Because the rest of us are grossed out by such barbaric behavior.

But it does help us to assign nicknames.  So that when someone refers to "Nosepicker" in a sidebar, no further description is needed.  We all saw you do it.  Numerous times.

FirstEnergy tries to block filmmakers at hearing.

Yes, we're laughing at you.
The only surprising thing about Saturday's Gazette-Mail story about Governor Tomblin's political game-playing with PSC appointments is that it happened at all.  Bravo to the Gazette and reporter Andrew Brown for this informative article, "Governor doesn’t have a timeline for filling Public Service Commission seat"!
"Doesn't have timeline" or just doesn't have time?  I got the "doesn't have time" excuse from the horse's mouth back in 2011 when he was running for Governor and I asked him why he was waiting to fill a PSC seat. "Too busy campaigning."  Right.  Along with the lies, I also noticed his smile was completely fake... it didn't reach his eyes.  He needs to take some lessons on fake smiling from pro fake-smiler Joe Manchin.  But, I digress.

Tomblin has been "too busy" to either re-appoint Commissioner Jon McKinney, or appoint a replacement for him since 2011.  That's FOUR YEARS that McKinney served at the daily whim of Tomblin.  Now McKinney has finally left the utility stable, and Tomblin is content to leave his seat open.

PSC Commissioners that are appointed are supposed to be insulated from political influence by becoming independent once appointed.  The appointer (Governor) supposedly loses power over the Commissioner once he/she is appointed.  However, by allowing appointments to expire, and the expired Commissioner to continue to serve, a Governor may control the day-to-day decisions of the Commissioner as long as this lasts (4 long years!).  If the expired Commissioner makes one misstep, he can be gone the next day if the Governor suddenly decides to appoint someone else.  This is a filthy practice that should be illegal.  But it's also how Governor-schmoozing corporate utility companies continue to stomp on West Virginia ratepayers.

It's not like Tomblin "doesn't have time" to make any appointments to the PSC.  He managed to promptly re-appoint utility lawyer Michael Albert in 2013, when his second term expired.  He also managed to appoint Brooks McCabe to the empty seat of former Commissioner Ryan Palmer, when he left in 2014.  McCabe is a former legislator who has absolutely no background or education in utilities regulation or consumer protection.

So, who shall fill McKinney's seat, now that it's finally vacated?  That's what the Gazette-Mail investigated:
Gov. Earl Ray Tomblin has no plan to appoint a third member to the West Virginia Public Service Commission, even though several people have expressed interest in the position or recommended others they believe would fit the post.

Emails and communications obtained through a Freedom of Information Act request show that numerous people have contacted the Governor’s Office since January, asking Tomblin to confirm them for the post or to consider their preferred candidates.

The list of people seeking the governor’s attention include a former state senator, a city mayor, a retired engineer, a member of the state’s rural water association, a managing member at one of Charleston’s largest law firms and a lobbyist for First Energy, the parent company of MonPower and Potomac Edison, two of the state’s largest electric utilities.
Hmm... sounds like a bunch more utility puppets, political favors, and inexperienced stooges.  Don't we have anyone in West Virginia with a background in consumer issues?

Here's two people you DO NOT want to see appointed:
An undated note left for the governor shows that Sammy Gray, the state affairs director and a registered lobbyist for First Energy, called to recommend two people for the commission spot. According to the note, Gray called to let Tomblin know that he supported Mike Castle, the Department of Environmental Protection’s director under Gov. Cecil Underwood, and Sam Cann, a former Democratic state senator from Harrison County, for the seat.
And what experience do these two have with consumer protection?  None.  However,
When contacted about his recommendations, Gray sent the request for an interview on to communication officials at First Energy.

“We believe both individuals possess solid experience with policy and energy matters that would help them make rulings in complex regulatory cases,” Todd Meyers, MonPower and Potomac Edison’s external communications manager, wrote in an email response. “Of course, the ultimate decision on who is appointed rests solely with the governor.”

First Energy’s recommendation of candidates for a utility commission, which ultimately regulates the company, is not out of the ordinary, according to Meyers.

“In the past, we have recommended individuals whom we believe to be qualified candidates for similar positions, both in West Virginia and elsewhere in our service territory,” Meyers wrote. “Again, others ultimately make the decisions on who is selected.”
Of course.  The utilities that own the governor own his appointments to the PSC, however the utility recommendations protect the utilities, not consumers.

Who else has been recommended?
In an email from April, Michael Basile, a managing member at Spilman Thomas & Battle, a Charleston law firm that represents clients like the West Virginia Energy Users Group in front of the PSC, asked the governor to consider attorney Susan Basile, his wife.

In the 1990s, Michael Basile worked for Gov. Gaston Capterton, the Attorney General’s Office, the West Virginia Development Office and later assisted in the transitions of Gov. Bob Wise and Gov. Joe Manchin. Basile, who has served as chairman of the Charleston Area Alliance and the Charleston Regional Chamber of Commerce, also is a registered lobbyist at the state capitol, where he has represented companies like DuPont, Chevron, Chesapeake Energy, DIRECTV and Dish Network.

In his email, Basile credited his wife’s qualifications and said she was a “big fan/supporter of GERT,” apparently referencing an acronym for Governor Earl Ray Tomblin.
Right... because being a fan of "GERT" translates to utility experience and a background in consumer protection.  Not.

Amy Swann, director of the West Virginia Rural Water Association, suggested the governor should consider one of her longtime colleagues and former PSC employee, Dina Foster.

Swann said Foster — now the manager of the Pea Ridge Public Service District, in Cabell County — has first-hand experience in utility issues and has the personal characteristics needed to make a good commissioner. With so many important issues being decided by the PSC, Swann said, Foster would be a valuable addition to the commission.
When Bill Wooten, a former Democratic state senator from Raleigh County, contacted the Governor’s Office earlier this year, he was hopeful he would be appointed.

With his experience in utility regulation from a legal and legislative policy perspective, Wooten thought he was qualified for the position, and he believed in his ability to weigh the needs of utility companies and their customers.
And then there's
John Manchester, the mayor of Lewisburg, also submitted his credentials for consideration.

Manchester, who previously worked for the Tennessee Valley Authority and has dealt with utility regulation as Lewisburg’s mayor, said his experience has prepared him for the position.

“I pride myself on being a mediator, a man who tries to find solutions to issues,” Manchester said.
And also
Allan Tweddle, a resident of Kanawha City and a semi-retired engineer, put his name in after having several people ask him to apply.

