After two years of Dominion refusing to do any publicity on its Mt. Storm - Doubs transmission line rebuild, rival FirstEnergy has swooped in to take all the credit for the project.

Cue the irony.
While Dominion has been doing a great job with directly affected landowners, the company has completely failed to disseminate any information about its project to the greater community.  As if folks don't notice the access roads, the helicopters, the construction traffic, the road closures, the implosive splicing...  I've gotten mighty tired of having to reassure people that this is not the PATH project, that this is a permitted activity, and that the world is not exploding.  But I do it, not for Dominion, but for the people who are the victims of Dominion's "secret" rebuild project.

Mt. Storm - Doubs (MSD) is a smarter, better solution than building the PATH project ever was.  So, let's get 'er done, fellas,  so that I can stop having this distraction sitting on the edge of a rather full plate

The MSD transmission line begins in Mt. Storm, West Virginia
and ends at the Doubs substation in Frederick County, Maryland.  The 96 miles of the line located in West Virginia and Virginia are owned by Dominion.  The last 3 miles of the line in Maryland are owned by FirstEnergy.  Each company is responsible for permitting and constructing its own segment of this project.  Dominion has been working on its portion of the project for more than 4 years.  FirstEnergy only recently got off it's corporate ass to do its part on the last three miles.

Well, yay, FirstEnergy!  You da man!  Fourteen transmission towers and 3 miles of line? 
Awesome!  Put Toad Meyers in a hardhat and push the "on" button.  That should ameliorate your billing and meter reading fiasco, right?


Back in 2010, while the PATH was still madly attempting to get it's 300 mile, 765kV transmission line sited and permitted
on new right of way, Dominion dropped a bombshell on transmission planner PJM Interconnection.  Dominion proposed several alternatives to the PATH project (which was never actually "needed").  One of the alternatives involved rebuilding MSD because of deteriorating towers.  A rebuilt and modernized MSD would increase the thermal capacity of the existing line 66% and make the addition of PATH's capacity unnecessary.  Both PJM and PATH partners FirstEnergy and AEP tried to deny the proposal and insist that PATH was still necessary.   That was the beginning of the end for PATH.  The Virginia SCC got mighty suspicious and ordered PJM to re-run some data on the necessity for PATH if MSD was rebuilt.  Low and behold, the data showed that there really wasn't a need for PATH after all and PJM suspended (and later cancelled) the PATH project.  PATH withdrew all its project applications and went into hiding, after wasting a quarter billion dollars of consumer funding on the project.

Ahhh... good times!  :-)

Now FirstEnergy says "look at me!" and give me credit for modernizing the electric grid.

Kind of makes you wish that someone would drop a load of insulators on Toad's hard hat, doesn't it?

Oh, what would I do if I didn't have this little outlet...

FirstEnergy's frequent financial fiascos aren't Tony's fault! 

Poor management pointed the finger at everyone else yesterday during some silly Chamber of Gladhanders event.

The quotes in the news article were bad enough, but check out the full text of the fairy tale here.

If Tony actually believes any of this stuff, he needs to exit stage left:

"All of us have been challenged by the economy over the last few years."

Well, except for you and your 1% pals, right?  After all, how much of a struggle is it to survive on $23M a year?  Almost as hard as it is to survive locked out of your job for months because your employer is a union buster, I'm sure.

"For example, in FirstEnergy’s six-state service area, our 2013 utility sales were below 2007 levels – and, during that period, wholesale energy prices dropped by more than 40 percent.  While this isn’t the first time we’ve faced tough economic conditions, this is the longest period of economic stagnation I’ve seen in my 40 years in the industry.  We will ultimately work through this… and as the economy grows, so will the use of electricity."

It's called energy efficiency, Tony.  It's permanent.

"But quite frankly, the challenges we now face from government interference in the electric business are far more intrusive and disruptive, and I believe far more significant to our industry’s future, and to your future.  That’s because whether it impacts our traditional regulated business or our competitive operations, government policy is now aimed at stifling the growth and use of electricity – and picking winners and losers in the competitive marketplace."

Oh, puh-leeze.  FirstEnergy was singing a different tune when the West Virginia government puppets at the PSC "interfered" in FirstEnergy's scheme to sell a dirty, old coal plant to itself and charge West Virginia ratepayers over a billion dollars for it.  Not only was having FirstEnergy's dirty trash dumped on ratepayers intrusive and disruptive to the amount we pay for electricity, it's effect is going to last well into the future.  The mistakes of FirstEnergy's competitive operations got dumped into its regulated business, and that stifles economic growth and use of electricity in West Virginia.  Worst of all, the PSC allowed FirstEnergy to pick winners and losers in the competitive marketplace.  Yeah.  FirstEnergy wins, we lose.

"Or, would you think it is fair to face competition from a supplier who can be indifferent to price… since all of its costs, including a return on investment, are guaranteed?"

What?  Every stinking penny of FirstEnergy's $121M dollar investment in its unneeded PATH project was earning a 14.3% return on investment, and recovery of its sunk costs are guaranteed in the event of abandonment.  FirstEnergy spent generously because it was indifferent to the ultimate quarter billion dollar abandoned price to ratepayers.

In addition, FirstEnergy is well on its way to plunking its "transmission spend" into a whole bunch of dubious projects, just to earn a big return on the investment.  That's not "fair."  Right.

"The industry has invested more than $840 billion… employs more than 500,000 workers… and pays billions of dollars in taxes."

