...request that the Appellate Court for the Fifth Judicial District REVERSE the above referenced orders of the Commission in their entirety, and declare Section 8-406(b-5) of the Public Utilities Act unconstitutional as Special Legislation, as violative of the Equal Protection Clause, and as violative of the Separation of Powers Clause.

The Law of the Instrument is a cognitive bias that is often expressed with the phrase, "If
the only tool you have is a hammer, every problem looks like a nail.” The draft National
Transmission Needs Study epitomizes the Law of the Instrument because it prioritizes
transmission as the only possible solution. Three years ago, DOE’s last congestion study
concluded, “…the Department has not identified transmission congestion conditions that would merit proposing the designation of National Corridors.”   Now the Department has
found terrible congestion in an area so vast that if the DOE were to designate corridors to
solve it, the entire continental U.S. would be one gigantic “corridor.” The only conclusion that can be drawn by these drastically different findings is that the DOE’s transmission studies are not based on data and science, but on political goals. This does not benefit the citizens the Department exists to serve. Although politics produces a vast supply of hot air, it cannot keep the lights on.

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The fact these long-in-the-works projects are reaching similar milestones appears to be coincidence; no single policy is moving them forward. They are, however, advancing at a time of increasing understanding by local communities and even traditional opponents — including some conservation groups — of the need to move clean energy from rural outposts and to build more durable electric systems after a series of weather and climatic events have felled grids in recent years.

PJM cautions against approaching this analysis based on a ‘top down’ analysis based on what appears to be an attempt at optimizing the deployment of renewables across the nation.

New transmission advances clean energy goals by enabling greater access to clean energy resources, which can be in remote areas, far from load and the existing transmission system.

Transmission projects also frequently face public opposition or “not-in-my-backyard” concerns for various reasons. These challenges can lead to increased costs, schedule delays, or even project cancellations.

A significant portion of the higher congestion noted in the Report is associated with multiple transmission outages in support of approved upgrades. As a result, the congestion listed should not necessarily be considered a persistent level of congestion in the Mid-Atlantic.

The study was warmly welcomed by Chicago-based Invenergy LLC, developer of the proposed $7 billion Green Belt Express line that could help carry up to 5,000 MW of Great Plains wind power to Great Lakes and mid-Atlantic population centers.
A key 530-mile segment of the line, running from Kansas to central Missouri, is a candidate for a federal loan guarantee, according to DOE — one of the new or strengthened transmission initiatives provided for DOE in the infrastructure act.

“We are encouraged by the findings of the draft study which underscore the critical need for interregional transmission to deliver cost-effective generation, meet projected demand growth and usage shifts, and improve reliability and resilience, especially in the face of increasing extreme weather events, cybersecurity risks, and physical threats,” said Shashank Sane, Invenergy executive vice president for transmission, in a statement.
“The draft study rightly focuses on identifying market barriers to interregional transmission development to accelerate deployment of clean energy,” he added.

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Those who are actually affected by a covered transmission project will not stop opposing and delaying that project because the federal government bought fake support from unaffected groups or individuals. Purchased fake support does not fool regulators. It doesn’t fool anyone in the community, either. It will only fool the fools in D.C. who purchase it.

Title XVII of the Energy Policy Act of 2005 (EPAct) established a federal loan guarantee program for certain projects that employ innovative technologies. EPAct authorizes the Secretary of Energy to make loan guarantees available for those projects.  Grain Belt Express, LLC (Applicant), has applied for a loan guarantee pursuant to the DOE Renewable Energy Project and Efficient Energy Projects Solicitation (Solicitation Number: DE-SOL-0007154) under Title XVII, Innovative Energy Loan Guarantee Program, authorized by the EPAct. The primary goal of the program is to finance projects and facilities in the United States that employ innovative and renewable or efficient energy technologies that avoid, reduce, or sequester anthropogenic emission of greenhouse gases (GHGs).

Potential impacts on resources include, but are not limited to, impacts (whether beneficial or adverse; short term or long term) on air quality and GHG emissions; soils and paleontological resources; water resources, including surface and groundwater and floodplains; vegetation, wildlife, and special-status species; land use and recreation; socioeconomics and environmental justice; public health and safety; cultural resources and Native American traditional values; transportation; visual resources; and noise.

