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Grain Belt Express Plants Trees to Hide its Forest

10/16/2022

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I'm starting think GBE's attorneys might not be the sharpest tools on the rack.  Their Reply in Support of Waiver of the 60-Day Notice Requirement veers right off into the weeds, instead of answering what could be the PSC's main question.

Why does GBE need a waiver of the 60-day notice?  We're only talking about a period of a couple weeks here.  What is so gosh-darn important about those 2 weeks to a project that has been languishing for a decade or more?  Those couple weeks aren't going to make or break the project, but they would harm the interests of affected landowners and communities who need time to find counsel and organize their finances to pay to protect their private property from Invenergy's greedy invasion.

GBE says
Grain Belt Express sought waiver of the requirement to file notice 60 days in advance, explaining that it filed the Notice of Intent as soon as practical after the finalization and public announcement of the proposed modifications to the Project.
As soon as practicable on GBE's own little timeline?  How does that meet the law and how does that help landowners?  Landowners had nothing to do with GBE's schedule or change of plans.  This is NOT a reason to waive the law.

Here's the real story:  Those few weeks allow the new "landowner protection" law (that really doesn't protect landowners) to apply to Grain Belt Express.  GBE needs the 60-day waiver to avoid legally filing its application after the law's effective date of August 28. 

GBE says it would voluntarily follow the law if the PSC approves the waiver, but who believes GBE's promises at this point?  GBE also forgets to mention that its "generous" offer to compensate landowners at 150% of GBE's assessed value of their property takes the place of its former 110% value PLUS payments of up to $18K for each transmission tower structure on your property.  Who says that 150% is a better deal than 110% plus structure payments?  Nobody but GBE, the fox inside your hen house.

It's more than obvious that GBE is only interested in a waiver because following the law means GBE would have to, well, follow the law.  Apparently they don't want to.  Instead, GBE attorneys whine on and on and create a thousand irrelevant arguments and insult the other parties, calling them "political theater."

But perhaps the best part of this filing is the attached data response to PSC Staff's question.  Look at this giant list of non-construction activities GBE has done during the 2-year period it had to begin construction without voiding its permit.  But none of that fluff matters.  There are only a couple of items on the list that matter, and they were completed mere days before the deadline.  Seems almost like GBE tried to spend the least amount of money it could trying to pretend it had started construction.
Between the effective date of the Report and Order on Remand in Case No. EA-2016-0358 (i.e. April 19, 2019) and the end of the two year period established by Section 393.170.3 RSMo and referenced by 20 CSR 4240-20.045(2)(D) (i.e. April 19, 2021), Grain Belt Express conducted the following activities in exercise of its certificate of convenience and necessity (“CCN”).

1. 
Constructing access roads of approximately 800 feet in total with such work commencing on April 9, 2021 at approximately State Hwy C & County Rd 141, Braymer, MO 64624 in Caldwell County and April 12, 2021 at approximately Hwy 3, Huntsville, MO 65259 in Randolph County.

2.  Installing foundations for transmission towers on property owned in fee simple in Chariton County at approximately Allen Rd & St. Joseph Ave, Keytesville, MO 65261 and Clinton County at approximately NE 280th St & NE Estep Rd, Turney, MO 64493, with such work commencing on April 13, 2021 in both counties and completed on April 17 and 20, 2021, respectively.
Perhaps GBE only pretended to start construction in order not to lose its permit?  Two transmission tower bases and 800 feet of access road?  That's almost like saying I've bought a hammer therefore I've started construction on a full-size replica of the U.S. Capitol.

Do you think maybe the MO PSC is starting to think that GBE could possibly be lying to them?  GBE lawyers might be more effective at this point using Door Dash to make a vanilla panna cotta delivery to the PSC, stat!!!
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New Award For Impacted Individuals

10/15/2022

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Hold tight to your barf bags, little surfs.  Invenergy CEO Michael Polsky is here to protect your human rights!

That's right, Polsky has received an award for "exemplary leaders across government, business, advocacy, and entertainment who have demonstrated an unwavering commitment to social change and worked to protect and advance equity, justice, and human rights."  At the same time, Polsky is seeking to take private property from thousands of Midwesterners to build his highly profitable renewable energy kingdom.

Do you feel that he has protected your human rights?  If not, consider the history and purpose of this award.  Anyone can decide to hand out an award, but does it make the recipient everything the award says?  Or are these fakey "awards" nothing more than political theater?  You be the judge.
Previous winners of the Ripple of Hope Award include Stacey Abrams, former Vice President Joe Biden, Bono, former Secretary of State Hillary Clinton, former President Bill Clinton, George Clooney, Tim Cook, Dr. Anthony Fauci, Amanda Gorman, Vice President Kamala Harris, Dolores Huerta, Colin Kaepernick, late Congressman John Lewis, former President Barack Obama, Speaker Nancy Pelosi, and Desmond Tutu.
Well, I'm sure Polsky is thrilled to be among his liberal elite pals.  People like you and me, though, we wouldn't be caught dead with these political poseurs.

Polsky says he's "honored."
"Robert F. Kennedy's vision of a better world spanned all areas and industries – he understood that advancing human rights and social justice requires investment in everything from education to energy and the environment," said Polsky. "I'm honored to receive this award and look forward to growing Invenergy's impact as we fulfill our mission as innovators building a sustainable world."
Shaped by Polsky's philanthropic values, Invenergy invests heavily in project communities through an impact program. His humble roots ignited a commitment by him and his family to giving back to many causes including education, entrepreneurship, climate and sustainability, healthcare, women's rights, immigration, veterans, and arts and culture. Most recently, Polsky's philanthropic efforts have been focused on his native Ukraine to ensure the well-being of Ukraine's people, the nation's victory, and ultimate reconstruction. 
The Ripple of Hope Award is inspired by Robert F. Kennedy's most famous speech, the 1966 Day of Affirmation address he gave in South Africa at the height of apartheid: "Each time a man stands up for an ideal or acts to improve the lot of others, or strikes out against injustice, he sends forth a tiny ripple of hope, and crossing each other from a million different centers of energy and daring those ripples to build a current which can sweep down the mightiest walls of oppression and resistance."

Oh, say, an impact program?  You mean buying apple pies and hogs at the county fair?  How positively plebeian!  Simply spread a few bucks around and you can impact the human rights of others as much as you desire.  Commoners are cheap dates, right?

I have an announcement for you!  I am hereby instituting the "Giving Invenergy the Finger" award.  This coveted new award will be bestowed annually to the peasant who best thwarted Michael Polsky's plans to impact them over the past year.

Now taking nominations...
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This Farm Is For Those Who Worked On It

10/15/2022

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Where was Invenergy when Missouri farmers worked their farms?  Marilyn Smith wants to know.
Smith says it is unfair for farmers to have their land used against their consent when they are the ones who have maintained the land for decades. 