But FirstEnergy earns a return on its investment, treats its workers like garbage, and doesn't pay any taxes!

"Thomas Sowell, a noted economist and commentator at Stanford, summarized a broader trend, now playing out in our nation’s energy policy, when he said, quote: “Much of the social history of the western world, over the past three decades, has been a history of replacing what worked with what sounded good.”

In the electric utility industry, energy efficiency, renewable power, distributed generation, micro grids, roof-top solar and demand reduction are examples of what “sounds good” – and while they may all play some role in meeting the energy needs of customers, they are not substitutes for what has worked to sustain a reliable, affordable and environmentally responsible electric system.  And, the mandates and subsidies needed to force their use have far-reaching consequences for our customers and our economy."

Energy efficiency, renewable power, distributed generation, micro grids, roof-top solar and demand reduction sounds like a workable, and inevitable, future to me.  Tony can either get in the backseat or get left behind.  His choice. 

Thomas Sowell quote?  Really?

"Consider the fact that you can no longer buy a 100-watt incandescent light bulb in the United States, but you can purchase a 500-horsepower vehicle."

Oh, the horrors!  Wanna bet that Tony is an incandescent bulb hoarder?  He probably sits in his underground bunker with huge stack of them, crying quietly.

"Or that electric customers are being forced to pay additional costs for subsidized, unneeded generation."

Is he talking about Harrison?

"Or that these policies and others – designed to achieve a social agenda that has little, if anything, to do with maintaining electric service – are shifting the fixed costs of the system to customers who can least afford it… and are undermining our nation’s competitive position."

"So why are we engaged in this effort to experiment with the electric system by taking away customer choice… increasing prices… and jeopardizing reliability?"

Why are you doing that to West Virginia, Tony, WHY?

"Quite frankly, I believe state and federal policymakers are manipulating the supply and demand, and distorting markets for electricity, to further advance the “war on coal.”

Well, quite frankly, I believe FirstEnergy is manipulating the supply and demand and distorting the markets for electricity, to further advance corporate profits.

"Some generating units were off-line as natural gas was used to meet higher priorities – and the entire market was affected by a substantial increase in the price of natural gas.  To put this price increase in perspective, it was the equivalent of paying about $85 per gallon of gasoline!"

And one of FirstEnergy's nuke plants was also off-line, right?  And then prices went up, and FirstEnergy charged more than 2 million customers a "polar vortex fee" that's now under investigation by more than one state regulatory commission.

"As President Ronald Reagan stated in a letter to Congress on July 17, 1981, “Our national energy plan should not be a rigid set of production and conservation goals dictated by government… When the free market is permitted to work the way it should, millions of individual choices and judgments will produce the proper balance of supply and demand our economy needs."

Because the only thing more trite than a Ronald Reagan quote is comparing your issue to the Holocaust, right?
Remember that ambiguous "energy agreement" that New England states signed back in December?  Its meaning is now beginning to take shape, not as a true energy plan, but as a ratepayer-funded transmission developer feeding frenzy.

Instead of "making investments in local renewable generation, combined heat and power, and renewable and competitively-priced heating for buildings that will support local markets and result in additional cost savings, new jobs and economic opportunities, and
environmental gains,"
it looks like some of the states are depending on this "agreement" to satisfy their energy appetites at the expense of the other states.

Here's how the states plan to implement their agreement:
In the next few months, the governors are expected to issue requests for proposals for 1,200 to 3,600 megawatts of transmission capacity that could carry wind and  hydroelectric power from the northern reaches and Canada.
Massachusetts is plowing ahead with legislation ordering utilities to solicit bids for up to 2400 MW of "clean" energy.

Instead of fostering the development of renewable energy within their own borders, or tapping the incredible resource right off their own shores, the energy hog southern New England states plan to import renewables from another country and run transmission lines through the northern New England states to deliver it.

What's in it for the northern states?  Part of the bill!
Massachusetts and Connecticut are driving the push to bring clean hydropower from Canada to help the states meet their clean-energy goals. But the other four states — Vermont, New Hampshire, Rhode Island and Maine — agreed through the New England States Committee on Electricity, made up of state utility officials from the six states. They have agreed to share the costs because they would benefit from the overall reduction in energy costs, although the details of how that would be done remain to be worked out.
Northern state landowners will also be required to sacrifice privately owned land or be subject to eminent domain condemnation and takings.  They will also have to live with these 200-foot tall extension cords zig-zagging through their communities and unspoiled vistas.

Because Massachusetts and Connecticut don't want any of that nastiness mucking up their views.

This "agreement" was never about true diversification of generation.  It's about increasing centralized generation and reliance on imported energy.  And it's about corporate schemes to make money by smoothing the way to build more long distance transmission. 

"Many of the proposals have been talked about in utility circles for some time..."

Of course they have, but the transmission developers needed cover to spring their plans on a wary public, and a way to broadly socialize the costs so that the burden on any one customer would be overlooked as minor.

The transmission developers and their pet Governors are even rewriting history, putting the egg before the chicken by pretending that the past winter's delivery issues were the impetus for the "agreement" that was signed before the problems occurred.
Adding to the charlie foxtrot are Big Green, who sanctimoniously oppose this new transmission plan, worrying that it "could crash the regional power market and kill off other needed energy-generating resources."  Funny... these are the same green hypocrites who are cheering Clean Line Energy's plan to cover the Midwest with wind turbines and HVDC transmission lines.  No worries about that crashing the regional power market and killing off other needed energy-generating resources.  Right.