In his communications with the Governor’s Office, Tweddle listed a long list of people who could testify to his “commitment” and “open-mindedness.” While Tweddle worked with Southern California Edison, an electric utility on the West Coast during his career, he said he has absolutely no connection to any regulated utility in the state.
Which one is your favorite?  Or would you just like someone who's not part of the utility industry, a captured regulator, or a political favor?  Here's an idea:
“We urge you to appoint a new commissioner as quickly as possible so that this investigation can be resolved,” Cathy Kunkel, a member of the Advocates for a Safe Water System’s steering committee, wrote in a letter to the governor in April. “Furthermore, we hope that anyone you appoint to the Public Service Commission will have experience in utility regulation and be independent of West Virginia’s major utility interests.”
"While the utilities are experts at running their business, it doesn’t always mean that they are right,”  said Jacqueline Roberts, director of the consumer advocate division.
And they're definitely not right for West Virginia's utility consumers, because utility guys will always view any conflict from the perspective of the utility.

We've got enough utility influence from Chairman Albert already.  And we've got our political favor in Commissioner McCabe.  Now it's time to appoint one for the consumers.

Tell "GERT" to get off his dead ass and get busy.  Maybe your suggestion can be featured in a future Gazette-Mail article?
On the eve of FirstEnergy's big stage show before the Public Utilities Commission of Ohio, here's a recent look at how this company hands out ratepayer-funded party favors to its supporters

The plot:

This ESP has been controversial. The reason is because FirstEnergy, as part of its plan, has asked the PUCO to pass a fee through to its ratepayers to support its subsidiary’s struggling coal and nuclear generation. The subsidy would be supported by all of FirstEnergy’s Ohio distribution customers, regardless of whether they acquire their generation from FirstEnergy’s subsidiary. The subsidy would be assessed through a rider that is based upon a power purchase agreement (PPA), pursuant to which the ratepayers would guarantee for 15 years a price for the electricity generated, regardless of market conditions.
The strategy:
What I want to focus on now is the tactic FirstEnergy has used to assimilate support for its ESP. In my January blog, I noted that FirstEnergy had assembled what Edward “Ned” Hill, the then-dean of Cleveland State University’s Maxine Goodman Levin College of Urban Affairs, called a “redistributive coalition.”

A redistributive coalition, according to Professor Hill, exists when a small group of stakeholders band together to seek mutually favorable policy treatment at the expense of the public at large. Typically, the coalition incurs little cost in coordinating its efforts. However the public, being heterogeneous and widely dispersed, incurs great cost and difficulty in organizing a response.

FirstEnergy was able to induce companies to support its ESP by including special rates or programs for the coalition members — with the costs therefore borne by the ratepayers. In his original testimony, Hill pointed that the redistributive coalition was assembled to present to the commission (and the public) the appearance of not only broad support for the ESP, but also a broad range of benefits that would flow to varying classes of customers, including those with low income. However, Hill demonstrated that the benefits would only flow to the members of the coalition — a very small group.
The audience:  Mostly ignorant!
But what really caught my attention in Hill’s testimony was his discussion of another concept that FirstEnergy cynically exploits: “rational ignorance.” Rational ignorance is the term used to describe reasonable disengagement by a public unable to digest complex technical arguments set forth by more knowledgeable industry experts.

In this context, Hill noted that FirstEnergy looks to exploit the general public’s inability to understand the nuance of the coalition support. On its face, the coalition seems to be asking for policy that the public should support — things such as price breaks for the poor, energy efficiency programs for small businesses, and so forth.

But under close examination, it turns out that the programs are narrowly crafted to help only those in the coalition. Why, for instance, would we only support the city of Akron and no other urban areas in northern Ohio? And why only support the members of the Council of Small Enterprise and not other small businesses?
The critics:
Utilities AEP and Duke also sought PPAs. Yet neither sought to assemble redistributive coalitions for PPAs to try to fool or confuse the public. But then again, they were unsuccessful in their applications.
Break a leg, fellas (or any other parts necessary to enable quarterly dividends)!
There's nothing as certain as death, taxes and yearly FirstEnergy rate increases.  On August 14, the company filed a request to increase its WV ENEC rates by $165M.  If you're a hypothetical customer, using a hypothetical amount of electricity each month, you'll pay an extra hypothetical amount of nine bucks or so a month.  Of course, you can't pay your debt to FirstEnergy in hypothetical dollars.  This rate increase is very real, despite all the hypothetical blather.

So, what kind of kool-aid is FirstEnergy and its PSC minions serving up to help the medicine go down this time?    The PSC's windbag says:
“It’s an annual true-up, and it is to cover the cost of fuel and purchased power,” PSC spokeswoman Susan Small said. “There’s not profit for the company. It’s not going to staff salaries. It’s not operations and maintenance fees. It doesn’t go to rent and pension plans or anything like that.”
Say what?  Of course there is profit for the company built into the transmission costs being recovered, since FirstEnergy owns the transmission capacity being billed in this filing.  Transmission rates also contain staff salaries, operations & maintenance, rent and pension plans.

And about those O&M costs?  The $44.5M correction for under-recovery of the "Temporary Transaction Surcharge" ("TTS") that is being recovered in this rate increase consists of $26.1M of unexpected Operations and Maintenance expense for the Harrison Power Station.  It also includes $5.7M of profit for the company.  I guess Susan Small doesn't know what's she's talking about... again.  Maybe she should read a case filing or two before activating the ol' pie hole?

The TTS was "designed to recover the net increase in non-fuel operation and maintenance expenses, depreciation and amortization expenses and taxes other than income taxes, and a return on incremental net plant, fuel inventory and materials/supplies resulting from the completion of the transaction [sale of Harrison].  The TTS also reflected reduction in non-fuel O&M expenses associated with the deactivation of Albright, Rivesville, and Willow Island power stations on September 1, 2012," according to the testimony filed by FirstEnergy at the PSC.  Sounds like it IS operations and maintenance, Susan...

The TTS was a temporary rate increase approved by the PSC to allow the company to recover the base rate cost of the Harrison power station from ratepayers for the period October 2013 and February 2015, when the new base rates that included Harrison went into effect.  At the time, the company calculated that it would need $199.8M to cover the cost of Harrison for 17 months.
  It designed its TTS to produce $160M of this revenue.  However, the case settlement (negotiated between parties without PSC ruling) only allowed for collection of a $113M TTS.  According to the company's most recent calculations, there is a $44M shortfall, which it is requesting to recover over the next year.  The biggest part of this shortfall is $26M of "higher than anticipated expense related to maintenance outages at Harrison."  In addition, there was an additional $9M O&M expense related to employee pensions and benefits at Harrison.