"They weren't here when we were bringing in the crops in the fall," Smith said. "They weren't here when my family was bringing in the cows and vaccinating them. They weren't here for planting."
They also weren't there when we did without to make the farm payment and spent the money to nurture and conserve the soil, said another Missouri farmer.  Invenergy wasn't there when any work got done, but now they want to profit from the use of Missouri farmers' land.  Invenergy wants to take easements through hundreds of Missouri farms to use for its for-profit transmission line.  The Little Red Hens of Missouri say
...farmers have earned the right to manage their land as they see fit. “We like to be able to look out at see this without any big power lines,” Smith said.
And it's just not about looks.  Transmission line easements across farms take land out of production and make farming more difficult and expensive.  More costs for Missouri farmers, more profits for Invenergy.
HANDS OFF!
Invenergy purports that Grain Belt Express will bring the lowest cost power in the nation to Missouri.  Except it would do so only if Missouri power companies choose to purchase power from generators in Kansas and ship it to Missouri on an exorbitantly expensive $5.7B transmission line.  All  of a sudden, that "cheap" power from far away gets more expensive than power produced locally that doesn't need a new transmission line to get to Missouri.  Is $5.7B a big price tag for a transmission line?  Compare to MISO's recently approved plan for numerous new transmission lines to move renewable power across the Midwest at a cost of $10.3B.
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Seems like MISO's lines are doing more for less.  This is the pivotal question nobody seems to be asking lately:  Is renewable energy delivered on new MISO lines cheaper for Missouri electric customers than Kansas power delivered via Grain Belt Express?  And here's the thing... Missouri electric customers are on the hook to pay for MISO's new plan, whether they use it or not.  So, $10.3B for MISO PLUS $5.7B for Grain Belt Express, or simply $10.3B for MISO.  Who would want to pay more?

Maybe Ray McCarty, the president and CEO of the Associated Industries of Missouri, who voiced a bunch of misinformed contentions about Grain Belt Express in the news article.  McCarty says,
"Some farmers are not necessarily going to want this going across their farms, but others are going to welcome the opportunity because they could make some additional money for the rights of way," McCarty said.
If there are landowners who welcome this intrusion into their business, where are they?  The reporter didn't seem to be able to find any, just the assurances of McCarty that they exist.  Landowner Marilyn Smith says
"If you ask any farmer, they will tell you they can't pay me enough to put that line through my farm," Smith said. 
There it is.  A farmer who says the land isn't for sale at any price, against a fictional farmer who welcomes it.  The welcoming farmer simply doesn't exist.

McCarty is also misinformed about need for Grain Belt Express.  He said
"And also understand that it may help them get out of a jam if they’re able to get power from that source when otherwise they wouldn’t be able to."

McCarty says projects like the Grain Belt Express are necessities to several parts of the community. 

"Electricity is an essential commodity," McCarty said. "We have to have it to run our farms, we have to have it to run our businesses, we have to have it in our homes."

McCarty and his neighbors already have plentiful electricity produced at local power plants that provide jobs and tax revenue to Missouri communities.  I can't find anything that says McCarty has any expertise in electric engineering -- he's just one of the folks who flips a switch and expects the lights to go on.  Fact:  Grain Belt Express is an optional merchant transmission project that has absolutely NOTHING to do with reliable power or helping farmers "out of a jam" when they can't get power for their farm.

Furthermore, I'm up to my ears in ridiculous claims that Grain Belt is going to "drop off" power in Missouri.  Stop saying that!  It demonstrates your complete ignorance of all things electric.  It's not like GBE is giving electricity to Missouri, like a home-baked pie left on their doorstep.  It's a merchant project and the only recipients are the ones who PAY for it.  It's not "drop off", it's purchase.  Missouri is getting nothing from GBE unless someone makes a purchase.  Currently, GBE only has one customer for just 10% of its available capacity.  There is no "drop off" of 2500 MW.  There is only availability to purchase 2250 MW.

The new "Tiger Connector" may just be the straw that breaks the camel's back.  Invenergy says
The Tiger Connector would expand the reach of the Grain Belt Express in Missouri by bringing power from the main line in northern Missouri to the McCredie Substation in Callaway County, which would send that energy out to thousands more Missouri homes and businesses. 
The "reach" was always there.  GBE always planned to make purchase available at a converter station that could be located somewhere along the DC portion of the line.  The fact is that the connection GBE historically planned to make wasn't feasible.  Without Tiger Connector, GBE has no place to connect to the existing transmission system in Missouri.  But instead of re-routing the DC line to connect at a stronger point of the existing grid, Invenergy decided to add a 40-mile AC connector to get from the DC line in Monroe County to the McCredie Substation in Callaway County.  Having the Tiger Connector only helps Invenergy, it doesn't help any customers in Missouri.  Without Tiger Connector, GBE's plans simply fall apart because it cannot connect. 

Grain Belt Express is the poster child for the stupidity of approving speculative transmission projects without confirmed interconnections or customers.  GBE was nothing but a speculative idea for a transmission project, but yet the PSC permitted it and allowed Invenergy to condemn private property.  GBE's plan was never fully formed, as other non-merchant transmission projects are.  Other transmission projects have confirmed connection points, a need verified by independent grid planners, and customers to buy the electricity.  Grain Belt Express still doesn't have that.  How many times is the speculative GBE project going to change, and how much more is it going to take from Missourians, before its plan is complete?

Fool me once, shame on you.  Fool me twice, shame on me!
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The Sick Stupidity of Big Green Hypocrisy

10/10/2022

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Now that "permitting reform" for electric transmission (and gas pipelines) has failed, the environmental advocate hypocrites are busy trying to make a case why electric transmission permitting "reform" (read federal usurpation) should happen, but not fossil fuel permitting.  There's really no way to try to do this without looking like a giant hypocrite.  It's NIMBY of the highest order -- they love this stuff as long as it's "not in my back yard," but in yours instead.

This guy went way overboard, claiming that electric transmission is "sexy."  Umm, dude, if "big ass" transmission lines make you feel all tingly down there, you need to get your head examined.  I suspect, though, that you're just trying a little too hard.  You probably have a loud fake laugh for your boss's bad jokes, too.  That's really SICK!

I do have to laugh at the way you try just a little too hard to convince Congress (not the legislature, which is a state body) that landowners would be better off if their rights were limited by the federal government.  This is probably the epitome of self-serving justification:
It’s not just state regulatory authorities that reject transmission projects when they don’t see a benefit. Ranchers and other local landowners are sometimes put off by how these (admittedly hulking) metal constructs will look on their property. The lines can be buried underground—or even underwater—but it’s more expensive. Everybody has a price, and you might just as easily find success paying the landowner what you would’ve spent burying the line.
It's just not true that "everybody has a price."  The vast majority of landowners threatened with eminent domain for new transmission line easements say that their property isn't for sale at any price.  And furthermore, it's up to the landowner, not you or any government functionary, whether the money is better spent on landowner compensation or burial to avoid impacts.  If you ask a landowner, they'd rather have it buried on an existing right of way, such as highway or rail, than to have it impeding their use of their land.

​And here's another brainlessly stupid thought:
That makes using existing infrastructure corridors so enticing. We’ve already got tracts of land connecting different parts of the country that are pre-approved for public works projects, like highways and railroads. If we could layer in transmission lines, it would avoid a lot of these land-use conflicts. We could also use existing electricity corridors to pump through a lot more power using modern technology. Issues remain: Our roadways are usually designed with shoulders where people can regain control of their cars if they veer off the road, which doesn’t always leave room for power lines. But many places, such as along railroads, should have sufficient capacity. You could run high voltage, direct current lines through those areas to high-population centers in need of clean energy.
Uhh... weren't we talking about burying transmission on highway and rail corridors?  You can still regain control of your car when you veer off onto the shoulder if the transmission is buried within the right of way but not on the paved shoulder of the highway.  See this report to find out how it can be done.  No one ever suggested that we build electric transmission towers on the paved highway shoulder.  Are you insane?  And, btw, where did you learn to drive?  Anyone who regularly veers off the highway and onto the shoulder to regain control shouldn't be driving in the first place.  You really had to dig to manufacture that "convincing" talking point, right?