So, a whole stable of eager transmission developers are chomping at the bit to have their project selected as the winner of the ratepayer-guaranteed profits.  Several proposals have been made.  In addition to stupid overhead projects like the parasitic Northern Pass, Anbaric has proposed a project that it says will be buried, both on land and offshore.
A 300-mile power cable would be buried on land in Maine and then run across the Atlantic Ocean floor to greater Boston under a proposal to tap Canada’s plentiful hydropower to meet the needs of power-hungry southern New England.
Maybe Anbaric thinks that battling the opposition that is sure to develop against an overhead project isn't worth the time, money and headaches, preferring to spend a little more to bury its project for fast approval, while the competition languishes for years on the regulatory battlefield.  Anbaric could teach some other "clean" energy developers a lesson.  But then again, Anbaric is counting on ratepayers to finance its project, including the extra cost to bury the cable. 

Other "clean" energy companies operating under a merchant model are caught in a desperate cost control game in order to keep their projects cost competitive.  Merchant transmission projects depend on energy markets for their existence.  If a merchant transmission owner can cover its own expenses to ship energy long distance and make a profit, then it is economic to build.  However, if a merchant transmission company's cost of service increases because it has to spend more to bury cable to make landowners happy, then it is no longer economic and will not be built.  Sounds fair, right?  But, what if the merchant developer wanted the power of eminent domain to take land cheaply for an overhead route, instead of having to please landowners during a fair, open market right of way negotiation process that could include the requirement to spend more money burying the line?  That would be the best of both worlds for the transmission developer -- depending on the artificial influence of eminent domain to keep its project costs in check to ensure market competitiveness.  This is perhaps the single biggest flaw in Clean Line Energy's plan.  Merchant projects should NEVER be granted a utility's eminent domain authority because they are not needed for reliability or economic purposes and depend completely on the economics of the market for existence, therefore they should also be forced to compete in unfettered real estate markets to bring their projects to reality.  If it costs too much to obtain right of way in a free market, then the project is not economic.

But, I digress.

New England has a lot of work to do to craft a real, sustainable energy plan that does not depend on inflicting social and environmental injustice on people in other states or other countries.

the states will hold public meetings to present the region's plan in preparation for bidding process. The meetings will include stakeholders, including environmental groups and developers.
It is unclear whether these "meetings" will include citizens, landowners and ratepayers, the most important "stakeholders" of all.
That's what former Secretary of Energy Steven Chu had to say about claims that distributed solar was making the grid unstable.
“That’s another bullshit argument,” said Chu, a Nobel Prize winning physicist who served as energy secretary from 2009 to April, 2013. Solar installations don’t threaten grid stability until they approach 20 percent of the customer base, Chu said.
Finally released from officialdom, Chu is no longer telling utilities what they want to hear, but what they need to hear.  Feels, good, doesn't it, Dr. Chu?

Chu has some sage advice for utilities:  To ward off the inevitable "death spiral," they need to get into the rooftop solar business.

Chu said his advice has been met by utilities one of three ways:
“Tell us what to do.”
“Deer in the headlights.”
“We’re going to fight this.”
What was your utility's response?

Isn't it refreshing that former high ranking energy officials are loosening up and telling the truth now that they can?  Former FERC Chairman Jon Wellinghoff is also under fire for giving away energy industry "secrets" about the vulnerability of our centralized electric generation and transmission system.

This isn't just some random crackpot who overdosed on the Metamucil, but two guys who had their finger on the pulse of our electric system for years.  It's rather telling that the industry and governmental officials are screaming foul when two of their own finally break rank and spill.  The regulated and the regulator are way too cozy in this country.  Denying the advice of those who know the system best, when they are finally free to give it, is a head in the sand approach to disaster. 
Customers in the deregulated states of Illinois and Ohio are up in arms about FirstEnergy's plan to stick it to them with a $5 - $15 one-time charge to pay for what it says are "unexpected costs incurred during the polar vortex."

"FirstEnergy Solutions is preparing to bill about 2 million of its 2.7 million retail customers a surcharge for expenses the company will soon have to pay for reserve power it needed when temperatures plummeted below zero."  2,000,000 x $15 = $30M

That's $30M being transferred from consumers pockets into the pockets of FirstEnergy.  A company spokeswoman opined, “We consider that pretty nominal.”

I wonder if she also considers CEO Tony Alexander's annual $23M compensation "nominal."  If the big guy took a pay cut, it would almost cover the cost of the "polar vortex," wouldn't it?

Crain's described the reason for the charge like this:

"The company confirmed that it will impose a one-time charge of between $5 and $15 on customer bills in June to recover a portion of its power-purchasing costs made through PJM Interconnection LLC's regional grid, which serves 61 million people in all or part of 13 states from northern Illinois to the Mid-Atlantic, as well as Washington. In January, PJM — which acts as a market referee for power generators — lifted caps on the price natural gas-fired power plant operators could charge as the cost of gas soared due to record demand, and electricity consumption likewise spiked.

The Plain Dealer described the reason for the charge like this:

"When the arctic blast hit the region in early January, demand for electricity spiked - and simultaneously dozens of power plants failed because of the weather, mechanical problems or because of fuel problems.

About 20 percent of the PJM region's power plant capacity went down, he said, threatening the stability of grid. And because the cold was widespread and lasted many days, PJM grid operators found that they could not import power from other areas.

Wholesale power prices then skyrocketed. PJM reduced voltages by 5 percent, asked for voluntary conservation and even briefly considered rolling brownouts to avoid a grid collapse and blackout.

