Jeff Tittel, director of the New Jersey chapter of the Sierra Club, said his group "will definitely oppose" the section in that state.

Tittel said the Sierra Club's opposition is "absolutely" a challenge to the existing business model for utilities, which often rely on far-off plants to send power into populated areas.

Tittel said the PPL proposal is like "frack by wire" because the proposed route across northern Pennsylvania would encourage new power plants fueled by hydraulically fractured Marcellus Shale gas.

Tom Schuster, a regional Sierra Club representative, said the group hasn't taken a position on the entire project because there are still too many unknowns.

Environmentalists who testified said they support the [Grain Belt Express] plan. James Harmon of Kirksville, a member of the executive committee of the Sierra Club’s Missouri Chapter, said it would help Missouri and other states meet the new federal goals for reducing carbon emissions.

Jay Apt, director of the Carnegie Mellon University Electricity Industry Center, said that enormous natural gas production from the Marcellus Shale has led to significantly cheaper wholesale prices in areas of drilling. In other words, a power plant could produce electricity cheaply in Pennsylvania and a utility could transmit it to places with higher electric prices, such as Maryland, New York, and New Jersey.

PJM Interconnection of Audubon, Pennsylvania, which oversees wholesale electric demand for 61 million customers in a 13-state mid-Atlantic region, has said that the electric grid is "undergoing an extraordinary transformation" as coal-fired plants retire.

 PJM could approve all, part, or none of the PPL plan, but regulators agree that the region needs transmission upgrades to ensure reliable and affordable electric service. Allentown-based PPL said the line would take about a decade to build.

PJM spokesman Ray Dotter said it's like a huge version of the dilemma many individuals face: Is the most effective thing to buy a new car, or fix the old one you have?
The PPL plan is like the new car choice. PJM will review the proposal and is likely to vote on it in November or December, and is also considering numerous smaller projects from other utilities.

"We have better places to invest our energy money" in or near in New Jersey, Tittel said, such as offshore wind, solar, and energy efficiency projects. He added that if money was spent in those ways "you wouldn't need the power line."

As a project manager at Clean Line
Energy and someone who is passionate
about moving the wind industry
forward, I would like to address some
of the misleading statements made in
the recent article published in the
Moberly Monitor, "Line's health problems
brought to light."

I strongly urge folks to gain a full understanding of direct current technology
from nationally and internationally trusted sources. At Clean Line Energy, safety is among our chief concerns as we strive to treat landowners with the utmost respect.

The recent editorial by Adhar Johnson, Clean Line Project manager has been expected, and her bias should be obvious.  The information provided in the June 6 article,  Transmission Line Health Problems Brought to Light, by Connie Duvall, was very careful to address ONLY the types of fields produced by high voltage lines.
My reputation is on the line in the community in which I live and serve, and the information used was carefully screened for accuracy.   Since the June 6th article, additional studies have been uncovered which directly name HVDC lines as the culprit in adverse health effects.  The information  from the studies repeatedly questions the "trusted" sources quoted by Clean Line Energy's advocates. This technical information will be used in November to testify before the MO Public Service Commission in Jefferson City.
(Above Statement by Dr. Dennis Smith)  

Clean Line managers and land developers have been flooding papers in would-be affected counties with their propaganda, touting their passion for wind energy.  These power lines have little if anything to do with wind energy as they are not needed to utilize it.  Clean Line execs typically implore the public to turn to trusted sources, which is exactly what we want them to do.
 
After all, the area of education of the Grain Belt Express (GBE) pushers is business and communications; their expertise is in the art of the deal, how to manipulate statements to their advantage, and how to turn a fast buck.  Is this reason to trust them?

They have determined to discredit Dr. Smith because his research threatens their venture.  Along with discounting him, they must also take down the numerous scientists, electromagnetic experts, and doctors who have done countless studies pointing to the harms of this type of EMF exposure.

