Hello Mr. Landowner,

Thank you for raising this concern.  The Department takes the requirements of the Participation Agreement very seriously.  The Participation Agreement includes numerous protective measures for property owners, including, as you mention, the Code of Conduct at Schedule 12.  The matter of your concern will be discussed with Clean Line and, as needed, Clean Line's compliance with all of its contractual responsibilities under the Participation Agreement will be clarified.

Christopher A. Lawrence
Electricity Policy Analyst
National Electricity Delivery Division
Office of Electricity Delivery and Energy Reliability
U.S. Department of Energy
O-(202) 586-5260
F-(202) 586-8008
[email protected]

All communications with property owners and occupants must be factually correct and made in good faith.

1. Do not make false or misleading statements.
2. Do not purposely or intentionally misrepresent any fact.

When contacting a property owner in person, promptly identify yourself as representing Plains & Eastern.

“I think it’s a great thing,” said Brent Abell, general superintendent of the Palmyra Board of Public Works. “Anything to keep costs down. That’s the ultimate key in the power industry, keeping our costs low enough to keep it affordable. It fills a void where we can get cheaper power.”
The announcement of the agreement was anticipated, according to Abell.
“We’ve heard rumblings that it was coming and it was a group decision to do it,” he said. “I think it’s a great thing if everything pans out the way it’s supposed to pan out. Sometimes things don’t pan out the way they seem, but I’m hoping it does and I think it will.”

Clean Line President Michael Skelly said the new agreement would give Missouri municipal utilities “low-cost access to really the best wind resources in the country.”

“We heard the commission’s concerns loud and clear, and one of them was they wanted to know there were actual Missouri customers for the line, and we’ve now proven that out,” Skelly said.

GBE has not presented adequate evidence to show that the Project is economically feasible.
Staff made credible criticisms of the GBE studies and pointed out the large amount of important information that is not known about the impact of the Project on Missouri. Interconnection studies with SPP, MISO and PJM have not been completed or are inconsistent with the Project’s current design, plans for operations, maintenance or emergency restoration have not yet been developed by GBE, and GBE production modeling studies do not support GBE’s claims that retail electric rates would decrease. In addition, there is a good chance that Project costs would increase beyond what was estimated by GBE due to transmission upgrades, congestion, wind integration and the need for additional ramping capacity.
Dr. Michael Proctor presented credible evidence that Ameren Missouri would have lower-cost alternatives than the Project for meeting its need for capacity and energy, both with and without considering the renewable energy requirements of the Missouri RES. GBE failed to perform adequate studies and present sufficient evidence on this analysis, which the Commission would need to properly evaluate economic feasibility of the Project. Dr. Proctor’s analysis showed that natural gas-fired combined cycle generation is the most cost-effective generation alternative, and that wind energy from areas of MISO or through the purchase of RECs are a lower cost alternative to wind energy generated by the Project. Therefore, the Project is not the least-cost alternative for meeting Missouri’s future needs for either energy and capacity or renewable energy, so it is highly unlikely to meet the Commission’s rule for 1% rate impact limitation from renewable energy.

Since the Commission has concluded that GBE has not met two of the Tartan factors, by that standard GBE cannot show that the Project promotes the public interest.

However, the Commission will also consider further some of the specific public benefits of the Project claimed by GBE.

As Staff witnesses point out, as a result of GBE’s inadequate production modeling studies, GBE’s claims that the Project would lead to lower renewable energy compliance costs, lower wholesale electric prices, lower retail electric rates, and reduce the need to generate electricity from fossil-fueled power plants are not sufficiently supported by the record. Moreover, the Project is not needed to satisfy the Missouri RES requirements. Although GBE argues that the Project will make wind energy more accessible to MISO and PJM customers, the evidence shows that wind energy is already accessible in those regions and, at least in MISO, has more than doubled as a percentage of total energy generated in the last three years. GBE alleges that the Project would result in economic benefits, but its studies are not reliable, as they fail to consider any negative economic impacts resulting from job displacement and energy production. Finally, GBE touts the Project as a way for Missouri to access affordable clean energy as increasing environmental regulations increase costs for coal plants. It is too soon to say what the impact of the proposal will be on Missouri.

In this case the evidence shows that any actual benefits to the general public from the Project are outweighed by the burdens on affected landowners. The Commission concludes that GBE has failed to meet its burden of proof to demonstrate that the Project as described in its application for a certificate of convenience and necessity promotes the public interest.

Skelly acknowledged many landowners will continue to oppose the project but said he’s hopeful the state will consider the line beneficial enough reconsider its stance.

“We’ve had opposition in the past and we may in the future,” Skelly said, “but we think this agreement is a very positive development for the project.”

“From an analysis we have based on the offer they gave us, we believe it’s going to save us about $10 million annually,” said Ewell Lawson, who manages government relations and member services for the Missouri Public Utility Alliance.

“Kind of what we’re seeing in the market right now for wind would bring it to Missouri at about 3 cents per kilowatt hour,” he said.

In 2014, Lawlor told Midwest Energy News the price of energy delivered by Grain Belt Express was between $40 and $45/MWh.
"Lawlor said the line can at current prices deliver wind energy to Missouri at between 4 and 4.5 cents per kilowatt-hour."
(Editorial note: 1,000 kWh = 1 MWh, however I am presenting these quoted figures in MWh for uniformity).