But PJM also ordered more expensive power plants to begin generating, just to keep the system stable, he said

But here's another reason:

FERC compounded the problem by lifting a $1000 price cap and allowing these greedy corporate entities to further game PJM's malfunctioning markets.  FERC has allowed generators to charge whatever they want, and is in denial about any "harm" that may result: 

"FERC said PJM's proposal met the commission's criteria for approving waivers, as doing so would remedy a 'concrete problem,' would not harm third parties and would be limited in scope."

It's really not sounding very "limited in scope," is it?

In addition, FirstEnergy ended up purchasing so much expensive power because many of its generation plants were out of service.  Where does FirstEnergy's fault in that end and the consumer's responsibility for the charges begin?

Not all electric companies are passing these "polar vortex" charges on to their customers, however.  But, FirstEnergy is shuckin' and jivin' like a champ
on a "special website" the company has set up to serve you some koolaid, as well as in the media:

Francis of FirstEnergy Solutions declined to say how much her company has been billed by PJM, except to describe the amount as unprecedented. She said the company is passing on only a portion of the charge to customers."

FirstEnergy also said the company has no idea how much it will have to pay

"Ms. Francis declined to say how much in unanticipated vortex-related costs FirstEnergy Solutions must pay, saying that figure was confidential. FirstEnergy will know next month precisely how much the surcharge will be, she said."

Yes, it seems that the real cost to FirstEnergy is going
to remain a deep, dark secret, not even revealed to the company's investors.

That's because:

"We thought it was necessary to pass through these costs to customers where contracts allow,” FirstEnergy spokeswoman Diane Francis said."

Necessary?  FirstEnergy thought using the fine print in its contracts to stick it to customers in deregulated states was so very funny during its last earnings call.

Steve Fleishman - Wolfe
Yeah. Hi, good afternoon.

Tony Alexander - President & CEO
Hi, Steve.

Steve Fleishman - Wolfe
Hi, Tony. I guess this question might be for Leila. I think you mention the PJM ancillary cost that some of those get pass through the customers?

Leila Vespoli - EVP, Markets, and Chief Legal Officer

Steve Fleishman - Wolfe
Is that just in certain states or how does that work? How do we know which areas get pass through or not?

Leila Vespoli - EVP, Markets, and Chief Legal Officer
It is pursuant to contract in a specific language within the contract so it is not a state by state kind of thing, Steve.

Steve Fleishman - Wolfe
Okay. So it is certain types of your customer classes?

Leila Vespoli - EVP, Markets, and Chief Legal Officer

Steve Fleishman - Wolfe
In a retail business?

Leila Vespoli - EVP, Markets, and Chief Legal Officer
It is not even the same throughout particular classes.

Steve Fleishman - Wolfe

Leila Vespoli - EVP, Markets, and Chief Legal Officer
It is as that contract language was developed for that particular customer or grouping of customer. So there is no way I can even give it to you by segment.

Steve Fleishman - Wolfe
Okay. So some of the cause when you get this data come up will be cause that you absorb but some of those would be available to essentially pass through your contracts to the customers?

Leila Vespoli - EVP, Markets, and Chief Legal Officer

Steve Fleishman - Wolfe
And in the future, do most of your contracts have that clause, so new ones do or not older ones or vice versa?

Leila Vespoli - EVP, Markets, and Chief Legal Officer
I think it would be safe to say that we are going to be adding that language where we can in the future.

Steve Fleishman - Wolfe
Got it. Okay. Thank you. Just want to clarify that.

Leila Vespoli - EVP, Markets, and Chief Legal Officer
So, if you don't want to get stuck with these kind of charges in your deregulated electric bill again, do like the City of Rockford and look for a new supplier ASAP.
The Missouri Landowners Alliance has retained excellent counsel to defend its interests against the intrusion of Texas-based Grain Belt Express.

After a long career with a big utility, attorney Paul Agathen brings a wealth of experience to the Alliance's legal team.  Paul has gone on the offensive with a Protest of the Grain Belt Express Application for Negotiated Rate Authority at the Federal Energy Regulatory Commission and a Formal Complaint before the Missouri Public Service Commission alleging that Grain Belt Express has violated and continues to violate the Commission's rules regarding ex parte communications.

First, let's take a look at the FERC Protest.  As a merchant (self-funded) transmission project, Grain Belt Express must concoct its own rate scheme to recover its cost of building and operating its proposed transmission line from customers.  GBE's rate scheme is under the jurisdiction of the FERC and must adhere to FERC's rules, including its non-discriminatory open access transmission rules.  GBE's rate scheme proposes that the company be allowed to negotiate rates with willing transmission customers in a open and non-discriminatory bidding process.  FERC's job is to review and approve GBE's proposed negotiation process BEFORE it occurs.

And, according to the protest, that's just the problem.  Although GBE hasn't "officially" initiated its "open season" for potential customers, GBE has already started soliciting interest from its preferred customers via a "Request for Information" directed solely toward wind project developers in Kansas.  Directing its solicitation to only wind developers discriminates against other forms of electric generation, such as solar or gas, that could potentially bid for capacity on GBE's transmission line.  This discrimination violates FERC's open access transmission rules.

GBE has been doing an elaborate fan dance with FERC, promising to provide access to all forms of generation, while touting its project as a "wind only" transmission line and soliciting interest from wind developers.

The Alliance's Protest asks that the Commission determine that GBE's proposed solicitation of customers is unduly discriminatory and dismiss GBE's application for negotiated rates.