This is a good place for an old joke:  Being stupid is like being dead.  When you are dead, you do not know you are dead. It's only painful & difficult for others.

And how stupid is it to willingly be brainwashed by a couple of guys with a political agenda without looking at an opposing view?  And how parochial is it to believe that rural America is your willing production slave for everything from the food you cram into your gaping maw to the power you use to write brainless things on the internet?
And the most productive solar and wind farms will not be located right next door to our population centers. Broadly speaking, they’ll be in more rural areas in the middle of the country, while the majority of people live on the coasts. Many of the rest live in metro areas inland. We need to move clean power from the places where we’ll harvest the bulk of it to the places where we’ll consume the bulk of it.
Wanna bet this guy will be at the head of the protest parade against offshore wind located just a few miles from his coastal home?  Offshore wind is a more reliable resource, too.  This statement is just total and complete garbage:
“Transmission, these big regional lines, often have benefit-cost ratios of 2:1 or 3:1, and that's because you can access resources that are on really low-cost land. Sometimes these solar and wind plants produce twice as much power at a given location than if you get closer to [where it’s used].”
This is just a NIMBY argument of the big green folks who live near the coasts.  And what's that about "really low-cost land"?  You think farmland is cheap?  It shouldn't be.  It's just that is it undervalued when the utility has the ability to simply take it using condemnation and eminent domain.  What makes city land so "high-cost"?  Availability.  At the rate farmland is disappearing, its value is set to skyrocket.  And, btw, what are you going to eat once you've covered all the prime farmland with turbines, solar panels, and transmission lines?  Don't suggest that farmers can simply work around all these impediments.  It would cost them more in time and effort, not to mention the necessities that would be made impossible, such as aerial applications and irrigation.

Betcha can't guess where the author of this idiotic blather lives?
​In practice, these lines would primarily carry energy from the center of the country—between Texas and North Dakota, where the wind really blows—to the East.  Others would carry energy from solar facilities in the South—particularly the Southwest, but also the Southeast—northwards.
So, we need to "build things."
The old environmental movement was about stopping things from getting built. The new environmental movement's about building stuff.
Well, unless those things involve fossil fuels, then we can't build them at all.  We can only build things "for clean energy".  But they can't package their hypocrisy that way because it's much too obvious.  

Turns out they're not really fooling anyone.  It's hypocrisy of the highest order.  And it's really not convincing at all.
The fix is to make it easier to build large transmission lines in anticipation of need, like an interstate highway, and allow power markets to spring up near them like communities along the road. Sen. Joe Manchin’s larger permitting reform bill goes some way in this direction, making it easier to site these lines and setting time limits for the environmental review and stakeholder comment periods. (It would do the same for fossil-fuel projects, which climate activists are not happy about. The bill is on hold after Manchin agreed to pull it from a larger funding bill at the end of September.) The bill would develop predefined corridors where this stuff can go on federal land and make it easier to create these corridors in general. Finally, Gramlich says, it will help with cost allocation, creating a regulatory framework to recover the upfront cost of these large interstate lines.
First of all, this piece is supposed to be a plug for DC transmission lines.  It even blathers on about needing to be converted from AC/DC/AC.  But then it is magically  servicing a power market along the line without being converted back into usable AC.  Whoopsie!  Logic fail!

Second, there's way too much word salad here about what Manchin's permitting reform bill would do.  How does it do those things?  Did you actually READ it and put on your thinking cap?  No, of course not.  You're trying to convince people stupider than you and I posit that that audience is small and shrinking at an amazing rate.  Absolutely nothing you've written about this bill is true.  It's simply not there!
Keeping the lights on is a matter of life and death, and so is transforming our energy system.
Do I need to repeat the joke about how being stupid is like being dead?
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Invenergy Salivates Over Government Handouts

10/3/2022

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Who didn't see this coming?  In last year's "Infrastructure" legislation, greedy transmission merchants inserted a provision whereby the federal government can become a fake "customer" of merchant transmission and pay the merchant with your tax dollars to transmit absolutely nothing to nobody. 

Not being able to secure any customers willing to sign contracts to pay to use merchant transmission has been a problem for the speculative merchants that have been pushing to construct hugely expensive boondoggle transmission lines that nobody wants to use.  A merchant transmission developer, first and foremost, takes on all risk and must pay for its project with voluntary customers.  There can be no backstop funding for merchant transmission, or it's no longer merchant transmission.  It becomes transmission with captive customers that must be regulated to protect the customers.  It can only charge "cost of service" rates that are subject to inspection and challenge by customers and regulators.

But reality and fairness never stops legislators from making the foolish laws greedy private interests want in order to fill their pockets.  It's only our courts that can stop laws that don't make sense, or overreach in some way.

Here's what Invenergy recently had to say about the IIJA's Section 40106 that orders the U.S. Department of Energy to become a "voluntary customer" of merchant transmission that doesn't have enough customers to be financially viable:
Under the Department of Energy’s Transmission Facilitation Program, as envisioned in Section 40106 of the Infrastructure Investment and Jobs Act, the Department of Energy may serve as an anchor tenant on new and upgraded transmission lines, by buying up to 50% of the planned commercial capacity of lines for a term of up to 40 years. Yet, under MISO’s interpretation of Attachment FF and BPM 20, a merchant transmission project with a Department of Energy contract, and meeting Invenergy’s other suggested indicia of being sufficiently advanced stage, would still not be accounted for in MISO’s transmission planning processes unless it had an executed interconnection agreement with MISO or was included in a state or utility IRP. This cannot be a just and reasonable interpretation of MISO’s Tariff and BPM language which requires MISO to “analyze the performance of the Transmission System in meeting both reliability needs and the needs of the competitive bulk power market, under a wide variety of contingency conditions,” to “give full consideration to the needs of all Market Participants,” and consider “a wide range of potential conditions that comply with Federal, State, local and transmission owner reliability standards and public policy mandates . . . as well as other industry trends,” as Invenergy quoted in its Complaint.
'scuse me there, Invenergy... "reliability needs" and "needs of the power market"?  Just because the DOE may sign a contract for free lunch payments to merchant transmission owners, it doesn't mean they intend to take service of even one electron over the transmission line.  And if there is no need for the electricity and/or no customers actually taking service, there is no "need."  There is no market.  There are no actual customers.  And since merchant transmission is a market-based need gamble, no customers means no market.  Just because greedy merchants pulled the right legislative puppet strings to add a legally dubious section to proposed legislation does not create a "need."

And because Invenergy is salivating so hard over Section 40106, I simply have to pop their balloon.  The DOE held a public comment period on how it might implement this ridiculous new law earlier this year.  The DOE asked for responses to answer a number of questions.  Here's one:
Is it advisable for DOE, when selecting eligible projects for capacity contracts, to prioritize projects that have a certain percentage of capacity already subscribed? If so, what should that percentage be? What level of commitment (firm supply versus other types of capacity subscription) should DOE require eligible entities to demonstrate to be selected for a capacity contract? How should applicants be required to document such commitments? Should DOE's capacity be capped as a ratio of the firm subscription obtained before the execution of a capacity contract? If so, what should that ratio be?
DOE only has $2.5B in its revolving slush fund and it wants to rotate it to new projects on a timely basis.  Does DOE want to blow its whole wad on a merchant project like GBE that only has something like 4% of the capacity subscribed and no real prospects?  As if, Invenergy!