And also in 2014 Grain Belt Express witness David Berry, Clean Line's Executive Vice President of Strategy and Finance, told the Missouri Public Service Commission in his sworn testimony that it would cost $15 to $20/MWh to transmit energy via Grain Belt Express.
"The cost of delivered energy is equal to the cost to generate wind energy in western Kansas (2.0-2.5 cents) plus the cost to move power on the Grain Belt Express Project, which we estimate at 1.5-2.0 cents per kWh."

In 2013, Clean Line told MISO that its transmission costs for the Clean Line projects were $20 to $25/MWh.
"Even when a transmission charge of $20/MWh to $25/MWh (based on Clean Line estimates for a 500 mile to 700 mile HVDC facility) is included, the delivered cost of heartland-region wind would be below both in-state wind and in-state solar PV price estimates in the Eastern U.S."

The new contract, which is contingent on Clean Line’s winning approval from Missouri regulators...

About 35 of the Missouri Joint Municipal Electric Utility Commission members are part of the contract now to procure from 50 to 100 megawatts of space, Lawson said. But more of the group’s 67 members can join and reserve space up to the 200 megawatts outlined in the contract.

CLEP has already won approval for Grain Belt Express from commissions in Kansas, Indiana and Illinois. In the Missouri decision, commissioners recognized the transmission system’s value to Kansas and Illinois but argued it would do little other than pass through their state.

CLEP has since added a 500 MW substation in Missouri to allow the line to serve load in the state, upping the system’s potential value.

Big Transmission never did and never will make sense. Let’s look at a half-dozen reasons why: 1) the laws of physics, 2) higher reliability risk, 3) stricter contingency limits, 4) lumpiness and investment risk, 5) rigidity of source and sink, and 6) better alternatives.

It is difficult to apportion the demise of PATH among reduced load growth, the Mt. Storm-Doubs alternative, new generation, and sophisticated statelevel opposition. However, it is fair to observe that reduced load growth had only postponed PATH in the past (three times). What was different in 2010 was the emergence of the Mt. Storm-Doubs  alternative, and the focus of a state regulator on that alternative.

But certainly when Big Transmission is dependent upon market conditions the lumpiness and risk factors are all the more daunting. Big Transmission somehow needs to bring together generation resources and market demand – to the exclusion of alternatives – to forge a level of commitment that will last for many years. That’s a prerequisite for financing. So the entities at each end need to perceive such a compelling business proposition that they will forego other alternatives and cast their fate with Big Transmission. That’s a tough sell.

FERC requires that utilities interconnect all new generation. So a new generator is assured of being able to interconnect its project to the utility serving the territory it is located in; the issue is solely how much money and time it will take for the interconnection. Given this legally assured ability to access the grid through the resident utility, market-based Big Transmission is effectively competing with that utility and thus must offer substantial value added.

Utility Energy has agreed to purchase 500MW of power from Plains & Eastern via an intermediate converter station in Arkansas. It is not immediately clear where the balance of the line’s capacity will be sold.

Liars overemphasize their truthfulness. “To tell you the truth…” “Honestly…” “I swear to you…” Oh, if only it were so! When people use these bolstering statements to emphasize their honesty, there’s a good chance they are hiding something. Learning to baseline someone’s normal behavior is important in situations such as this:  You want to listen for normal or harmless use of such phrases. There’s no need to add them if you really are telling the truth, so be on guard.

"The growth has been in some fits and starts, but we're at a point now where this is an essential project to continue to provide, really, the type of service, the level of service, that our customers expect from us," Fakult told the Asbury Park Press. "It reinforces the system in that area. It allows us to, again, provide better, more reliable, resilient service."

"The time is now," Fakult said. "It just needs to be done now."

Nearly 16 years ago, the utility scrapped plans for a 6.5-mile transmission line, to be run on 60-foot high steel poles, along the railroad tracks from Matawan to Middletown, after intense community opposition. Residents and some town officials, fearing a reduction in property values and worried about health risks, fought the project for a decade.

"To me, it is nothing but a resurrection of precisely the same plan that we fought and stopped," said state Assemblywoman Amy Handlin, R-Monmouth, a vocal opponent years ago. "It's the phoenix rising from the ashes, it's the ghost of battles past. It's not different."

This time, the utility proposes to run the wires atop slender single poles that average 140 feet tall rather than bulky towers used in the past, spokesman Ron Morano said.

The use of the NJ Transit corridor, which is already designated for public use and has existing electric infrastructure, as well as the slimmer monopoles, will help to minimize the disruption on the community, Fakult said.

Morano, the JCP&L spokesman, said the utility follows all safety and heath guidelines and will have an electromagnetic fields expert available at open house sessions. "We are successfully building transmission lines in other (areas) without any issues," she said.

PJM Interconnection, the organization that oversees the electric grid in 13 states and Washington D.C., has identified the Monmouth County Reliability Project as a necessary project to reduce the length and frequency of outages in Monmouth County, the utility said.

If not built, "over the long term, you start to see issues emerge," Fakult said. "When you start to see peaking conditions, you just don't have the contingencies that you need to run the system reliably."

As noted in the fact sheet, Energizing the Future is a transmission initiative through 2017 that involves upgrading and strengthening the grid to meet the future demands of customers and communities. Key factors driving that investment include enhancing system reliability by replacing existing equipment with advanced technologies; meeting projected load growth; and reinforcing the system in light of power plant deactivations, the fact sheet added.

The company plans to hold three open house events in neighborhoods near the proposed project to share information with the public and gather feedback. The company also is setting up a website at www.monmouthreliability.com.

“The energy resources that we would like to have seem to be located in places where people really don’t live,” Byrne pointed out.