Without negotiated rate authority from FERC, GBE will have no way to collect its cost of service.  No money, no GBE.

Moving on to the Missouri PSC Complaint, the Alliance alleges that GBE has been violating the Commission's ex parte rules.  Ex parte means "one side only" and refers to communication between the decisional authority and only one of two (or more) parties in a case.  It's like one person getting to have a private conversation with the judge in order to sway his opinion against the other person.

But that's not exactly the way the Alliance alleges GBE has violated this rule.  The ex parte rules state:
It is improper for any person interested in a case before the commission to attempt to sway the judgment of the commission by undertaking, directly or indirectly, outside the hearing process to bring pressure or influence to bear upon the commission, its employees, or the presiding officer assigned to the proceedings.
The Complaint alleges that GBE violated this rule through its extensive public relations campaign intended to influence public opinion through statements on its websites, the gathering of boiler plate letters of support for its project, public statements and media interviews, and meetings with local government officials.

The Alliance is not objecting to GBE providing legitimate information to the public:
The Alliance is not objecting here to  everything on the two Grain Belt websites.
It recognizes, for example, that it is perfectly acceptable for Grain Belt to provide  nonargumentative factual descriptions of the Line and its supporting towers; to include maps of the alternative routes of the Line; to provide information for potential suppliers of
component parts for the line; and to address any other matter which is not likely to be a
contested issue at the forthcoming  Commission hearings.
The Alliance is objecting to GBE's elaborate public relations campaign:
As is apparent from all of the above, Grain Belt has engaged and continues to engage in an elaborate PR campaign designed to sway public opinion on matters which it will litigate in the forthcoming Commission proceedings. Their campaign is extensive, it is expensive, and it is professionally managed in all of its various aspects. They have even incorporated Facebook and Twitter into their PR arsenal, and added links in their website to a number of video presentations.

For example, it its Application to the FERC for approvals regarding the proposed Line, Grain Belt refers to their video "that describes the need for the Project and how Grain Belt Express will bring significant economic benefit to states through much-needed transmission expansion for new wind energy projects .... " (Exh. 23, p. 8).

This description of the Grain Belt PR efforts is not intended in the pejorative sense at all. The Grain Belt publicity campaign is undoubtedly effective, and will no doubt accomplishing two of its principal goals: to sway public opinion on the Line in Grain Belt's favor, and to thereby convince members of the public to sign on to the computer-generated letters of support which Grain Belt will file with the Commission.

The letters may have no effect at all with the Commission. However, the ultimate impact of Grain Belt's efforts should not be the deciding question here. If Grain Belt has violated the Commission's ex parte rules, their conduct should not be excused by some sort of "no harm, no foul" escape clause.

We may never know how many people in Missouri were exposed to and influenced by Grain Belt's one-sided presentation on issues which they themselves will raise later at the Commission. Nor could the Alliance ever hope to present its own position to all of the people reached by Grain Belt. Grain Belt has been waging an extensive PR campaign for about four years, and will likely win that battle.

Just how Grain Belt has gone about doing so is illustrated in materials presented at a recent conference in Houston, where participants spent two days learning various techniques for "selling" a transmission project to the public.
A copy of the initial brochure for that  conference is attached here as Exhibit 18.
As noted on the first page, the conference was held this past January, and was to be
hosted by Grain Belt's parent company- Clean Line. As noted at page 3 of that brochure, the keynote speaker at the conference was to be the Executive Vice-President of Clean Line.

According to the brochure, this is a sample of what those involved with building and siting transmission lines were to learn in Houston:

• How best to utilize social media to "engage the public", including who you can expect to reach, and how to go about doing it. (Exh. 18, p. 4) Not surprisingly, an expert in social media from Clean Line was to be one of the two speakers on this subject.
• How to deal with people disparagingly referred to as "NIMBYs" and "BANANAs". Ironically, the audience at that session was also told that a driving force behind the emergence of community-based opposition groups has been the push to build more infrastructure to support more renewable energy. (Exh. 18, p. 4).
• In "Marketing to Mayberry" the attendees would learn, among other things, how to talk down to people in small town, rural America, by communicating with them "in a conversational tone rather than corporate tone ... "  Presumably, these techniques were designed with the citizens of rural northern Missouri in mind.
• "How to frame and 'sell' infrastructure projects ... ", and how to use "effective
strategies and tactics, and share in critique of on-camera training ... "
• How to deal with the media, including:  "Getting into a reporter's head"; "How to answer questions you don't want to be asked"; and how to "position" your message to the media. (Exh. 18, p. 6)
• Finally, the Executive Vice President from Clean Line was to explain "how to ensure that our stakeholders feel they are informed and part of the process". (
emphasis added). Apparently, it is not important to Clean Line that stakeholders actually be informed, or actually be involved in the process, so long as they are somehow made to feel that they are.

The Complaint asks the Commission to find that GBE violated the ex parte rules, order it to revise its websites to conform to the rules, "that the letters of support included by Grain Belt with its Application for
Commission approval of the Line constitute the fruit of a poisonous website, and be therefore stricken from the record in that case,"
and other just and reasonable relief.

Everyone needs to read this Complaint.  The uneven playing field on which transmission owners and the public who oppose them do battle has been clearly defined as unfair.  This is the new normal of transmission opposition, so transmission developers may as well get used to it and turn over a new leaf to play fair.
There's been lots of discussion in the news over the past year about the "disruptive challenges" increased deployment of distributed generation resources, such as onsite solar, pose to traditional utility business models.  Even the Edison Electric Institute publicized a report urging utilities to devise a way to continue to collect monthly payments from you, even when you disconnect from the grid.