Hmm... what should you expect when your electric distribution company buys an antique coal plant?  Once the ratepayers own it, the company spends generously performing all the maintenance it has put off while it was the owner responsible for the bills.

There were also some mysterious increases in the book value of Harrison, decreases in the book value of the purchased Pleasants
power station, and a $10M increase in the illegal "acquisition adjustment" FirstEnergy scored from the PSC.  The "acquisition adjustment" was the difference between what Harrison was actually worth and its book value, which produced $256M (now $266M) of pure profit "funny money" for FirstEnergy.  Federal accounting regulations do not allow the recovery of "acquisition adjustments" from ratepayers, but the WV PSC ignored that in its haste to bless the Harrison purchase transaction.  The acquisition adjustment and any adjustments related to it are pure nonsense.

Adding insult to injury, forecasted sales of power from Harrison were much higher than actual... because power market prices were low and Harrison's coal-fired power was more expensive than other resources during the period, reducing Harrison revenue that might have offset some of the costs of owning the power station.

Upon further contemplation, it looks like most of the testimony of FirstEnergy witness Kevin Wise is nonsense.  What else could explain the general advertising expenses totaling nearly $5K booked to the TTS in October 2014, January and February of 2015?  Did you ever see any advertising about Harrison on your TV or in your newspaper?  Hear any radio commercials?  Of course you didn't.  This is probably just a misallocation of general FirstEnergy corporate expenses.  *sigh*  I hope someone goes over this nonsense with a fine tooth comb.
  There's probably plenty of "mistakes" in here that don't belong but coincidentally increase the rates you pay and the profits of FirstEnergy.  Thank goodness for West Virginia's Consumer Advocate, who gets the blinding and thankless task of separating the legitimate from the nonsense in FirstEnergy's filing.

In addition to the $44.4 TTS adjustment, the company wants to recover around $96M of inaccurately estimated fuel, purchased power and transmission costs for the past 2 years, along with $23.6M of new rate increases for 2016, the amount it would be short if it keeps collecting at the current rate through June of 2016.  Total rate increase $165M. 

How did the company estimate its rate so badly that ratepayers are so far into the hole, requiring a 12.5% rate increase?  This increase is for ENEC rates, which are supposed to be filed yearly to cover variable costs incurred
by the company.  ENEC rates are based on an estimate of the yearly costs.  At the end of the year, a true-up occurs, where the company compares its actual costs to the estimate it collected, and either issues a refund, or asks to recover the shortfall.  In contrast, base rates cover the company's fixed costs and are determined through occasional base rate cases, where a fixed rate is established.  The company must operate within that rate until the next base rate case is filed.  The last rate increase was a base rate increase where the company added Harrison to its rate base.  But that wasn't the end of the Harrison costs, because as this most recent filing shows, Harrison was also racking up additional costs that the PSC said it could recover in this delayed ENEC filing.  This filing got delayed because of the Harrison purchase, so now ratepayers are on the hook for 2 years of ENEC true-up, in addition to the Harrison TTS true-up.

Hey, remember when FirstEnergy told everyone that purchasing Harrison would offset itself because Harrison would sell its excess power capacity into the PJM electric market and credit the proceeds to ratepayers?  Well, guess what?  There were no proceeds!  Prices and sales were much lower than FirstEnergy anticipated, making the ratepayers subsidize the Harrison plant, instead of profit from it.  There was no offset, just more expense.  Gee, that's exactly what all the other parties told the PSC during the Harrison proceeding.  "I told you so" x multiple rate increases.  The purchase of Harrison was nothing but a ratepayer-funded subsidy for FirstEnergy and the coal industry.  The plant wasn't economic without these subsidies and should have been closed, instead, FirstEnergy "sold" it to West Virginia ratepayers and collected a huge windfall.  We'll be paying for this mistake made by the WV PSC for a long, long, long time.

This article introduces something I haven't had to contemplate for a long time (and what a nice time that was!), the senseless babble of FirstEnergy spokespuppet Toad Meyers.  As regular readers will recall, Toad uses "Magic Math" to explain the benefit of rate increases.

FirstEnergy spokesman Todd Meyers said the $165 million increase proposed in the Aug. 14 filing is largely the result of lower-than-expected wholesale electric prices over the past year.
Meyers noted the current rates were set partly based on projections of what amount of revenue the utility would be able to pass on to customers as a result of selling the excess electricity generated at its power plants.
“When we set the rates ahead of time based on where we think power prices are going to be, and then power prices aren’t there, we’ve already built in what we project the net benefit of sales to come back to customers will be. That’s built into the rates as they stand,” Meyers said. “That’s why the lower sales then really have an effect in the next true-up.”

Meyers said the Harrison Power transaction was never meant to be evaluated on the basis of a single year, but over the entire projected life of the plant. Prices can change year to year, sometimes in unforeseen ways, he said.
“We’re never looking at things to be a benefit to customers at one particular snapshot in time. We’re looking at what the best-case scenario is over time,” Meyers said. “You just don’t know what’s going to come around the corner, and we thought that having our whole strategy dependent on market purchases, then you’re really at the mercy of the market.

While recent case filings may create the impression that FirstEnergy has continued to seek rate increases, Meyers noted that there have also been decreases, such as the 5 percent rate decrease resulting from the 2012 ENEC filing.

At that time — roughly a year before the Harrison Power transaction was approved — the companies cited lower fuel and wholesale electric costs as reasons for the decrease.
“The perception that we keep raising the rates lately — that perception may be true — but there’s also times that we lower the rates, and people forget about the downswings,” Meyers said. “I wouldn’t call it a pattern. Every year, it’s a different look based on different circumstances.”