Adhar Johnson, Clean Line manager, attended the Randolph County commissioner public meeting where a gentleman emotionally testified of his wife’s oncologist’s admonition that such a power line would necessitate their relocation.  In a meeting at Rothwell Park, Adhar told me  that the doctor had no business saying that, and then she handed me Clean Line’s go-to documentation of the one out-dated statement made by the World Health Organization (WHO) that there were no known health risks.  Much more recently, the WHO has revised their statement and has classified the emissions from these lines a class 2B carcinogen, as has the Environmental Protection Agency.  HUD has ruled the lines and towers “a hazard and a nuisance”, and FHA appraisals have to be adjusted to address the effect these lines have on marketability of properties near the lines.  The highly respected, non-partisan, U.S. Government Accounting Office expressed many of the same concerns voiced by citizens regarding HVDC lines in its report to Congress in 2008.

Dr. Smith also discovered the following statute:

Exercise of eminent domain over private property for economic development purposes prohibited--definition.
523.271. 1. No condemning authority shall acquire private property through the process of eminent domain for solely economic development purposes.  2. For the purposes of this section, "economic development" shall mean a use of a specific piece of property or properties which would provide an increase in the tax base, tax revenues, employment, and general economic health, and does not include the elimination of blighted, substandard, or unsanitary conditions, or conditions rendering the property or its surrounding area a conservation area as defined in section 99.805.
Missouri Revised Statutes
Chapter 523
Condemnation Proceedings
Section 523.282
Our Randolph County Commissioners have welcomed Clean Line GBE to our county for the exact reasons that the statue prohibits and have voiced at public meetings their support for those reasons prohibited in the statute.
 
Dr. Smith is trusted in this community as he has been in all communities in which he’s lived.  I make no apologies in stating that he has had a stellar medical career, having graduated in the top 5% of his medical class and having received multiple awards and accolades for his single-minded service to his God-given mission in Public Health.  He maintains excellent rapport with former hospitals where he has been employed and would be whole-heartedly welcomed back to any of those facilities.  Consider also the editorials that have been submitted by the many respected members of the community, your long-time friends and associates who oppose this line. Shall we then trust some wealthy business people whose real passion is increasing their profits, or should we trust scientists and doctors who are devotees to public health and safety?  It’s not a difficult choice.

Sincerely,
Laurie Smith
Moberly, MO

“We think we can provide green power at an attractive, fixed-rate price for TVA and other utilities in the region,” Clean Line Energy Executive Jimmy Glotfelty told TVA last year. “Having a guaranteed price for 20 years is a great hedge against volatile natural gas prices.”

The existing three coal-fired units at ALF provide both real and reactive power for the Memphis area. To continue to reliably serve the area, generation resources must be located at or near ALF.

Whereas, the Association of Tennessee Valley Governments (ATVG) represents local governments within more than 200 Tennessee Valley River Region Counties which closely monitor issues associated with the
Tennessee Valley Authority (TVA); and

Whereas, TVA's mission focuses on providing low cost, reliable electricity, environmental stewardship and economic development to the people of the Tennessee Valley; and

Whereas, the TVA Act of 1933 mandates that TVA provide power to its customers at the lowest feasible cost; and

Whereas, TVA is currently evaluating a proposal to purchase a large amount of wind generated electrical power from the Oklahoma panhandle from Clean Line Energy Partners, LLC, and transport It 700 miles using a single high voltage direct current transmission line that will bypass the existing network of power
lines to Memphis, Tennessee; and

Whereas, such a partnership between Clean Line and TVA would likely transport wealth outside the Tennessee Valley to the detriment of the nine million residents of the Valley; and

Whereas, TVA has stated that electricity demand in the Tennessee Valley is not expected to return to 2007 levels until 2020; and

Whereas, the nation's power grid is a complex, interconnected network of generating plants,
transmission lines and distribution facilities; and

Whereas, bypassing the grid to purchase electricity from such a long distance away increases security threats by providing additional exposure for natural or malicious events due to the extreme distance between generation and point of use without needed network redundancy; and

Whereas, wind is an intermittent power source that lacks the dispatch capability of other resources and does not eliminate the need for base load or dispatchable power plants like other more dependable resources such as nuclear, natural gas, coal and hydropower; and

Whereas, the number of property parcels and property owners that may be negatively affected by eminent domain as a result of the construction of this proposed 700 mile transition line is unknown;

now, therefore

BE IT RESOLVED by the Association of Tennessee Valley Governments (ATVG), that we strongly encourage the Tennessee Regulatory Authority to exercise caution as it considers the application of Clean Line Energy Partners, LLC, for a certificate of public convenience and necessity to operate as a
public utility with powers of eminent domain within the State of Tennessee until it is proven that its proposal meets TVA's obligation to provide reliable power to its customers at the lowest feasible cost.