ITC Holdings Corp. builds, owns and operates transmission.  Unlike other utilities that also own generation or distribution (your "local" electric company), transmission is all ITC does.

More distributed generation means less transmission.  ITC must have found that pretty terrifying, because the company recently "...conducted research, including an online survey of national audits and in-depth interviews with business leaders on grid and transmission development, to measure whether businesses and the general public understand the complex and significant economic benefits that stem from a fully functioning electric transmission grid."
And wouldn't you know it, "[t]he research found that 99 percent of Americans polled think the grid is important to the United States, the national economy and their local economy. Ninety-one percent of Americans agree that investing in transmission will help local, regional, and national businesses grow and succeed. Further, 89 percent of Americans included in the ITC Holdings research believe that investing in the electric grid will benefit consumers by increasing competition and lowering electricity prices."

Oh, poppycock, ITC!  It's all in how you ask the questions, right?  A "hired gun," or advocacy survey is carefully constructed to lead the participants to the desired responses through carefully worded questions, false choices, or limiting possible answers.

Let's take a look at ITC's "survey:"
  • The survey included an upfront, conclusive statement before any questions were asked of the 800 sample "Americans":
After reading the following short description about the electricity transmission grid, nearly all Americans (99%) think that the grid is important to the United States, the national economy and their local economy.

"As you may know, an important part of our nation’s infrastructure is the electricity transmission grid. The grid is made up of transmission towers and power lines that deliver electricity from power generating sources to the distribution network and the millions of businesses and consumers across the country. It’s often useful to view the transmission grid as the “backbone” to the country’s electricity infrastructure. The pieces that make up the transmission grid are very old and outdated. More than 70% of the nation’s transmission lines are at least 25 years old."
  • Questions consisted of asking participants if they agreed or disagreed with the following statements:
Investing in the electricity transmission grid will ensure reliable access to power, especially during severe storms, for consumers and businesses.
Investing in the electricity transmission grid will help America’s economy by promoting job creation and economic growth.
Investing in the electricity transmission grid will help regional local, regional and national businesses grow and succeed.
Investing in the electricity transmission grid will increase competition by facilitating
access to more efficient forms of energy and thereby reducing costs.
Investing in the electricity transmission grid is important to national security.
Everyone benefits from investments in the electricity transmission grid.
Investing in the electricity transmission grid will accelerate access to all types of power.
  • Participants were asked "Why do you think the United States should invest in the electricity transmission grid? Select all that apply."  Why is it assumed that all participants think the U.S. should invest in the grid?  And why isn't one of those choices "To make my electric rates go up while providing corporate welfare for transmission companies?"  Instead choices were limited (and surprisingly sappy):
To lower electricity prices, helping to save consumers like me money
To reduce the number of power outages, especially during severe storms, making electricity more reliable
To make a difference for future generations, including my children and grandchildren
To give businesses more reliable power and make our economy stronger
To minimize the impact of cyber security risks
Here's what ITC concluded from the above question:
• The majority of Americans (61%) prefer investing in the electricity transmission grid rather than building power-generating facilities to increase energy efficiency.
The majority of Americans would rather give their money to ITC every month than invest it in their own power producing equipment or energy efficiency improvements that lower their bills overall?  That is a plainly ridiculous conclusion.  What was in the koolaid they handed out?
  • For some reason, a majority of ITC's "Americans" think that the government invests in the grid from some magic pool of money that doesn't cost the "Americans" anything:
Despite agreement around the benefits of investing in the grid, Americans are divided over who is primarily responsible for actually investing in it.
• More than half (56%) say either federal (Congress) or local/state government is responsible for investing in the grid, while a quarter say electric utility companies are. Small percentages think that President Obama, consumers, or private investors are responsible.
Only a small percentage of these "Americans" know the truth -- that consumers pay for grid expansion in their monthly electric bills.  Oh, if only we really did have a magic grid expansion investment fairy, then there would have been no need for this "survey!"
Now you know how ITC reached its desired conclusion that "Americans" want ITC to build even more transmission to increase corporate dependence and profits!  Then ITC turned this into a white paper for use in trying to convince the federal government to create laws mandating more transmission.  We don't need more transmission!  We need more generation near point of use and less unreliable and expensive transmission!

Since ITC's "survey" was scientifically carried out online, let's undertake our own online survey to see if we can arrive at the same results as ITC's pollster.

    Americans Online Transmission Survey

Another quarter, another FirstEnergy earnings call.

Heavy sigh.

They sounded like they were all on some sort of doggie downer while reading their scripts for the first half of the call.  It was only when the line was thrown open to questions that the party started.

Stupid business buzz word for this quarter:  "glide path."  Ex.  FirstEnergy sees its glide path to riches dotted with the corpses of its customers.

It seems that FirstEnergy is about to take one in the shorts because much of its generation was offline during the polar vortex and it had to purchase power.  Very expensive power.  FirstEnergy also expects to be hit with a bundle of PJM charges resulting from the vortex, but that's okay, the company expects to either drop them on regulated customer doorsteps, stick it to competitive customers through contracts, or simply whine to PJM and FERC about the unfairness of it all.  When asked (repeatedly) to put a ballpark number on this, Tony the Trickster avoided the question.

Heavy sigh.