Meanwhile, Invenergy asks Missouri and Illinois (and later Kansas and Indiana) to give them permits and eminent domain authority to take land from the good citizens of those states in order to build a transmission line that nobody may ever use.  That's not a "public use."  Until GBE has real customers (not obligations to pay for absolutely nothing from DOE) it's not a public use.  And Grain Belt Express/Invenergy completely fails to mention any of this to the state regulators!  Invenergy just keeps talking about "need" and other meaningless platitudes.

What else did Invenergy have to say in its forbidden Answer to an Answer at FERC?  This very short fictional story caught my eye:
MISO TOs cite to the Rock Island Clean Project as an example of why advanced-stage merchant transmission should not be accounted for in MTEP/LRTP base case analyses.  However, the Rock Island project never had final, non-appealable permits in any state. See Illinois Landowners Alliance, NFP v. Illinois Commerce Comm’n, 2017 IL 121302 (2017) (finding that the owner of the proposed merchant transmission project was ineligible under Illinois law to obtain a required certificate of public convenience and necessity). Rock Island subsequently discontinued efforts in neighboring Iowa in light of the Illinois developments. In contrast, Grain Belt Express has final, non-appealable permits in Kansas, Missouri and Indiana.  Although Grain Belt Express is making minor modifications to those permits approvals, which is typical for new project development, the underlying approvals are sound and Grain Belt Express has significantly advanced the development of the project since securing those permits including securing rights of way and land.
RICL wasn't abandoned in Iowa simply because it lost its case at the Illinois Supreme Court (big time!)  Invenergy seems not to be aware that the Iowa legislature made a law in 2017 that prohibits eminent domain for above-ground merchant transmission lines.  This crazy town revised history fictional story doesn't even make sense.  Without approval of those "minor modifications" (which are actually material changes) GBE doesn't have a working project.  The Grain Belt Express cannot be built without approval of "minor modifications" to its existing permits, and considering that one of those "minor modifications" asks to use eminent domain on a whole bunch of new landowners, there's really nothing "minor" about it.

When the new laws greedy corporations make don't work with the fundamentals of regulation, it's nothing but a hot mess where nothing gets accomplished.  Drool all you want!
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Federal Eminent Domain Across Your Land

9/24/2022

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I warned you last week that slimy senate snake Joe Manchin's secret backroom deal with Chuck Schumer would contain FEDERAL EMINENT DOMAIN to take your land for new electric transmission lines.  Sure enough, when Joe finally showed his hand, all the bad stuff is in his idiotically-named "Energy Independence and Security Act of 2022."

Like this:
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.’’.
Federal eminent domain authority could be granted with the flick of a pen by the Secretary of Energy, if in her opinion a transmission project pushed forward by corporate lobbyists "is consistent with sound national energy policy; and will enhance energy independence".  What the heck does that mean?  We're going to spend trillions building stuff AND TAKING PEOPLE'S PROPERTY because of "policy" created by political hacks?  Isn't all electricity in this country already domestically produced?  What do you mean "energy independence"?  Sounds like plumped up nonsense to me.  I want my country back!!!

The Secretary LOVES this legislation!!  She said


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.
Jenny from the Block is very concerned about you.
“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.”
And then she said
“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.
She wants "community input" but then turns right around and uses a derogatory term intended to dismiss community concerns.  Jenny is an elitist piece of &#!%.  She might as well have said, "Let them eat cake!"

Some states are opposing this nonsense.
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.
Nothing has ever been made faster and better through federal government mandates.

So, what can you do?  Call or write your U.S. Senators and tell them to oppose Manchin's permitting reform legislation.  Do it now, even if you've done it before.  The stakes are too high to sit back and hope things work out okay.  We must act!
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Manchin Deal Gives Transmission Permitting Authority to U.S. DOE

9/17/2022

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Quick... to your battle stations, good citizens!

The biggest hush-hush in Washington these days revolves around West Virginia Senator Joe Manchin's "permitting deal" with members of Congress.  Reports indicate that in exchange for voting for the recent "Inflation Reduction Act", Joe was promised quick passage of new legislation that changes permitting authority for new electric transmission projects.  News articles say that Senate leader Chuck Schumer has promised to attach Joe's proposed legislation to a "must pass" government funding bill that avoids a government shut down at the end of this month.  Time is growing short and perhaps they think they will have a short and quiet glide to the finish line.  Don't go quietly, folks.  This legislation is THE WORST THING TO COME OUT OF WASHINGTON IN YEARS.  You might as well go kicking and screaming all the way.  Let's defeat this horrible plan!

Here's a one page summary of the legislation that was leaked to the press.  See the second to last section on this document:
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.
Here's the actual proposed legislation, in long form.  You can check these talking points in the legislation, like I just did.

Here's a summary:

This legislation will usurp the authority of your state public utility commission to approve siting and permitting of electric transmission.  Instead of your state regulators determining whether the project is needed, economic for you, and properly sited to avoid impacts, the U.S. Department of Energy in Washington will be making a decision whether the project is "in the national interest."  What does this mean?  Considering how political the DOE is, it means that a political deal is made that is completely divorced from need and economics.  It would be about whether the developer who wants to fill his pockets building it has the right lobbyists to get a DOE designation.  Once the designation is bought from DOE, the legislation passes the buck to the Federal Energy Regulatory Commission in Washington to site and permit the project.  What do some appointed bureaucrats in Washington know about how the project might affect you and your community?  They absolutely don't care.  They may simply stamp it "approved."  Once that happens, federal eminent domain authority will be used to take your property for the transmission project.  That's right, folks, FEDERAL EMINENT DOMAIN to condemn and take your private property.

And then the legislation dips into FERC's authority to allocate the costs of regionally approved transmission projects to captive electric customers (this means you).  Currently, only those projects planned and approved by federally regulated electric grid managers, such as MISO or PJM, may be allocated to captive customers who must pay for the project.  However, this legislative mandate requires ALL transmission designated by DOE as in the "national interest" to be cost allocated.  This would include the many merchant transmission projects that are currently being developed outside regional grid plans.  Merchant transmission, by definition, does not have captive customers that are required to pay for their projects.  Merchants must negotiate contracts with voluntary users to pay for their projects.  They cannot simply charge everyone for a project that has not been found needed by independent regional grid planners.  A merchant project gambles that voluntary customers will find it useful and pay for it.  If that does not happen, then the project will not be built.  We should not be forced to pay for politically-connected merchant transmission projects that are not needed for reliability, economic or public policy purposes.  We should not be forced to pay for speculative developer boondoggles in the name of greed.

And here's another foray into FERC's authority to ensure that transmission rates are just and reasonable.  This legislation requires captive consumers to pay for a utility's BRIBES, that's right  BRIBES, to local communities in exchange for accepting transmission impacts.  Long-standing FERC regulations prohibit a utility from recovering its costs to influence transmission approvals.  This includes making bribes to local governments in exchange for their support of the project.  If this legislation passes, we will be paying to bribe ourselves to accept disbenefits and impacts.  How does that make transmission better?  It doesn't.  It just makes it hurt even more.

So, what can we do about this?

Let Joe Manchin know that you do not approve of his "permitting deal" on electric transmission!  Tell him you do not approve of federal eminent domain, federal permitting authority, being forced to pay for speculative projects, and paying bribes to your own community in exchange for allowing your private property to be condemned.  Tell him that new transmission technology allows projects to be buried on existing rail and road rights of way.  Buried transmission on existing rights of way doesn't take any new land and is not opposed by communities.  It doesn't require BRIBES and it doesn't cause project siting delays.