Oh, shut up, Toad!  Cathy Kunkel told you what was going to come around the next corner when your company proposed buying Harrison in the first place.
Cathy Kunkel, a fellow with the Institute for Energy Economics and Financial Analysis who testified against the Harrison Power transaction, said the PSC’s 2013 decision has a direct correlation to the scope of the proposed ENEC increase.
Had the transaction never occurred, Mon Power and Potomac Edison would have purchased more electricity from the market than what they generated at the power plants under their control. This means ratepayers would have directly benefited from the low wholesale electric rates during the current ENEC review period, Kunkel said.
“One of the fundamental things we were saying at the time is the transaction was about risk, and it was about shifting risk from shareholders to ratepayers. And whether or not the risk actually materializes, it was still a shift of that risk,” Kunkel said. “And I think now we’re seeing the risk has materialized, and we’re seeing it in this rate increase.”
In recent years, wholesale electric rates have been driven down by low-cost natural gas, Kunkel said. But with a lack of fuel diversity in Mon Power and Potomac Edison’s generation fleet, West Virginia ratepayers haven’t seen as much benefit from this downward pressure on the wholesale electric market, she said.
The Harrison Power Station is one example of a larger strategy that FirstEnergy has adopted in recent years of moving more of its largely coal-fired generation fleet into regulated markets where the company is able to pass on more costs to ratepayers, according to Kunkel.
“I think the big picture is we’re just seeing coal less competitive in the marketplace than it used to be, and ratepayers are paying the difference, because Mon Power has invested so heavily in coal,” Kunkel said. “No one can say what the power prices are going to be, but it looks like a bad deal at least in the short run. It’s a high-risk investment for ratepayers. Let’s put it that way.”
So, what should you do about this proposed rate increase?  Simply whining to the PSC that you can't afford it does no good.  The PSC has already approved the Harrison transaction and the company has already spent this money.  The best you can do is to support the efforts of your Consumer Advocate, who will be busily chopping down the total rate increase and fishing out all the financial funny stuff.
“We are very concerned about the level of rate relief the company’s requesting,” Jackie Roberts, executive director of the PSC’s Consumer Advocate Division, said. “We are in the process of evaluating the filing to understand what drives their cost request.
“This is a very large rate increase following on the heels of other large rate increases, and we will be carefully scrutinizing this case.”
Unless, of course, you want to take on the task of auditing FirstEnergy's filings yourself to come up with a more reasonable rate.  Good luck with that!  Just a cursory review of the thousands of pages filed will make you deeply appreciate what your Consumer Advocate does with little money, and even less respect from the company and the PSC Commissioners.  Maybe you should direct your efforts toward funding and strengthening your advocate?

Because... I've saved the best part for last.  FirstEnergy has proposed doing away with these annual ENEC filings in favor of quarterly filings that raise your rates 4 times per year.  Can you imagine having to go through these thousands of documents 4 times a year, instead of just once?  Your Consumer Advocate won't be able to keep up, unless its funding is increased three-fold in order to hire more staff to do nothing but pore through FirstEnergy's quarterly ENEC filings.  And if the PSC allows FirstEnergy to switch to quarterly filings, then all the other utility kids are going to want the same treatment, until your advocate gives up in desperation.  As well, the news media would soon tire of reporting on small quarterly increases, and there would be no bad publicity for FirstEnergy or the PSC.  Get in line and eat what you're served, little ratepayer...
I have a declaration to make.  Clean Line Energy Partners doesn't represent my interests.  I'm pretty sure they don't represent the interests of any other eastern state ratepayers or the eastern states themselves, either.  It's all just a bunch of "royal we" smoke and mirrors where Clean Line attempts to speak for others who aren't present and don't necessarily agree with them.  "Me and my imaginary friends..." has no place in a court of law.

That's pretty much the basis for Clean Line Energy's application for rehearing of the Missouri Public Service Commission's denial of the company's application for a permit for its Grain Belt Express project.

The Kansas City Star continues its excellent coverage of the Grain Belt Express debacle with its story about the request for rehearing.
“The project is too important to Missouri’s energy future not to pursue,” Clean Line Energy officials said, adding that the state’s ruling also deprived the rest of country of low-cost, clean energy."
Where's the proof of that?  Who elected Clean Line to speak for "Missouri's energy future?"  Who elected Clean Line to speak for "the rest of the country?"  Nobody, that's who!

The Missouri PSC does have a role in determining "Missouri's energy future," however, and the "rest of the country" has not been actively participating in the case.

Clean Line's request for rehearing is a long-winded whine about the Commission not accepting its "evidence" at face value.  Clean Line also whines that, because it is not required to participate in regional transmission planning,  the Commission's consideration of federally-sanctioned transmission planning is somehow discriminatory.  Clean Line wants the PSC to ignore regional transmission planning when considering the "need" for a transmission project dreamed up for the sole purpose of enriching private investors.  This collateral attack on regional transmission planning organizations simply cannot be supported.

But Clean Line's main argument seems to be to hide behind the Commerce Clause to claim that Missouri's denial
interferes with the flow of interstate commerce, be it through actions that overtly discriminate against interstate commerce through differential treatment of in-state and out-of-state economic interests, or through actions that impose a burden upon interstate commerce that is excessive in relation to the putative local benefits."

Commerce Clause?  Really?  I hope Clean Line wasn't expecting anyone to actually be afraid of this, and is merely wasting time in Missouri while posturing for its lobbyists in Washington, D.C., who could claim that allowing state authority to site and permit transmission is preventing needed transmission from being built.

Clean Line is not THE ONLY way to ship electricity.  In fact, it might not even be the most efficient or economic because it has not been vetted as part of any regional planning process.  It's not like Missouri has said wind cannot be shipped across the state on existing roads, or new roads that are proven needed by regional planners.  It's that Clean Line may not build a new, private, toll road to ship electricity across the state.

Clean Line seems to believe the Commerce Clause protects any private enterprise that wants to damage a state for its own interstate commerce profits.  It's really not that simple.

So, here are a couple of things Clean Line says in its brief that demonstrate just how little Clean Line cares about the rights of people impacted by its projects:

1.  "...because the narrow local interests that the Report and Order serves do not justify the burden that it imposes upon interstate commerce."  In other words, protecting the rights of Missouri property owners and electric ratepayers are less than the "interstate commerce" goals of Clean Line.