FirstEnergy expects 80% of its earnings to come from its regulated business in the future.  That includes FirstEnergy's new found love of transmission upgrades.  Once again, FirstEnergy puts all its eggs in one basket.  Ooooh!  Shiny object!  Transmission spend!

Does anyone but FirstEnergy really think that milking regulated customers for transmission upgrades of questionable necessity isn't going to run into a regulatory buzz saw?  My Magic 8 Ball tells me "it is certain."  Maybe Tony needs to get a Magic 8 Ball to help him run the company?

Heavy sigh.

FirstEnergy is all ticked off about PJM's markets not working.  What they mean is that the markets are not working to make FirstEnergy a bundle of money.  But, FirstEnergy seem intent on making a regulatory nuisance of itself

Heavy sigh.

One more thing before I go....

This is a vocabulary lesson for Leila:

The word you were searching for is exacerbate

exacerbate |igˈzasərˌbāt|
verb [ with obj. ]
make (a problem, bad situation, or negative feeling) worse: the forest fire was exacerbated by the lack of rain.

Here's a link where you can hear the word pronounced.

The word is not pronounced "exasperate."  These are examples of incorrect usage:

"The situation with market power prices in January was a product of base load generation that was stretched to its limit and exasperated by gas units that were impacted by constrain gas transmission and high spot trading prices."

"The fact that JCP already has the lowest rate in the state of New Jersey, which again further exasperates the consequence of that."

Leila's misuse of exacerbate exasperates me.

Heavy sigh.

A mysterious, new group advocating for "more ways to send Iowa's wind power out of state" appeared on TV screens all across Iowa on Monday.  The mysterious group claims it includes "wind power activists, vendors and industry leaders" and that is it "neutral" about the Rock Island Clean Line.  How could a group advocating for transmission lines in Iowa not be for RICL?
The true purpose of this group was revealed later on in the interview, however:
The Rock Island Clean Line is one for-profit company proposing to ship wind power produced in western Iowa to the outskirts of Chicago. None of that power would stay in Iowa and a number of landowners along the proposed 500-mile-long transmission line route have opposed the plan. Some owners and farmers have expressed concerns about potential damage to land from transmission tower construction and the threat of eminent domain to push a route if enough willing sellers aren’t found.

 But Lang, and Mike Prior, interim director of the Iowa Wind Energy Association, hope the new organization could serve as a “go-between” to bridge some of the disagreements between land owners and the Clean Line developers.
"Neutral," my eye!

A front group is an organization that purports to represent one agenda while in reality it serves some other party or interest whose sponsorship is hidden or rarely mentioned. [or denied!] The front group is perhaps the most easily recognized use of the third party propaganda technique.
So, what are Clean Line's ties to the new Windward Iowa group?

Windward Iowa's web domain was purchased October 21, 2013 by Larson Shannahan Slifka Group, aka LS2Group.
Larson Shannahan Slifka Group (LS2group) is a bipartisan public relations, public affairs, and marketing firm that guides its practices with one goal in mind: what others may do, we strive to do better. We offer clients an unparalleled commitment to excellence and take pride in our consistent delivery of successful outcomes. Our strength lies in the diversity of our team and its determination to apply creative solutions and unique perspectives to clients' needs. We see possibilities others cannot and have a track record of helping our clients reach their goals.
Right.  I'm sure other public relations companies cannot "see" the wheels coming off the front groups they set up for their clients at roll out.  But, that's neither here nor there. 

Who are LS2Group's clients?
"LS2group has a thorough understanding of our needs and responds quickly to our requests, coupled with a vast network of strong relationships with key officials."
- Cary K., Director of Development, Rock Island Clean Line
Who are LS2Group's employees?  I saw this one minding the Clean Line information table at the first Mendota public hearing.  Others have reported seeing her at other Illinois and Iowa public events.
This same LS2Group employee is also the named company contact on a recent press release about the Rock Island Clean Line project.

The claims that Windward Iowa is not advocating for Clean Line's RICL project, and has nothing to do with the company, are beyond credible belief.

Windward Iowa incorporated as a non-profit Iowa corporation on December 12, 2013.  According to its Articles of Incorporation, its purpose is:
to promote social welfare by seeking to educate and encourage landowners to become familiar with wind energy production and transmission, and expand the wind industry in the state of Iowa to further the common good and general welfare of the people of Iowa and the Midwest.
According to its Articles:
no substantial part of the activities of the corporation shall be the carrying on of propaganda, or otherwise attempting to influence legislation, and the corporation shall not participate in, or intervene in (including the publishing or publication of statements) any political campaign on behalf of or in opposition to any candidate for public office
and must abide by the laws for a 501(c)4 corporation as determined by the Internal Revenue Service.  This also means that donations to this corporation are not tax deductible.

Donations?  Yes, that's one of the ways you can "get involved" with this group, in addition to "submitting a letter to the editor or opinion editorial; commenting online through Facebook, Twitter or LinkedIn, or on an article; commenting to the Iowa Utility Board; or contacting your legislator or local government official."  Hey, wait a tick, doesn't that last one violate the Articles' prohibition on attempts to influence legislation?  That's some pretty thin ice!

I also wonder what the legal implications are of this corporation involving itself in negotiations with property owners that eventually result in eminent domain takings?

Windward Iowa's Facebook page contains numerous links to stories about RICL.