You can email Joe here.  Or you can call his office at 202-224-3954 and tell him you oppose his permitting deal on electric transmission.

And while you're at it, you can also contact your own Congressional representatives and let them know you oppose Joe's "permitting deal" on electric transmission.

Time is short.  Please take a few minutes to register your resistance to this horrible plan now.

Don't let all your hard work opposing the transmission project that has affected you go to waste.  Don't let your victory turn into defeat at the hands of Washington politicians.  Stop this horrible deal now!
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Lessons On Empathy

9/11/2022

1 Comment

 
At the beginning of this year, I opined
These arrogant greedsters will continue to push their narrative that only a boot on the neck of rural America can usher in a renewable energy future.  Instead of working with rural America to find a solution, these folks continue to push for more authority to simply take what they want.
It's still true, and getting worse.  Look what this selfish little baby recently wrote in a liberal propaganda rag.  Blah, blah, blah, we're so much smarter than you and we have to have our way!  We don't want to see energy infrastructure from our little city cracker box stacks.  We need to build an enormous amount of wind and solar and transmission in your back yard right.the.heck.now. and you don't matter.  You know how it goes, dear reader, glib name calling from clueless partisans.

But wait... look at this.  I mean REALLY look at this!

Australia has spent several years already trying to do the same thing this country has only recently started to attempt -- overbuilding wind and solar in remote places, along with new transmission to connect it to cities.  Australia is several years ahead of us in this game.  But it's not turning out so swell.  Massive public protests against the new transmission have happened, and the growing movement against this "clean energy" plan actually threatens the plan itself.  The opposition has played this to a stalemate.  Transmission cannot move forward.  And because it can't move forward, the whole "transition" is being delayed.  Little do these elite babies know that anger against unwanted infrastructure, if left unchecked, can turn into anger against clean energy and derail the entire thing.  The boot on the neck of rural Australia has not worked.  It won't work here, either.

Australia's experience is a lesson we need to learn now, before our own "transition" begins in earnest.

The lesson is here.  Literally right here.

Australia's Energy Grid Alliance has recently released a new report, Acquiring Social Licence for Electricity Transmission, A Best Practice Approach to Electricity Transmission Infrastructure Development.

Doesn't sound like much -- just more trendy speak... social license?  However, once I got reading, I was hooked.  This report tells the most important truths about transmission opposition and why the U.S. Government's current approach to put a boot on the neck of rural America will fail, just like it did in Australia.  I'm not sure when I've seen all the right social/behavioral/community studies together in one easy-to-read report like this... probably never.  Maybe you'll think it's a bit geeky and the Aussie-speak requires a bit of translation while reading, but you won't be sorry you invested the time to read it.  After reading, please feel free to forward it to every elected official, regulator, reporter, transmission developer, and environmental group you can find.  This is how we need to begin:  Tear  down the current system we've been using to build electric transmission and start from scratch.

If you read that stupid NYT editorial linked at the beginning of this blog, you'll see that self-appointed "advocates" fueled by Big Green money are pushing for the "
talk to them early and pay them more" approach that has completely failed in Australia.  Why would we take this approach when it is sure to fail (and waste a bunch of time in the process)?  Turns out these self-appointed "advocates" don't know diddly squat about opposition to electric transmission, which makes them suggest incorrect (and outdated) ideas.  I'm looking at you, Niskanen Center... this wouldn't be the first time I've told you to shut up and go away because you don't speak for any electric transmission opposition group.  You speak for the people who intend to get rich building transmission.  You are the original fox in the hen house.  The Energy Grid Alliance Report talks about people just like you...
At a recent Australian energy conference, the program indicates that the energy industry is acutely aware of, and concerned about, the urgent need to develop trust and acquire social licence for transmission. So much so that a panel discussion specifically focussed on the best ways to combat anti-transmission line sentiment. The panel included key industry representatives from the Victorian Department of Environment, Land, Water and Planning (DELWP), the Australian Energy Infrastructure Commissioner, AusNet Services, Powerlink Queensland, Nous Group and CutlerMerz.

Interestingly, the panel did not include members of the public, representatives from community advocacy bodies or community groups calling for better transmission planning and framework reform.

T
his raises an important question; how can anti-transmission sentiment be truly understood by the industry if those representing the Australian public are not involved in the discussion? The lack of public inclusion in forums such as this suggests there is still much work to be done in understanding best practice engagement principles.
I've long written about silly industry conferences where they talk about ways to control or neutralize opposition, and consistently get it wrong.  Happens in Australia, too.  And it's happening here right now, where environmental groups tell regulators how they should control us.  Hypocrites of the highest order!  We are never invited to participate.  They don't want to hear what we think, what we want, what we feel.  They don't want to hear from us, period.

Oh, sometimes they pretend to allow us "meaningful participation," but it's like shouting into a pillow.
Firstly, communities are not upset that their concerns haven't been heard as there is no doubt opposition has been voiced. Communities are upset because their concerns are not being understood, listened to or respected, with collaborative action being taken to understand and accommodate this opposition to bring about a more mutually beneficial outcome. There is a significant difference between being heard and being understood. Communication is not simply about the transmission of information; it is about the reception and understanding of it. Genuine engagement is then demonstrated by taking meaningful, constructive and collaborative action.
But it doesn't stop them from pretending they know what we want better than we do.  They think they just need to "educate" (indoctrinate?  brainwash? fool?) us better about all the "benefits" we will receive.
Secondly, in the case of the WVTNP, there are no foreseeable benefits to communities expected to carry the burden of 190km of overhead transmission. How can the industry better sell the benefits to host landholders and neighbouring communities when there are no benefits to sell?
And this report does one of my most favorite things ever!  It introduces a rarely used word from the Brits that I plan to use the heck out of:
             DISBENEFITS
Disbenefits are the opposite of benefits.   They are disadvantages. They are costs to landowners and communities.  They are harms.  They are impacts.  They are uncompensated.  They are forever.  A transmission line visits many disbenefits on the landowners it crosses.

When the actual affected people are not equal partners in the solution, nothing gets solved.  The newest thing being pushed by environmental groups in the U.S. is earlier engagement with communities and more compensation.  This doesn't work because it's not about giving opposition a seat at the table, it's about "educating" and bribing them to accept disbenefits.  Here's what the report says about that:
The energy industry and governments can do more to understand and appreciate that community benefits and compensation may not be the quick-fix solutions they hoped they might be. In fact, pushing the ‘talk to them early and pay them more’ agenda is very likely to further dilute trust, increase opposition and dissolve any credible opportunity to acquire social licence. Without empathy in the social licence and public policy equation, it will be near to impossible to develop trust for transmission.
What was that?  EMPATHY!!  There is absolutely no empathy for affected landowners and communities (see NYT op ed I started this blog with).  These arrogant and elite babies who would give their last dollar to a homeless person on their way home from work, or let a hardened criminal out of jail, have absolutely no empathy for hardworking farmers or rural residents from all walks of life.  The big environmental groups and our big government are also devoid of empathy for these folks.  It's almost like they take perverse glee in making rural folks shoulder the burden of new energy infrastructure.... because maybe they voted for another political party.