2.  "
The Commission never considered the substantial uncontested evidence on the record of renewable energy demand and RES requirements of other states, and the substantial public benefits the Project delivers to other states. It also cited to the concerns of individual Missouri landowners -- but in the application of the Tartan factors impermissibly weighed those concerns only against the potential benefit to local interest, as opposed to the broader regional and national interest -- in concluding that the evidence shows that any actual benefits to the general public” did not justify approval."  Perhaps the Commission gave little weight to Clean Line's conclusory "evidence" of what other states and the broader regional and national interests require.  The concerns of individual Missouri landowners are real and came from the landowners themselves.  The "needs" of other states or the nation at large were not presented by any of these interests, only Clean Line pretending to speak for them as the voice of the national interest.  Clean Line, get over yourself!  When the PSC gave Clean Line the opportunity to present evidence that these national interests needed its project, the only thing Clean Line could produce was crickets.  Clean Line has no "other state" or "national interest" customers who need its "interstate commerce."

3.  "
The Commission’s finding that the Project would probably make Missouri-based wind projects less likely to be constructed is exactly the sort of economic protectionism that the dormant Commerce Clause prohibits. So too is the Commission’s criticism of the Company’s witness on economic benefits, who the Commission found did not address the displacement of jobs and energy production in Missouri due to the Project. Courts are highly alert to “the evils of ‘economic isolation’ and protectionism.... "  So, Clean Line believes that lost economic opportunities in Missouri are "evil" or should not be considered? Or that they must necessarily be less than the "national interest?"  If all local interests take a back seat to "national" ones, that's a pretty slippery slope!  I mean, we might as well just surrender ourselves to some world dominating corporation and let them do whatever they want.  Speaking of Evil, is the good Dr. in the house?

"The Commission’s denial of the Company’s CCN Application runs afoul of this element of Commerce Clause analysis because it unduly burdens the delivery of electricity generated by wind farms in Western Kansas not just to Missouri consumers, but to key markets in Illinois and Indiana. The Commerce Clause violation is as apparent in this instance as it would be if Missouri sought to restrict passage of cattle raised on Western ranches for shipment to stockyards in the East."  Again, it's not as though the MO PSC said no electricity (cattle) could pass through the state... it simply denied a permit for Clean Line to burden Missouri residents by building a new toll road to ship only certain electricity (cattle) across the state.  Cattle is perfectly free to use existing roads in Missouri to get to other states or anywhere it likes

5.  "
With the interests only of Missouri utilities and consumers in mind, the Commission made findings whose burden on interstate commerce clearly exceeds the local benefits. For example, the Commission found that Missouri had no need for the Project, and that the Project is not economically feasible, because utilities in the State could build natural gas fired plants and buy renewable energy credits.  Neither is a valid reason to deny Kansas wind producers efficient access to the market or to deny utilities and their customers the ability to benefit from the Project. And the putative local interests do not outweigh this burden."  So, the ONLY market for Kansas wind power is through Missouri?  Clean Line provides a "benefit" to utilities and customers?  Did Clean Line prove this?  I don't think so!  Clean Line doesn't have any customers!

6. "Indeed, any burden to local landowners would be small compared to the hundreds of millions of dollars of savings to Missouri and other states. The evidence shows that Grain Belt Express has agreed to compensate landowners for the fee value of their land, plus an annual payment, plus any economic damages to crops.  Even if, as a last resort, Grain Belt Express acquired an easement through a condemnation proceeding, Missouri courts would require that Grain Belt Express pay fair value."  Landowner burdens are "small"?  That sort of depends on if it's your land, doesn't it?  Who is Clean Line to determine the burden on landowners?  If the burden was ameliorated by Clean Line's compensation, why are the overwhelming majority of landowners opposing the project?  One could conclude it's because Clean Line's compensation doesn't even come close to making landowners whole. Clean Line also failed to prove the "hundreds of millions of dollars of savings to Missouri and other states."  The PSC did not find those claims credible.  How would Clean Line ever attempt to prove this claim, when it cannot set a price for electricity generated by others?  It can't even set a capacity price for its transmission line at this point!  There's simply nothing that shows evidence of "savings."

“The menace of inconsistent state regulation invites analysis under the Commerce Clause of the Constitution, because that clause represented the framers’ reaction to overreaching by the individual states that might jeopardize the growth of the nation— and in particular, the national infrastructure of communications and trade—as a whole.”  So, because all states don't have the exact same regulations governing siting and permitting of interstate transmission that somehow violates the Commerce Clause?  Or is this just a peek into the rationalizations of Clean Line's Washington DC lobbyists?  If every state was required to have identical laws, you might as well make transmission siting and permitting a federal process, right?  I don't think that's the intent of the Commerce Clause.

8.  "
The Commission’s actions here are equally likely to paralyze the development of interstate electric transmission to deliver low-cost renewable wind power from high capacity states to states lack renewable energy resources. The Commission’s stated local interests, confined to protecting Missouri utilities and consumers, do not outweigh (and in no way justify) its demonstrated effort to isolate itself from a growing national concern over the lack of such transmission infrastructure by erecting a barrier against the movement of interstate commerce. Indeed, given the shipper-pays nature of the Project and the evidence regarding the cost impacts of the Project, there can be no detriment to Missouri consumers because they will bear no costs unless a utility determines that the benefits of purchasing energy delivered by the Project outweigh those costs. Similarly, no Missouri utility is compelled to buy power delivered by the Project if it isn’t lower than the cost of other resources."  Paralyze the development of interstate electric transmission?  Hardly!  Plenty of interstate electric transmission is proposed, approved and built through the regional planning process Clean Line chose not to participate in.  Clean Line's proposals simply aren't viable, and the fault for that is entirely Clean Line's.  What states lack renewable energy resources?  I don't think there are any states that have no renewable energy resources.  It is not up to Clean Line to determine what kind of renewable energy resources states build and use.  That must violate some clause or another somewhere... And where's the "growing national concern over the lack of such transmission infrastructure?"  I don't think Clean Line has provided any evidence of that.  It's all just a bunch of vocabulary diarrhea.  Blah, blah, blah, we're speaking for everyone else here and we are what they want.  I don't think the MO PSC was fooled by that, just like the people weren't!

9. "There can be no harm to Missouri from having another option to supply power. Any perceived detriment to landowners is mitigated by the law that provides them fair and reasonable consideration. If there is a detriment to landowners, it is drastically outweighed by the hundreds of millions of dollars of benefits provided by the Project, the thousands of jobs that it creates, and the immeasurable ways in which it would advance the national interest in clean, inexpensive, renewable wind energy."  Wow, there they go again, throwing Missourians under the bus for benefit of the "national interest" that Clean Line pretends to speak for.  Who says the "national interest" outweighs the interests of Missouri landowners?  Clean Line?  Not.their.job.  Where's the proof of the thousands of jobs and the "immeasurable ways"?  Perhaps we could actually measure the ways in which Missouri would be harmed by this project?  Actually, I think that's what the PSC did here!  Nobody believes Clean Line is their altruistic economic electricity savior.  Nobody.  Save the drama for your mama (when you ask her to sign your petition supporting your project).