Windward Iowa's website makes sweeping statements that it does not back up, such as:

"Experts predict the U.S. will soon be in the midst of a transmission crisis. It is important to be proactive in addressing the issue and developing new infrastructure. We cannot afford to wait another 60 years for wind energy development.
The country’s electric grid is outdated and in need of attention and upgrades. Projects that bring wind energy through new avenues are part of the solution to providing clean, dependable, and renewable power."

Who are these "experts" and where have they made these statements?  Or did the public relations firm just make it up out of whole cloth?

Compare this information to the signs of a front group here:

1.  The group does not report who they are really working for, who their members are, or the source of their funding.  The idea that three individuals spontaneously decided to start an advocacy group managed by a pricey lawyer and a public relations group defies belief.

2.  There is no physical address or list of staff on the website.

3.    The group claims neutrality on some hot button issue and appears to be making general arguments about a topic only marginally related to the issue, and yet they mainly focus on a “secondary” issue (RICL).

This is all so classic.  I've had experience uncovering and reporting on transmission company front groups in the past, and my opinion is that Windward Iowa is a front group being paid for by Clean Line Energy Partners.

Because RICL and Clean Line Energy Partners are no longer viewed as an impartial and trustworthy source of information in Iowa, the company and its public relations contractor have created a supposedly "neutral" third-party entity that will continue to advocate for its project under another name.  If you wouldn't believe a word RICL says, then don't believe anything the company tells you when it is wearing its "Windward Iowa" mask.

Windward Iowa only has the same amount of credibility as RICL, and should be treated accordingly by opposition, elected officials, and the media.  It's very disappointing that none of the reporters attending the group's "launch" yesterday had the curiosity to ask where this group is getting its funding.  That's the literal "million dollar question."
FirstEnergy finally filed a public copy of its Electric Power Research Institute (EPRI) report on its West Virginia billing problems.  The report can only be described as a grammatical HOT MESS

The general gist of the report tells FirstEnergy to stop screwing around with its estimation algorithm because it works well, except that it overestimates customer usage an average of 14%.

EPRI tells us that when the meter is read every other month, both monthly kwh values are a forecast or estimate, because the first month is estimated and the second or "actual" month is actually a result of actual use plus any true-up amount from the first estimated month.  In other words... you never get a monthly bill for the actual amount you use.  Customers whose bill is read every month have accurate bills, but not you.

The report goes wrong in the first paragraph:
The focus of this assessment is to evaluate the BE protocols’ performance where bi-monthly
meter reading is the standard.
The General Investigation was not triggered by the inaccuracy of FirstEnergy's estimation algorithm.  It was triggered by a huge outcry by customers whose electric meters had not been read as required by FirstEnergy's tariff.  FirstEnergy made it about its algorithm by focusing on that during the investigation and hearing.  By asking the wrong question, FirstEnergy shifts the focus off its willful disregard of its own tariff and the injury it caused (and continues to cause!) to its customers.
"If they can get you asking the wrong questions, they don't have to worry about the answers." - Thomas Pynchon
And, therefore, this hot mess should be tucked away in File 13 and forgotten.  It's not relevant to the investigation.

Besides, it's the hardest read I've come across in a long time.  Yes, it's hopelessly technical, but it seems that FirstEnergy also ran it through the Gibberish translator before approving its final content.  This thing is chock-a-block full of typographical errors, missing words, extraneous words, incorrect words, and incomplete sentences, to the point that the reader is constantly stopping to reach for their secret Gibberish decoder ring.  Here's just one of the hundreds of sentences that gave me pause.  What does this mean?
When the values are designated as actual, then BSE assumes that they are actual meter reads and treats when according to the
protocols employees in levelization.
Here are a few quotes from sentences that didn't need decoding:
Note:  "BE" stands for "Bill Estimation."  Just think, if EPRI had named it the "Bill Simulator" instead, we could have been treated to a report full of "BS."  Oh, wait, I think that happened anyhow...
As the number of consecutive estimates increases, the BE performance deteriorates.
...ascertain if using the Prior Period should not be considered for the Base Period if the Prior Period was estimated, and especially if there are indications that there was a large but unwarranted reconciliation.
In the case of scenario 10b (Figure 7-13), which imposed two months of 33%
underestimation followed by a large reconciliation, the performance was not quite as good. The R-value distribution became less compacted around R = 1.0, and the
percentage extreme R-value increased to 8%, four time that of scenario 1b. This might
result because underestimation of usage results in systematically poorer performance of the BE in situations where the estimated month’s usage and the reconciliation amount is large. More testing is called for to verify this result before changes are made to the BE
protocols to mitigate this apparent bias.
Missed scheduled meter reads resulted in a modest increase in the extent of
overestimation measured by the mean R-value, but more importantly more individual
customer R-values are in the extreme tails.
Blah, blah, blah, who cares?  But if you can manage to get through nearly 100 pages of this Gibberish, there's a treat at the end for you.  It's a 12 slide deck of FirstEnergy's "response" to the EPRI report.  Why did FirstEnergy need a slide deck?  Maybe it's because:
EPRl was asked to perform objective statistical testing of our estimation processes. While we (FirstEnergy) agree with EPRl that the  estimation algorithm performs well for most customers we also believe that performance can be improved.
As such we recognize the need to mitigate any unintended impact to customers in the interim and will as proposed in the settlement:
Bill message customers who received a bill varying by more than 25% from previous year following multiple estimates to remind of
payment options (February 2014);
Exception customers whose current estimate vary by more than 25% from their previous year’s bill for manual review (May 2014).
Settlement?  What settlement?  Is the Commission going to allow FirstEnergy to skip out with a slap on the wrist in a settlement?