The report puts a high priority on empathy, which it describes like this:
Empathy is the ability to emotionally understand what other people feel, see things from their point of view, and imagine yourself in their place. Essentially, it is putting yourself in someone else's position and feeling what they are feeling. The ability to feel empathy allows people to "walk a mile in another's shoes". It permits people to understand the emotions that others are feeling.
I challenge every regulator, elected official, and clean energy disciple to really stretch themselves to learn and practice empathy.  That's where progress begins.  We're not your enemy.  We all inhabit the same planet.  You wouldn't like it if we imposed our will on you to place energy infrastructure in your back yard.  Be honest and admit it.  That's the first step.  Only through mutual understanding will we create a fair and just energy system.
The admonition to walk a mile in someone else's shoes means before judging someone, you must understand his/her experiences, challenges, thought processes, etc. Truly listening to another persons view creates empathy, something that community sentiment suggests is lacking within the energy industry.

It’s not difficult to understand why it may be challenging for the energy industry to demonstrate empathy. For decades, its has been insulated from the need to consider social or environmental externalities and has rarely had to meaningfully engage with, or have empathy for landowners and communities.
Are we turning the page, or continuing the unjust rationale to visit the needs of the many on the lives of the few?
Empathy helps develop trust; therefore, it is important that transmission network planners and policy makers spend time to consider, understand and respect landowner and public perspectives, experiences, and motivations before making a judgment about them and asking rural communities to shoulder the burden of overhead transmission for the benefit of the masses. Economic benefits, community benefits, compensation, the climate, environment, emissions, jobs, and green energy, are often wielded by governments and the industry to garner public support for overhead transmission. While there may be truth in some of these benefits, many in the community view this strategy as an intentional attempt to reduce credible objections to those of NIMBYism (Not in my backyard). For many, this strategy demonstrates a concerning lack of empathy as to why overhead transmission projects are being objected to in the first place.

In addition to legitimacy, credibility and trust, empathy should be added to the list of social licence components. Without empathy, it is impossible for the other three components to exists. Without empathy, it will be challenging to garner community support. To develop empathy, it is necessary to first explore the deeper reasons for objection to offer these objections the respect and attention they deserve.
And you can only get that from affected landowners, not the puffed up environmental actors who hate them.  Landowners need a seat at the table.  That means upfront, where policy is created, not at the end of the line where they may have 2 minutes to tell an uninterested regulator why they object to the transmission project that has been thrust upon them as a fait accompli.

How familiar does this sound?
When discussing compensation and engagement with potentially impacted landowners throughout the eastern states of Australia, many have indicated, in no uncertain terms;

‘I'll never sell'; 'We will not be bought off'; 'No amount of money will compensate for the impact on our properties, community and environment'; 'We will not risk our kid's inheritance'; 'Our land is our superannuation, we will not sacrifice that'; ‘This is our livelihood, who has the right to take that away.

W
hen speaking with stakeholders in the energy industry and those living in more urbanised environments, reactions suggest a level of confusion. Comments often conveyed indicate it’s difficult to comprehend why people would not accept payment for the burden they are expected to carry.

'They are only transmission lines'; 'We drive past them every day to work, what's the issue'; 'This is the price we must all pay for progress and to reduce our impact on the climate'; 'Transmission towers remind me of our engineering mastery'; 'It's only farmland, plant your potatoes somewhere else'.
Transmission opponents have all lived this.  Over the past 15 years, I have listened (with empathy, btw) to hundreds of landowners affected by different transmission projects.  Sadly, I've often seen the dismissive attitude of the unaffected as well.  This section is 100% accurate.

So, how do we get past this to develop understanding and empathy?
To understand this, we need to dig a lot deeper than early engagement and financial motivation. We need to understand the connection between people, the environment, the land, and rural areas. We need to understand the person-place interaction that leads to attachment to place. This connection to place is experienced by traditional owners, landowners, neighbours, and visitors alike. The strength of this attachment often surfaces under threat of loss of place.
We need to recognize and understand this:
Family farms are a unique institution, continuing through time in a world where considerations of hard work, long-term thinking and commitment are often sparse. Families in agriculture have long provided a steady backbone to rural Australia, serving as stewards of our natural resources and taking care of the neighbours, communities and environments in which they live. Because of their dedication to preserving farm operations and improving land for native wildlife, farm families are very emotionally close to their way of life and to the land on which they live. Many see themselves as temporary stewards of their land, managing it for future generations, just as their great-great-grandfather might have done for them.

A statement by one landholder was, “I don't have a sense that I own it as such. But I've been given the privilege to influence it, to protect it, to enhance it and among other things – stop other people influencing it, without me giving them permission."
Ultimately, here's what needs to be understood and accepted by everyone:

New transmission only made necessary by the "clean energy" transition must be willingly accepted by those asked to host it.  It won't happen through force.  It can only happen when we set firm boundaries against new sacrifice and put on our innovative thinking caps.  How might new transmission, or better yet a new energy system, be built that doesn't cause unnecessary sacrifice?  One answer might be building smaller systems for localized use and dispensing with the need for big new transmission altogether.  Another might be rebuilding existing transmission to increase its capacity.  But a favorite idea, by far, is to build new transmission on existing linear rights of way, such as roads or rail.  Better yet, burying this new transmission on existing rights of way is an idea that has already gained acceptance with landowners in the U.S.  It is popular in Australia, too.
It’s also important to note that a cost seen by some, is viewed as an investment by others. Communities impacted by proposed overhead transmission projects argue that despite potential increase in capital by avoiding a shorter more impactful route, use of existing easements, longer least-impact routes or an investment in undergrounding (particularly HVDC), is a long-term economically viable investment in achieving climate change objectives, protecting our environment, avoiding land use conflict, and providing increased redundancy, resilience and reliability to our transmission networks. Despite the increased cost, Star of the South, a private development, is undergrounding its transmission to minimise the environmental impacts. This has been well received by potentially impacted communities.
Of course, each community is different and it's important to bring them to the table before any decisions are made about how the project will look, or where it will go.  However, a project that doesn't create any impacts on privately-owned land, such as one buried on existing right of way is a guaranteed winner with any group of landowners.  You don't bother them, they won't bother you.  In fact, they might even *gasp* support you!!!

So, as Congress takes on the task of trying to improve energy infrastructure siting and permitting this fall, it's important to let your representative know that a boot on your neck will not work.  It didn't work in Australia, and it's not going to work here.
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FERC Complaint Changes Everything You Thought You Knew About Grain Belt Express

9/8/2022

1 Comment

 
Isn't it high time to stop Invenergy's posturing about how "advanced" Grain Belt Express is, or how much of a "sure thing" it is.  Here's the reality I've been continually serving up for years, now bolstered by both MISO and MISO transmission owners:  Grain Belt Express is a speculative project that can't be completed because it doesn't have enough customers.  Here, I even created a fresh one!
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Invenergy is so full of themselves lately that maybe now they even believe their own exaggerations about how "needed" they are?  What else could explain the recent Complaint Invenergy filed against Midcontinent Independent System Operator (MISO) at the Federal Energy Regulatory Commission (FERC)?  At any rate, filing that complaint could begin a new section of Invenergy's Grain Belt Express scrapbook entitled "The Beginning of the End."  Well, if Invenergy is keeping a scrapbook, that is....

Invenergy filed its complaint in the beginning of August, claiming that MISO wrongly excluded GBE from its recent Long Range Transmission Plan (LRTP).  Invenergy said that although MISO's rules require a merchant transmission project to have a signed interconnection agreement (IA) or to be included in a utility's state-approved integrated resource plan in order to be a part of the plan, Grain Belt should also be included because it is an "advanced stage merchant transmission" project.  Invenergy said that by failing to include a completed and operating GBE in the model of the MISO transmission system that is used to identify new projects, MISO was hurting ratepayers by making them pay for projects that might not be necessary if GBE was included.  In plain English -- some of the projects that MISO approved in its LRTP may be a better deal for GBE's prospective customers!!!