10. "It is clear that the Commission’s decision in this case was not even-handed, and that its exclusive and inaccurate focus on Missouri utilities, consumers, and landowners arbitrarily resulted in an application of the Tartan factors to the Company’s CCN Application that discriminates against the Project merely because of its interstate nature."  Actually, it was very even-handed.  The Commission listened to both sides of the argument and was not swayed by Clean Line's propaganda and attempts to purchase support for its project.  Nobody discriminated against Clean Line merely because of its interstate nature... it's simply a bad idea pushed by a bunch of disrespectful rich people for dubious economic reasons.

Block GBE-MO's Jennifer Gatrel hit the nail on the head when she characterized the company's request for rehearing as disrespectful:

“We continue to be disappointed by the lack of respect shown by Clean Line to landowners and citizens of Missouri,” opposition leader and farmer Jennifer Gatrel said Thursday. “They have been told no in every way possible and yet they persist in attempting to override the will of the people and the decision by our commissioners.”
The media is calling both the House and Senate energy bills "boring."  The goal seems to be to pass an energy bill that doesn't do much of anything.  For this, we pay these guys the big bucks!

Boring is much better than controversial, because honestly, these critters can get up to all kinds of hijinks when they're out of your sight in Washington, DC.  Some of the more "controversial" stuff proposed earlier didn't make it into the bills that are currently being marked up, such as the "APPROVAL Act" bills introduced by the Arkansas delegation to neuter Section 1222 of the last energy policy act.  Went nowhere.  Nothing but hot air intended to appease angry voters.  What a disappointment!

Anyhow, what IS in the bills that's of interest?  Oh, there are a few things...

The House bill contains a section establishing an
Office of Compliance Assistance and Public Participation within the Federal Energy Regulatory Commission.  This figurehead shall:
Section 319 of the Federal Power Act (16  U.S.C. 825q–1) is amended to read as follows:


‘‘(a) ESTABLISHMENT.—There is established within the Commission an Office of Compliance Assistance and Public Participation (referred to in this section as the ‘Office’). The Office shall be headed by a Director.

‘‘(1) IN GENERAL.—The Director of the Office
shall promote improved compliance with Commission rules and orders by—

‘‘(A) making recommendations to the Commission regarding—

‘‘(i) the protection of consumers;

‘‘(ii) market integrity and support for the development of responsible market behavior;

‘‘(iii) the application of Commission rules and orders in a manner that ensures that—

‘‘(I) rates and charges for, or in connection with, the transmission or sale of electric energy subject to the jurisdiction of the Commission shall be just and reasonable and not unduly discriminatory or preferential; and

‘‘(II) markets for such transmission and sale of electric energy are not impaired and consumers are not damaged; and

‘‘(iv) the impact of existing and proposed Commission rules and orders on small entities, as defined in section 601 of title 5, United States Code (commonly known as the Regulatory Flexibility Act);

‘‘(B) providing entities subject to regulation by the Commission the opportunity to obtain timely guidance for compliance with Com- mission rules and orders; and

‘‘(C) providing information to the Commission and Congress to inform policy with respect to energy issues under the jurisdiction of the Commission.

‘‘(2) REPORTS AND GUIDANCE.—The Director shall, as the Director determines appropriate, issue reports and guidance to the Commission and to entities subject to regulation by the Commission, regarding market practices, proposing improvements in Commission monitoring of market practices, and addressing potential improvements to both industry and Commission practices.

‘‘(3) OUTREACH.—The Director shall promote
improved compliance with Commission rules and orders through outreach, publications, and, where appropriate, direct communication with entities regulated by the Commission.’’.

What?  Why isn't the Commission already doing these things?  And more importantly, who does this Director report to?  Sounds like he reports to Congress as their special FERC minion.  Is this Director supposed to take the place of a consumer advocate at FERC, freeing up the resources of state consumer advocates to concentrate on consumer issues within their own states?  If so, how come this Director has no real power, other than to issue reports and recommendations?  How will this position be filled?  Appointment?  Hired by the Commissioners?  Whose interests would this Director REALLY serve?  Sounds like nothing but a feel-good figurehead sucking the taxpayer teat that produces nothing of use to consumers.

The Senate bill has a couple of items of interest, including a "Transmission Ombudsperson" who, unlike the House's FERC minion, serves only the industry, smoothing things over for companies who want to build transmission (or at least that's how the Senate thinks it will work).
    (1) ESTABLISHMENT.—To enhance and ensure the reliability of the electric grid, there is established within the Council on Environmental Quality the position of Transmission Ombudsperson (referred to in this subsection as the ‘‘Ombudsperson’’), to provide a unified point of contact for—
  1. (A) resolving interagency or intra-agency issues or delays with respect to electric transmission infrastructure permits; and
    (B) receiving and resolving complaints
    from parties with outstanding or in-process applications relating to electric transmission infrastructure.
    (2) DUTIES.—The Ombudsperson shall—
    (A) establish a process for--
    (i) facilitating the permitting process  for performance of maintenance and upgrades to electric transmission lines on Federal land and non-Federal land, with a special emphasis on facilitating access for immediate maintenance, repair, and vegetation management needs;
    (ii) resolving complaints filed with the
    Ombudsperson with respect to in-process electric transmission infrastructure permits; and
    (iii) issuing recommended resolutions
    to address the complaints filed with the
    Ombudsperson; and
    (B) hear, compile, and share any com-
    plaints filed with Ombudsperson relating to in-process electric transmission infrastructure permits.
If this Ombudsperson ever exists, put him on your speed dial and complain regularly!  Although he'll probably just sit around, take long lunches and frequent vacations because the federal government has a very narrow responsibility to issue electric transmission infrastructure permits.  It's up to you to wake him up occasionally!  Another do-nothing on the taxpayer dime.