The TVA and other load serving entities have a strong and growing demand for cost-effective electricity from renewable resources.

There has and will continue to be a demand for affordable and reliable renewable energy in Tennessee, the larger TVA service footprint, and throughout the Mid-South and Southeast.

The Project will allow TVA and other utilities in the South to reliably and consistently access the country’s most cost-effective wind energy resources.

In particular TVA has been a leader in realizing the benefits of wind energy in the Southeast. In its most recent Integrated Resource Plan, TVA called for 2,500 MW of renewable energy purchases by 2020. Wind energy from economical locations such as the Oklahoma Panhandle can provide a consistent, long-term, low-cost energy supply to TVA and other load-serving utilities in the Mid-South and Southeast.

These wholesale buyers may include TVA as well as other utilities inside and outside of Tennessee that seek to purchase low-cost electricity generated in the Oklahoma Panhandle region.

The Petition states that the Company will provide wind power to TVA and other potential customers. Please identify all other potential customers that Plains and Eastern has had discussions with regarding the purchase of power and provide copies of any agreements reached with these customers.

On page 6 of David Berry's testimony, he provides a list of wind power purchase
agreements involving the TVA (purchaser). To your knowledge, discuss the TVA's process for choosing to enter into such projects, including whether the projects go through the RFP process.

Is TVA or other potential wholesale purchasers under any obligations (including any state or federal requirements) to purchase additional wind power to meet its renewable energy objectives? Provide supporting documentation. To your knowledge, is TVA currently meeting its renewable energy objectives? Will TVA be able to meet its renewable energy objectives absent approval of Plains and Eastern's petition?

Provide a copy of all Memorandums of Understanding with TVA.

Please explain and describe in detail any guarantees or assurances that Plains and Eastern can provide lower cost renewable energy to TVA than TVA currently purchases.

Please list all available state and federal tax credits that Plains and Eastern currently
receives related to projects in other states and federal credits that the Company anticipates receiving upon completion of the project proposed in this docket. Are these federal credits figured into the pricing model used by Plains and Eastern? If so, please explain in detail the impact on rates, as well as the Company's overall operations, that
would result if these federal credits were discontinued by the federal government.

On page 9 of Michael Skelly's direct testimony, he states, "The TVA and other load serving entities have a strong and growing demand for cost-effective electricity from renewable resources." Provide the source from TVA and other potential entities stating they have a growing demand for renewable resources.

On page 11 of Michael Skelly's direct testimony, he states, "The Project will allow TVA and other utilities in the South to reliably and consistently access the country's most cost effective wind energy resources." Please provide all underlying support and rationale
relied upon for the assertion that this project will allow access to "the country's most
cost-effective wind energy resources."

For clarification, please provide the estimated number of construction jobs that would be
created in Tennessee if the petition is  approved. Also provide the estimated duration of these temporary construction jobs.

For clarification, please provide the estimated number of permanent full-time jobs that
would be created in Tennessee upon  completion of the project.

Please describe any assurances and/or guarantees that Plains and Eastern will hire
Tennesseans for the temporary construction and permanent jobs detailed above.

Provide the latest update on the environmental impact statement being prepared by the DOE under NEPA. Also provide the latest update on all federal reviews/environmental studies being performed by the DOE.

Provide an update regarding Plains and Eastern's CCN application in Arkansas.

The eventual “partnership” with DOE through its agency Southwestern Power Administration (SWPA), which markets power in six south-central states, would be limited to use – if needed – SWPA’s eminent domain authority to obtain right-of-way in Arkansas.

SPRA has concerns in general about implementation of Section 1222, and specifically about the proposed Plains and Eastern project. Of specific concern is the protection of SPRA’s federal power customers from any and all liabilities arising from the planning, design, construction, operation, maintenance, and/or ownership of Section 1222 projects. Other concerns include the
demonstrated need for any proposed project and that such projects promote   interconnection of the grid in which they are located.