Here's a map of MISO's recently approved Tranche 1 LRTP.
Picture
As MISO confirmed in its Answer to the Complaint, Invenergy's problem is the series of lines beginning at "Orient" Iowa (its the name of a substation, not necessarily a town) connecting to Fairport, Missouri, connecting to Zachary, Thomas and Maywood, Missouri, and ending at Meredosia, Illinois as shown on the above map.
On March 17, 2021, MISO laid out its initial roadmap for LRTP transmission solutions based on the Futures analysis. The initial roadmap included a proposed line from central Iowa, through northern Missouri, with two offshoots further south into Missouri with one in a similar area as the proposed Point(s) of Connection for the GBX Line, and finally into central Illinois.
 
It was announced during that meeting that the analysis had been completed on the proposed Transmission Solutions linking central Iowa to Northern Missouri to central Illinois and that those upgrades would be included in the LRTP portfolio. It was only after this announcement that Invenergy approached MISO to express its views regarding the GBX Line and how it interacted with LRTP.
Or, as Missourian Norman Fishel said in his Comments on Invenergy's complaint filed at FERC:
In comments to MISO, Invenergy claimed that “[f]ailure to account for the GBX Line may cause economic harm to GBX.”

Grain Belt Express acknowledges how it intends to edge out new MISO projects by taking their place:

“Across the Midwest and Great Plains, several potential transmission projects have been proposed over the next decade to address regional reliability needs, enable the delivery of power to load centers, reduce congestion, and unlock renewables potential. While there still may be a need for localized upgrades, given that the Project addresses these broader goals, it stands to logically reason that the Project could plausibly defer/eliminate the need for certain future major transmission developments."
Well, talk about overestimating your own importance!  Invenergy must think that it can control MISO's planning the same way it has grabbed various state politicians by the scruff of their neck and owned them.

A merchant transmission project cannot just horn into a regional transmission plan and claim it's accomplishing the same goals and therefore make the regional transmission organization cancel its own projects.  It just doesn't work that way.  MISO plans its own system.  MISO also manages generator connections like GBE to make sure they don't compromise the system.
Invenergy also compares the expected timeline of its proposed projects to the expected timelines of the LRTP Tranche 1 projects, but that comparison does not help Invenergy’s argument, even if taken on its face value. Under the Tariff, the MTEP is “developed to facilitate the timely and orderly expansion of and/or modification to the [MISO] Transmission System.

Including projects without sufficient certainty, regardless of timeline, does not advance system reliability.
In other words, MISO cannot count on speculative merchant transmission projects to ensure reliability.

Couple other things MISO said in its Answer, which I urge you to read carefully:
  1. GBE kept changing its interconnection requests in both size and location.
  2. GBE still has an interconnection position in Ralls County.  MISO doesn't know what its intention is with this.
  3. GBE's interconnections are all unidirectional -- they have asked for permission to inject energy into MISO, not withdraw it.  Beware any entity that has been promised service from MISO to PJM (MJMEUC).  Or any entity that has been told how GBE could reverse directions and move power from east to west in an emergency.  It just can't happen.
  4. "Invenergy has only requested to operate the GBX Line as a long generator lead line."  That's a quote.
  5. "Adopting Invenergy’s proposals will reduce the precision of MISO’s planning models by making them subject to an MHVDC [merchant] Connection Customer’s changes or withdrawals." and "Invenergy’s proposals may inappropriately assign costs driven by the GBX Line to MISO load. The Commission should not allow Invenergy to unilaterally mold MISO’s MHVDC connection and planning processes to fit its commercial proposals."
  6. No load serving entity (electric utility) in MISO said it was "planning on the GBX Line as a resource to meet their plans/goals."
  7. Invenergy told MISO that Ameren was ordered to include GBE in its Integrated Resource Plan by the MO PSC, but "Ameren’s 2022 IRP update does appear to not mention the inclusion of the GBX Line."  Sounds like another case of Invenergy using stale information to misleadingly bolster its project.  Be sure to verify everything Invenergy says from now on (more on why in the section of this post about Norm Fishel's comments).
  8. MISO's rules "protect MISO customers from unjust and unreasonable rates that could result from the incorporation of premature or incorrect assumptions about future projects without sufficient certainty."  Here's the thing... GBE can be cancelled at any time due to lack of customers.  If MISO counts on it and that happens, MISO would have to quickly plan projects to take its place that may be less efficient and more expensive.
  9. "The reality, however, is that projects and business plans change and the GBX Line proposal is a prime example..."
  10. "[Invenergy's] proposed definition of “Advanced Stage Merchant Transmission” is completely unsupported."  Read Norm's comments to see why "Advanced-stage merchant transmission has no definition, and even seems to change depending upon the venue in which Invenergy finds itself.  In its recent Missouri Application, Invenergy claims that its project has not yet reached an advanced stage..."
  11. MISO explains how adding a speculative merchant transmission project to the models before the interconnections are approved causes new lines to support those interconnections to appear in the plan earlier, where they are paid for by captive ratepayers, instead of the merchant that caused them... "...relieving Invenergy of its obligations to pay for upgrades needed to accommodate its interconnection." 
  12. "MISO is concerned that the Complaint is merely a vehicle to address one entity’s commercial preferences or use MISO’s processes to enable a specific project rather than an identification of a genuine need."  And if Invenergy was looking for MISO to support building GBE, it can now be sadly disappointed.  All the malarkey about reliability, need, lower prices can now be chucked out the window.  Reliability, need and cheaper electricity prices are what MISO does.  MISO says GBE is not needed for any of those purposes.  Who are you going to believe?  An impartial grid planner or a self-interested profit-seeking corporation?
And if you think the MISO Answer is derisive towards GBE, don't miss the Protest of MISO Transmission Owners (TO).  This entity consists of a large group of utilities that own transmission lines that serve MISO and who have fully participated in MISO's planning process which came up with the new lines Invenergy objects to, including Ameren.  The TOs don't mince words.  You should probably read this to yourself using a sneering voice:
Invenergy also fails to show that the GBX Line should receive special treatment and circumvent the MISO planning process. As a project that is not yet certain, MISO properly excluded the GBX Line from the planning studies for LRTP projects.
The TOs go on to point out why GBE is speculative.
Invenergy claims that its GBX Line, a merchant high voltage direct current (“MHVDC”) transmission project designed to carry up to 5,000 megawatts (“MW”) of energy, should have been accounted for in MISO’s transmission planning analyses even though it has not yet obtained all necessary approvals and interconnection agreements, and its prospects for achieving such statuses are not at all certain.
The TOs make other points too righteous to ignore:
  1. "In the instant proceeding, Invenergy asks the Commission to render MISO’s transmission planning process null by compelling MISO—after MISO’s Board approved LRTP Tranche 1 Portfolio on July 25, 2022—to conduct a sensitivity of the Tranche 1 projects that accesses the potential impact of the GBX Line assuming it is ever finished, based solely on an unsubstantiated allegation that the Tranche 1 benefits metrics may be flawed because they did not account for this speculative project."
  2. Invenergy's attempt to disrupt MISO's planning is "particularly egregious."
  3. "Unless and until the firm generation and load customers are identified by Invenergy, the GBX Line cannot be modeled..."
  4. "Invenergy had multiple opportunities to participate in the numerous stages of the process whose outcome it now seeks to upend."  But it did not until it thought the process might hurt its project.
  5. "Invenergy repeatedly describes how much money it has expended toward completion of the GBX Line as evidence that the line is at an advanced stage near completion. However, a developer can spend many years in development and millions of dollars on an MHVDC project that will never be completed. For example, the Rock Island Clean Line project (“Clean Line”) failed to reach completion despite its half-decade and multi-million dollar efforts.  Had MISO assumed the Clean Line project would be constructed in its long-term planning processes based simply on the time and money that had been invested in the project, there is no telling how many changes and new plans would have been needed once it became clear the project would not go forward."
This quote deserves to be highlighted:
While Invenergy explains the status of the GBX Line noting the number of approvals and permits it has obtained, the prospects for the project are far from certain. For example, as Invenergy concedes, permits are still required in one state. In addition, on August 24, 2022, Invenergy submitted an amended Certificate of Convenience and Necessity Application in Missouri to request significant changes in the GBX Line.   Invenergy also has not yet executed interconnection agreements with half of the transmission systems it proposes to interconnect—MISO and PJM.
Speculative... far from certain... not advanced enough to be included in regional transmission planning.  So, you might ask youself, what the living spit is the Missouri Public Service Commission doing allowing such a project to CONDEMN and take land from the good people of Missouri?