Hey, but wait, perhaps if the section codifying Obama's "Interagency Rapid Response Transmission Team" (RRTT or "er-tit" as we dubbed it) makes it through, Ombudsperson will have more to do!  The er-tit is supposed to "
expedite and improve the permitting process for electric transmission infrastructure on Federal land and non-Federal land."  Again, very few federal transmission permits, but the er-tit is supposed to whip the federal agencies to approve the few permits they do have jurisdiction over faster, faster, faster!  The er-tit consists of representatives from a laundry list of federal agencies, but has absolutely NOBODY watching out for the interests of consumers or landowners.  Full-speed ahead for the er-tit and its industry flunkies!  I shouldn't laugh... the original incarnation of the er-tit rammed through a federal process for the Susquehanna Roseland transmission line in Pennsylvania and New Jersey that cost ratepayers $60M, plus interest over the next 40 years, to pay off the demands of former Interior Secretary Salazar.  Let's hope the new er-tit behaves better.

So, anything can happen in the Congressional energy world, as the busy little bees try to add things (bad things?  good things?) into these energy bills before the recess.  How come the consumers don't have a lobbyist working for their interests on Capitol Hill?  It's up to you to babysit these Congress critters!

The only news story to leak out of the Illinois Commerce Commission's three public hearings on Clean Line's Grain Belt Express project presents an opinion that is not factual.
"To bring Illinois forward in clean energy, we need dedicated direct current lines here in our state," said Taylorville's Patty Rykhus.
"Dedicated?"  Dedicated to what?  If Patty thinks Grain Belt Express is "dedicated" to clean energy, she's mistaken.  Electric transmission is "open access," and even though Clean Line asked the Federal Energy Regulatory Commission for permission to give preference to wind generators when assigning capacity on its project, the Commission denied their proposal.  Clean Line cannot be "dedicated" to any form of energy.

Does Patty think that HVDC lines bypassing Illinois will actually move "clean energy forward" in Illinois?  Where might she have gotten that idea?

GBE spokespuppet Mark Lawlor tries to tell the reporter "In the first five years of this line being in operation it will reduce wholesale rates by $750M."  Where's the proof of that, and why would he say such a thing?

First of all, the Missouri Public Service Commission recently examined the company's claim that the project would reduce wholesale rates in Missouri and rejected it.
The GBE production modeling studies do not support the GBE allegation that the Project would result in lower retail electric rates for consumers.
Let's hope the ICC does a similar evaluation.  Lawlor goes on that way because the promise of lower wholesale rates is the ONLY reason the ICC granted the company a CPCN for their Rock Island Clean Line project last year.  But the ICC did not find the project "needed," only that it might "...promote the development of an effectively competitive electricity market that operates efficiently...".

That still doesn't give Clean Line the eminent domain authority they seek in Illinois.  Maybe Patty should educate herself before making statements on TV that aren't factual.  And Lawlor should know better.

Dumping a whole bunch of "cheap" energy into a local market may have the initial effect of lowering prices through supply and demand, but Clean Line isn't selling electricity at wholesale.  Its entire business model is based on power purchase agreements between generators in Kansas and east coast utilities.  Lawlor leaves out quite a bit in his quest for the perfect (if not entirely factual) sound bite.

Big win for landowners in the story though.  Landowner Clint Richter clearly articulates the problem of using eminent domain for purposes of enriching investors speculating in "clean" energy markets:
Shelby County landowner Clint Richter said that, "it's not that we're not for renewable energy, but we're against a private company coming in and taking land that's ours for their own private gain and I think that's what is really happening here."

WAND-TV's Ed Cross asked, "why is that such a concern?"

"Well it's a concern because I think all of us know what it's like to work hard to save up money to buy land to something that's special and important to you and to have someone come in and basically say 'hey I want that, I'm going to take that land, and I'm going to make some money off it,' I don't think that sits well with a lot of people," added Richter.
That's what the viewers will take away from this story.  Way to go, Block-GBE Illinois!
Ask a transmission developer proposing a new transmission line and you'll get an answer in the neighborhood of 10 times the cost of an overhead line.  (Example: $1B overhead = $10B buried)

Ask an engineer for a company proposing an underground project and you get an estimate that burial would double the cost of a similar overhead line.
(Example:  $1B overhead - $2B buried)

I've been told both of these things.  So, who to believe?  Who might be exaggerating to serve their own purposes?

Apparently it only does "almost double" costs to bury HVDC transmission.
  That's what the Department of Energy concluded in its recently released draft environmental impact statement on the ill-fated Northern Pass project.

A complete burial of the Northern Pass transmission line would nearly double the project’s cost, but reduce potential negative impacts on the environment, tourism and local property values, according to a draft report released by the U.S. Department of Energy Tuesday.

While the proposed Northern Pass project — made up primarily of overhead lines strung between Pittsburg, N.H., and Deerfield, N.H. — would be the cheapest option at roughly $1.02 billion, it would also pose the greatest environmental and visual impact, the report says.

Four of the alternatives call for a complete burial of the transmission line. Another calls for partial burial beneath Interstate 93 through Franconia Notch, or along Routes 112 and 116 through the White Mountain National Forrest.

Five call for burial along existing roads and highways, options with the least environmental impact, the report says. All of the underground alternatives carry the highest costs, ranging from $1.83 billion to $2.11 billion.
But nowhere near a magnitude of 10 times the cost.  Liar, liar, pants on fire!

In addition, a buried line provides significant benefits over its aerial cousin.
The visual impact, which includes “large industrial-appearing lattice structures,” could negatively impact New Hampshire’s tourism and recreation, the report says. And the proposed overhead route likely would cause the largest drop in residential property values and have the least economic tax benefit to host communities.

Putting the line underground, as opposed to overhead, lessens the impact on tourism, recreation, historic resources and the environment, the review says.

Burying the line requires less vegetation removal and has fewer effects on wildlife, including protected species. The buried lines are less susceptible than the overhead lines to damage from extreme weather.

Construction of the overhead line would generate fewer short-term and permanent jobs than an underground alternative, the report says.
But wait...
But, the report says, blasting during construction would generate more noise than putting the lines overhead. And burial of the line would increase the potential for erosion.
Really?  That's the only drawback?  Noise from blasting?  So, how much "blasting" would Clean Line need to do to bury its proposed transmission lines across Midwest farmland?  Little to none?  What if much of the additional cost of burial was tied to blasting up the "Granite State" to create trenches?  And erosion?  I think that could probably be handled.  Once buried, out of site, out of mind, right?

C'mon, Clean Line, get with the program and re-engineer your projects as underground lines!  How much have you spent (and moreover how much will you have to spend in the future) trying to get your lines permitted?  It would have been much cheaper (in terms of both money and time) to have done the smart thing and proposed your projects as buried lines in the first damned place!