LPO will hold six public scoping meetings for the project, four in-person and two virtual meetings, at the following dates and times (Central Time). Registration for the virtual public meetings may be completed at the following web links:


• Wednesday, January 25, 2023, 11:30 a.m.-1 p.m., virtual meeting on Zoom ( https://us06web.zoom.us/​webinar/​register/​WN_​NOQzgumNTpOAIL5UoLVIeA)
• Thursday, January 26, 2023, 5 p.m.- 6:30 p.m., virtual meeting on Zoom ( https://us06web.zoom.us/​webinar/​register/​WN_​D619NGe1TGqMH0fcHx5SSA)

• Tuesday, January 31, 2023, 11 a.m.-1 p.m. and 4 p.m.-6 p.m., Dodge House Hotel and Convention Center, 2408 W Wyatt Earp Blvd., Dodge City, KS 67801

• Tuesday, January 31, 2023, 11 a.m.-1 p.m. and 4 p.m.-6 p.m., Municipal Auditorium, 201 W Rollins St., Moberly, MO 65270

• Thursday, February 2, 2023, 11 a.m.-1 p.m. and 4 p.m.-6 p.m. Corinthians Hill Event Center, 464 NE 20 Ave., Great Bend, KS 67530
• Thursday, February 2, 2023, 11 a.m.-1 p.m. and 4 p.m.-6 p.m., Fairview Golf Course, 3302 Pacific St., St. Joseph, MO 64507

All meetings are open to the public and free to attend.

"The purpose of the pre-filing process is to facilitate maximum participation from all stakeholders to provide them with an opportunity to present their views and recommendations with respect to the environmental impacts of the facilities early in the planning stages of the proposed facilities."

...an applicant may demonstrate that it has met the statutory good faith efforts standard by complying with an Applicant Code of Conduct in its communications with affected landowners.

...the term “environmental justice community” includes disadvantaged communities that have been historically marginalized and overburdened by pollution. The term also includes, but may not be limited to, minority populations, low-income populations, or indigenous peoples.

... whether the proposed rule constitutes good policy, such as, for example, whether it will be beneficial in determining whether to site electric transmission projects when the states have not done so, or whether the rule will tend to ensure almost nothing is ever sited.

State regulators are much better prepared to deal with that myriad of local concerns, including concerns over routing and costs, than FERC. Furthermore, state processes are far more convenient and user-friendly than processes at FERC, if for no other reason than geographic proximity. So, waiting one full year to allow a state to “go first” and make its decision makes sense for a lot of reasons. One obvious reason is that if the line is truly needed, the state regulators will in all likelihood approve it, and no FERC staff time and resources will need to be expended at all. The whole mantra that goes “the states are blocking needed transmission all over the country!” is simply a political and special-interest narrative. The steadily mounting increases over the past decade in transmission rate base nationally, with concomitant skyrocketing increases in transmission costs to consumers, blows up the narrative that states are systemically blocking needed transmission lines. Contrary to the narrative, states need more authority to scrutinize transmission projects for need and prudence of cost, not less, to protect consumers.

Compensation for property taken under this subsection shall be determined and awarded by the district court of the United States in accordance with section 3114(c) of title 40, United States Code.’’.

Energy Secretary Jennifer Granholm on Friday backed the much-debated permitting overhaul provisions unveiled in Congress this week, saying they would enhance the department’s efforts to speed up electric transmission lines that connect clean energy to the grid.

“We are very excited at DOE about the potential for streamlined permitting on clean energy projects,” Granholm told reporters on the sidelines of the Global Clean Energy Action Forum in Pittsburgh.

“And I think that holds the greatest promise of the goals we’d like to achieve, which of course is getting to 100% clean electricity by 2035,” Granholm said.

“Community input is important in all of this,” she said. “We have to be very intentional about that, and we’ve got a team that is focused on that as well.”

“Obviously, the transmission process has been ridiculously slow, and so many NIMBY issues related to it,” Granholm said, using an acronym for the “Not In My Backyard” movement.

We don’t think that removing the states is actually going to reduce the time frames,” said Greg White, executive director of the National Association of Regulatory Utility Commissioners, which represents state officials.

He called the permitting proposal “draconian,” arguing it does nothing to solve delays stemming from federal environmental reviews. NARUC has pressed the department to scrap the proposal and bring states to the table.

“The sense is, if they can remove the state authority on siting these, that these projects will proceed quicker—and we disagree with that,” White said.

Enhance federal government permitting authority for interstate electric transmission facilities that have been determined by the Secretary of Energy to be in the national interest.

Replace DOE’s national interest electric transmission corridor process with a national interest determination by the Secretary of Energy that allows FERC to issue a construction permit.

Require FERC to ensure costs for transmission projects are allocated to customers that benefit.

Allow FERC to approve payments from utilities to jurisdictions impacted by a transmission project.