And, let's end this section with the following quote from the TOs:
The Commission should deny Invenergy’s attempt to obtain preferred treatment for the GBX line.
Don't miss the Comments of Missouri's own Norman Fishel asking that FERC deny Invenergy's complaint.  They were written for "real people" and are perfectly understandable.  Norm gathers information from Invenergy's various applications, comments, and permits to show, "Grain Belt Express seems to be like a chameleon, its description changing depending upon the venue it finds itself in, and the goal of its filing." 
Norm says that GBE doesn't even consider itself to be an "advanced-stage" project.  He also points out that GBE  has NO state approvals, since all the state permits will have to be re-approved due to changes in the project.  He points out that GBE only has one valid interconnection, since it has proposed changes to its SPP interconnection in Kansas that have not yet been approved.  And, perhaps my favorite part is where Norm baldly demonstrates that Invenergy might be a... well... a liar.
In its Complaint, Invenergy claims “Grain Belt Express has secured voluntary easements for over 75% of the necessary right-of-way in Kansas and Missouri.” However, in its Application in Missouri, Grain Belt claims it has “[a]cquired 72% of all easements required for the Kansas and Missouri portion of the Project.” While only a difference of 3%, it is notable that the percentage of easements acquired went down in the two weeks between the filing of this Complaint and the filing of the Missouri application.
So Invenergy told FERC on August 8 that it had secured over 75% of the easements, and then on August 24 told the MO PSC that it has 72% of the easements.  Did a bunch of easements get unsigned in that 2 week period?  If not, Invenergy is a flat out liar.  You can't believe anything a liar tells you.  Word to the wise.

Another section of Norm's comments deals with all the inconsistencies in GBE's Negotiated Rate Authority from the Commission and questions whether Invenergy has invalidated the Commission's approval to negotiate rates with potential customers.  Without Negotiated Rate Authority, Grain Belt Express cannot sign contracts with customers.

And maybe that's what Invenergy intends?  Norm clips this quote from GBE's Illinois application:
“Subject to additional oversight and approval by the Federal Energy Regulatory Commission (“FERC”), Grain Belt Express may sell and/or lease an undivided interest in the project to potential buyers and/or lessees, and Grain Belt Express and those buyers/lessees may seek to provide transmission service over the line to eligible customers as defined by FERC on a non-discriminatory basis under a FERC-approved open access transmission tariff (“OATT”). Any co-owner or lessee of Grain Belt Express that seeks to provide transmission service will be required to operate pursuant to an OATT on file with FERC that will meet the requirements of the Federal Power Act and FERC’s regulations. Grain Belt Express may also sell a cotenancy interest or lease a long-term leasehold interest in the transmission line, in which case it is not providing transmission service to such buyer/lessee because the buyer/lessee has control over that undivided interest”.
Invenergy says it may sell "interests" in the projects to other private parties for their own private use.  Those parties who buy an "interest" may sell service to other parties for public use, but they may also keep all the transmission service for themselves.  If they kept it to themselves, it would be nothing more than a private-use generation lead line, which is a private electric roadway for a generator to connect to the transmission system.  The BIG HUGE problem with this is that without offering its transmission service to all entities through a public offering, Grain Belt Express is no longer "for public use."  And if GBE is not for "public use" then it is not entitled to use eminent domain to condemn and take property.

It sure looks to me like GBE is only using FERC's Negotiated Rate Authority as a fig leaf to cover its real plan to use the project for private use without opening it up to public bidding.  Looks like it's going to take land now under false pretenses, and then privatize its project later once it has all the land it needs.  This is a GIANT stopper for both the Missouri PSC and the Illinois Commerce Commission (and the Illinois Supreme Court, who had serious questions about RICL's "public use" that were never addressed in that case).  Without being for "public use" the project CANNOT USE EMINENT DOMAIN.

So, to sum up this exceedingly long blog...  We've got a whole new ball game, folks! 

MISO has approved new projects that will bring Iowa wind electricity to Missouri and Illinois, most likely for a much cheaper price that GBE has been offering.  This happened because GBE has failed to be built when it said it would be built.  A stone rolling downhill, or a grid with hungry customers, waits for no man/project.  MISO says that GBE is not "needed" for reliability, economics, or any other reason.  MISO and its TOs think GBE is far from certain to be built.  This is quite refreshing because for so long Invenergy has been trying to gaslight regulators, legislators and landowners about how it is needed for reliability and economic purposes and is ready to be built.  Turns out none of that is true.  It's all been a house of cards.  Reject everything you thought was true about Grain Belt Express and embrace the new reality this complaint demonstrates.  Grain Belt Express's reign of terror across the Midwest is about to end.  The sooner Michael Polsky realizes this, the less money he will lose at the end.  Let's hope he's not as stupid as Michael Skelly was... dumping his last penny into projects that never become reality.

When you poke a stick into the lion's cage, sometimes the lion bites your head off.

The End.
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Missourians Protest Unnecessary Transmission Project

9/2/2022

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Picture
The good citizens of Missouri peacefully protested outside the Public Service Commission this week.  The citizens are opposed to the plans of Chicago-based renewable energy company, Invenergy, to use eminent domain  to run the high-voltage electric transmission Grain Belt Express Tiger Connector line through their properties.
Picture
The successful protest attracted lots of attention from the media.

Such as this story on KOMU.  Maybe someone wants to ask Patrick Whitty at Invenergy who the other customers for 2500 MW of transmission capacity in Missouri might be, since his "39 cities" have only signed up to purchase less than 10% of the available capacity?  Those 39 cities aren't going to generate enough revenue to build a $5B electric transmission line across 4 states.  Can we apply a little common sense here?

And this story in the Fulton Sun.  Isn't that gracious of Invenergy to "thank the citizens for their feedback?"  What a bunch of lousy fakes!

And this one on KRCG.  Short and to the point, heavy on the pictures.

And there are plenty more. 

Too bad for Invenergy, who tried to hide or minimize the Tiger Connector project in recent press releases.... one of which got absolutely no media attention at all.

The cat is out of the bag now...
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Bravo, Missouri citizens!
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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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