And don't give me any of that crap about how its technologically impossible to bury long lines.  The engineer who gave me the spot on double cost estimate also told me there is no mileage limit.  He's got a lot more cred than you do at this point...

How much does opposition cost?  How much does buying support cost?  How much does lobbying to change laws cost?  How much are a whole bunch of contested eminent domain cases going to cost?  How much do repeat or additional approval processes cost?

Clean Line says its currently proposed transmission line will only add something like 2.5 cents per kw hour to the 2.5 cent cost of wind energy.  So, even doubling the project costs, it's still possible to deliver at 7.5 cents/kwh, right?  Well, unless Clean Line has been lying about the delivered price of wind via its projects...

Maybe Clean Line's projects won't be "economic" enough to provide big returns to their investors without foisting some of its costs off onto bypassed landowners by taking land as cheaply as possible through condemnation and eminent domain?

We all know that the public's appetite for "green" energy only stretches so far as their wallet.  When faced with increased electric bills for "green" energy, the majority of the public will snap their wallet shut and oppose it.  So, why would this same public expect that Midwest landowners should accept economic sacrifice and burden to keep urban electric bills low?  It's only appealing when its been greenwashed and politicized, and none of that nasty infrastructure gets planted in THEIR backyard!

And... this question bubbles up... why does the DOE's draft EIS for the Northern Pass include multiple routing options that require underground lines when DOE's draft EIS for the Clean Line Plains & Eastern project proposed NO underground options?  Are the people and environment of Oklahoma and Arkansas worth less than those in New Hampshire?  Or is it just that Northern Pass has gotten bigger, politically-connected, push back and top-notch legal help?

It's about time to recognize that the public will no longer accept the burden of overhead lines.  Anywhere.  There's a better way.  "Green" energy costs more.  Deal with it.
... and this one goes to Sprouse!

We're still living in America, where money apparently can't buy everything.  And that's a cheery thought!

The Kansas City Star continues its excellent coverage of the Grain Belt Express debacle in the wake of yesterday's denial of the project by the Missouri Public Service Commission. 

The Star focuses on impacted Missouri landowner Loren Sprouse, who, along with his brothers, operates a farm in Caldwell County.  Read the article and watch the video here.
A week before the vote, Loren Sprouse — along with two brothers, he farms land in Caldwell County that’s been in the family since 1919 — said of Grain Belt: “This is a giant land grab by a huge company. They (Clean Line) are a private, for-profit company trying to masquerade as a public utility.”

After Wednesday’s vote, Sprouse said: “Now we can get back to the important business of feeding America.”
Clean Line Investor Corp. is a subsidiary of ZAM Ventures, L.P., which is one
of the principal investment vehicles for ZBI Ventures, LLC. ZAM Ventures, L.P. has a consolidated net worth of $500 million based on U.S. GAAP measurements. ZBI Ventures,
LLC is owned by Ziff Brothers, a multi-billion dollar family investment fund.
The Order stopped short of revealing how much of this particular $500M chunk their multi-billion dollar fortune the Ziffs have invested in Clean Line's struggling projects, but Clean Line's recent application to the Illinois Commerce Commission revealed it's in the neighborhood of $70M.  That's nearly 1/5 of ZAM's fortune tied up in Clean Line with no hope of recovery if the projects fail.  Maybe this will give the Ziffs some empathy for the Sprouse brothers, who stand to lose a huge chunk of their investment if the project is built.

And let's think about that for a second... how much potential profit is in these projects for the Ziffs if they're willing to invest such a huge chunk of their fortune?  Will they recoup their entire investment if only one of Clean Line's five projects gets built? 

So, who watched the Missouri PSC meeting yesterday?  It was lovely of Mike Skelly and Mark Lawlor to choose seats that put them within range of the streaming video camera.  Everyone got to watch them lose!  Here's what it looked like:
Schadenfreude?  You betcha!

Skelly originally took his classic "arms folded" defiant pose while Lawlor awkwardly stood in the doorway with a hang dog expression.  I guess someone told them that their body language was unbecoming for the occasion, because Skelly switched to the "hands tightly clasped between his knees" pose and Lawlor sat down to take notes.  Although, in this shot, it looks like Lawlor is about to bolt from his seat and run screaming from the room. 

So, what did Clean Line have to say afterwards?  It took forever for them to issue a press release (because the victory one they probably had prepared ended up in the shredder).  Clean Line says:
...there appears to be some confusion at the Missouri Public Service Commission about how the project will benefit Missourians.
Confusion?  Hardly.  The MO PSC's Order was clear as a bell.  It weighed the evidence and made a decision that actual benefits to the general public from the Project are outweighed by the burdens on affected landowners.

Who does that Clean Line?  Who calls a state regulatory board "confused" when they don't get their way?  This isn't boding well for another application down the road...

The profit-seeking needs of the Ziff Brothers were outweighed by the burden the project proposed to the Sprouse Brothers.

What a great thought as we celebrate America this weekend!

And let's end with a final photo of Mike and Mark, who finally managed to have a word with each other as the meeting was ending.  What do you suppose they said?
The Beckley Register-Herald published a spot on editorial last week regarding the captive West Virginia PSC's continual rubber stamping of utility rate increases.


The editorial lambasted the PSC for not even bothering to act like they care to listen to public commentary.

At a hearing last week in Beckley, one citizen clearly believed the PSC acts more as a rubber stamp for the utilities than an advocate for the people. His notion was not hindered by a PSC staffer who was perceived to be texting or playing with her phone throughout the meeting.
The editorial points out that at some point, the continued advancement of utility bill increases are going to meet the immovable object of consumer ability to pay.

In the past, the PSC has shown little concern about consumers, except to scam them with "consumer rate relief bonds" designed to simply hide huge rate increases with slick PR campaigns and additional financing fees.

The WV PSC must balance the interests of consumers with those of utilities.  Simply denying a rate increase needed to keep the utility solvent isn't an option.

What's a regulator to do?

Break those utility chains that bind you, Commissioners!  Instead of being lead around by the utilities like a monkey on a leash, how about leading for a change?  We're only going to get a handle on utility rate increases when regulators start acting like regulators and stop acting like utility sycophants. 

Only when regulators use their authority to lead utilities can true balance happen.  Perhaps our Governor should start appointing Commissioners with the proper skills, instead of appointing his cronies to the PSC as political favors.