SWPA’s original authority to construct transmission facilities is limited by Section 5 of the Flood Control Act of 1944 to “only such … facilities as may be necessary in order to
make the energy and power generated at … [Corps] projects available” to its wholesale
customers. SPRA is concerned about extending SWPA’s authority to construct transmission facilities beyond this original mandate.

1. Does purchasing electricity from this distance increase security threats to TVA's
power supply? Former U.S. Secretary of State George Schultz has said we should
pay attention to generating more energy where we use it because of national
security risks.

The power grid is a complex, interconnected network of generating plants,
transmission lines, and distribution facilities. This system is designed with
redundancy and resiliency at its core to ensure a reliable electric power system.
Some increase in security risk is unavoidable as distance increases between
generation and point of use. The extra distance provides additional exposure for
natural or malicious events to force a transmission path out of service. The potential
for an interruption with long duration to power supply increases if full transmission network redundancy is not provided or as greater amounts of supply are obtained
from more remote sources. The Department of Defense has become aware of this
risk; it is implementing a program to make its major installations self-sustaining in
energy to mitigate the potential interruption from the grid.

2. What is the cost of purchasing wind electricity compared to TVA generating or
purchasing other types of electricity generation?

TVA is studying the addition of new wind energy resources as part of the
development of its new Integrated Resource Plan (IRP). This process provides
opportunity for public participation. When TVA evaluates the cost of wind energy,
we include the value of the energy itself, as well as the cost to transmit out-of-valley
wind energy to the Tennessee Valley. In addition, there are costs associated with
the intermittent nature of wind generation. Through the IRP, TVA will rigorously
compare wind energy purchases against other alternative sources of energy
(renewables, new and existing TVA generating assets, or purchased power) to
serve local power companies and directly-served customers in a cost-effective
manner.
In FY2013, TVA's average fuel rates by asset type were as follows: nuclear,
$6/MWh; coal, $32/MWh; and gas, $39/MWh. The TVA average system fuel cost,
which includes hydro (no fuel cost) and purchased power, was $24/MWh. By
comparison, off-system wind purchases were $80/MWh (including transmission).
The cost of both wind and solar have trended steadily down in recent years. Lazard
Freres and Company, LLC, a leading financial advisory firm, does a periodic study
on the costs of renewable energy. Its most recent report states that the cost to
generate wind with the Federal production tax credit (PTC) is as low as $23 MWh;
without the credit, the costs are as low as $45 MWh. (Note that these are
production costs that do not take into account the cost of delivery to or the impact on
the TV A system.)

3. There is substantial opposition in Congress to the wind production tax credit. Will
TVA ratepayers be at risk of increased rates if the wind production tax credit is not
renewed?

TVA does not benefit directly from the PTC. As noted in the prior response, the
PTC has a material impact on the cost structure of wind developers and, in turn, the
price they can offer to TVA or other purchasers of the wind energy. Any TVA
purchase of wind energy would be under a long-term contract that would place risk
associated with the tax credit on the seller.

4. What is the reliability of purchasing wind power as compared to other types of
electricity generated by natural gas, nuclear, coal, or hydropower?

Because wind is an intermittent resource that lacks some of the dispatch capability
of other resources, it does not eliminate the need for base load or dispatchable
power plants like nuclear, natural gas, coal and hydropower. Adding intermittent
generation resources like wind can be challenging to manage, particularly as the
volume of generation from those sources increases. Wind patterns are fairly
predictable, but not entirely so; in addition, weather and other factors can affect
output. To maintain reliability, a wind energy purchaser must keep adequate
capacity and spinning reserves to cover the variability inherent to wind. Spinning
reserve is typically calculated as the amount of capacity available to cover the loss
of the largest generation source on the system. Utilities across the country have
been integrating more wind into their systems over the last several years, and TVA
already integrates 1,515 megawatts of off-system wind power. The industry has
growing experience with this issue, but it does make ensuring reliability more
complex.

5. TVA's peak power demands tend to be between 4:00 p.m. and 7:00 p.m. and wind
tends to mostly blow at night. How does wind power fit into TVA's overall demand
structure if the electricity isn't being produced when TVA needs it the most?

TVA analyzes historic and forecasted wind patterns to determine expected wind
deliveries at our system peak. Our forecasting and planning processes reflect
adjustment to wind generation at our summer peaks based on this analysis. Clean
Line has told us that a production profile provided by the independent meteorology
firm, 3Tier Oklahoma, shows that panhandle wind energy produces at about a 50
percent capacity factor between the hours of 4:00 p.m. and 7:00 p.m., thus
contributing to meeting peak demand. TVA's current wind resources produced
about 25 percent average capacity factor over that peak period last summer, with
significant variation each day (between 5 and 65 percent capacity factor). TVA will
take the seasonal and time-of-day energy patterns of wind into account when
evaluating adding additional wind energy to its portfolio.

6. At a roundtable in September 2013, hosted by Senators Corker and Alexander, you
said that TVA didn't need additional electricity generation capacity as the result of
reduced electricity demand. Has this projection changed?

Electricity demand is not expected to return to 2007 levels until the end of this
decade. We are projecting growth in demand of approximately 0.6 percent per year,
net of TVA's energy efficiency efforts. TVA believes that we have adequate
supplies to meet the near- to mid-term energy needs of the Valley reliably. Cleaner
energy sources, including nuclear, renewables, hydro and energy efficiency, provide
diversity within TVA's existing balanced energy portfolio. TVA is evaluating future
power needs and opportunities to meet them through the IRP. Wind and other
generating resources are regularly evaluated against existing or planned asset
additions to address changing conditions.

7. If the projection for TVA's electricity demand has changed since September 2013,
does it make more sense to purchase this wind power from Clean Line Energy
Partners, to build additional nuclear capacity, or to build additional natural gas or
coal capacity?

While demand over the next decade or so is predicted to be stable with low growth,
the TVA generation fleet is in transition. TVA has retired or will retire a substantial
portion of its coal fleet; we are committed to the completion of Watts Bar Nuclear
Plant Unit 2 and to a large new gas combined cycle plant in Paradise, Kentucky.
We have the potential to get incremental megawatts from the hydro system and a
significant amount from power uprates in the nuclear fleet. We have to either
retrofit, retire, or replace the Allen Plant in Memphis before 2019 under the terms of
an agreement with EPA and others. (Clean Line cannot supplant Allen because of
the need for a generation source physically located in that area to provide
transmission support that imported wind generation cannot provide.) In addition,
other market participants have approached TVA with expressions of interest to
provide electricity from gas, nuclear, wind and solar assets. TVA also factors in
energy efficiency and demand response programs into its resource decisions. The
recently announced draft 111 (d) rule from EPA, if enacted in its current form, will
also have a national impact on future decisions.
Clean Line will be evaluated in this context of low growth, transitioning fleet and
other options by application of the statutory mandate and guidance noted in the
preamble of this letter.

"We don't think a long time about things, she says.  "That seems like a good idea!  Let's do that!  That's the extent of our long range planning."

A majority of Americans oppose new high-voltage transmission lines in their community, but that opposition drops precipitously to 17% if those lines are delivering clean, renewable energy from wind. Support for new transmission lines leaps from just 46% to 83% when respondents are asked specifically about high-voltage transmission lines delivering wind power.

The survey of 1,239 adults nationwide was conducted last week (April 21-23) by The Saint Consulting Group, the political land use consulting firm that also issues the annual Saint Index© survey of attitudes toward real estate development projects, including energy-generation projects such as wind, nuclear and hydro facilities.

Ben Kelahan, energy practice leader at Saint Consulting, said the new results are a clear sign that Americans support cleaner, renewable power and that it has carried over to the distribution of that power through their own backyard.

“High-voltage transmission lines generate some of the most adamant NIMBY (Not In My Back Yard) opposition in the country. That such a large percentage of people are willing to allow green lines in their community says a lot about the awareness and importance of renewable energy and climate change issues in addition to the education efforts undertaken by the renewable energy industry,” Kelahan said.