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Great Moments in Wasteful Government Workshops

11/28/2018

Hey kids, what time is it?

It's U.S. Department of Energy Triennial Electric Transmission Congestion Study time!

The DOE continues to waste taxpayer funding on mandated (but sadly useless) studies of transmission congestion, and it's time for the 2019 episode! So, grab your gear and pull up a chair, it's another exciting energy party where transmission developers and renewable energy companies beg DOE to jump into their Section 1221 bulldozer and clear their path to incredible riches!

Right before Thanksgiving, DOE held a poorly noticed "workshop" to inform their study. I see the workshop was publicly noticed on DOE's website just 6 days before. It wasn't listed or linked on DOE's Congestion Study page. It's almost like you needed to be an insider to find out about it. Yay, you, DOE! I mean, it's not like DOE hasn't been spanked by the courts in the past for not allowing adequate public participation or anything. I see the new study is off to an auspicious start!

Anyone who didn't have the inside scoop is left with a list of links to workshop presentations without any explanation or context. It's almost like watching a silent movie. I love silent movies! I can make up my own dialogue to go along with the pictures. And since DOE's oh-so-generous opportunity to comment on the workshop was again only 6-days long and coincided with the Thanksgiving holidays, (and was only noticed on its website 1-day before comments were due), I'm just going to have to amuse myself here. Never fear, though, DOE promises to create a detailed meeting summary from its recording of the festivities. Oh, please, let there be a comment period for that! Of course, finding it will be the biggest hurdle. I'm still looking for the comments about the workshop DOE promised to post on its "congestion study website." The information on this "website" is thin and poorly coordinated. Heaven forbid DOE maintain an up-to-date, comprehensive, on-line record of its public participation process!

Let's first take a look at the agenda for this wondrous workshop.

Look, it's a panel on "Challenges to building transmission facilities where and when needed: Permitting/siting issues."

That's you, transmission opponents! Although, during DOE's "workshop" you were represented like this:

NIMBYs? Really? Aren't we, as a society, beyond the derogatory name calling? You'd think the government would have covered this in their sensitivity training. I'm hurt! Truly wounded to the core! But I guess this is why no transmission opponents were invited to the workshop to make presentations about the real problems with permitting and siting. If they were, the DOE and its industry and environmental group flunkies (oops, my bad, was that a bit derogatory? I'm about as sorry as Reese's.) couldn't continue to kid themselves about real solutions.

I'm only going to call out a few of these dreadful presentations, but be sure to read them all to get a large helping of information deficit, local government and special interest group schmoozing, along with ways to speed up permitting by neutralizing state authority. Same old, same old. These tactics haven't worked yet, but the industry does love them so, we might as well let them continue to bang their heads against a brick wall.

Since we've already peeked at National Grid's uninspired presentation, let's start there. Here's what National Grid thinks are siting and permitting challenges:

Increase in municipalities seeking "impact fees."
Competitive transmission projects offering more than previous regional projects.
"Pass-through" communities feeling overburdened by regional project.
Concern of added costs to municipalities from project.
Increase in community activism.
Lack of understanding of local benefit for regional project.
Trees, viewsheds.
Property values.
Increase in EMF concerns.
Business loss.
Increase in involvement by state legislators.

Yes, all of the above. It's what we do. So how are you going to "solve" it, National Grid?

Offer to fund (regulatory) employees to work on infrastructure projects.
Slide that appears to compare an overhead project to a buried project.
Dozens of meetings with public officials and creation of "agreements."
Offers to fund new, unrelated infrastructure.
Informational meetings with NIMBYs.
Fund "independent" EMF expert.

Any funding of "independent" employees to grease the project or lie to the public is an attempt to cheapen the regulatory process. It doesn't actually make transmission more acceptable. Buying off local government officials with cheap trinkets and back room deals likewise doesn't actually mitigate the project's impact on any affected landowner. Landowner still takes it in the shorts, and he will extract his revenge at the next election. By that time, National Grid will be long gone. All this adds up to a combination of information deficit and governmental schmoozing. What's information deficit? It's the presumption that opposition stems from lack of information, and that the dissemination of more information will ameliorate opposition. Oh no... it doesn't work. It hasn't worked for years! We're all tired of your one-way information fountain. It's self-interested and your information is lies and crap. Save your energy and money. Find a better solution.

But wait, that slide with the two different projects... what was that supposed to mean? We'll get to that later.

Next, let's take a look at Ecology & Environment's presentation. It compares the successful Great Northern Transmission Line process with the unsuccessful Northern Pass Transmission project. It seems to rely on information deficit. Lots of slides with little comment symbols. Whut? Yappita, yappita, yappita. I'm pretty sure this had nothing to do with GNTL's success. Next...

Richard Sedano of the Regulatory Assistance Project presented a bunch of slides from EWITS (no, I didn't actually say TWITS, but I can see the similarity). EWITS envisions a huge network of new HVDC projects stretching across the continental United States. This junk has been around for years, so there's no danger of it actually happening. Then there's a NREL study, MISO, Western Governors, and a slide from our friends at the Edison Electric Institute (utility lobbying group extraordinaire). Then there's this slide.

Ahh, I think I get it now. My silent movie dialogue goes like this... What do all these things have in common? FAILURE! And in the case of Plains & Eastern, it was a colossal failure in which DOE participated! All these slides are bad ideas for a bunch of long-distance transmission. Sedano finishes up by remarking that states are best positioned to site and permit, but sadly claims there isn't enough information "to overcome fundamental mistrust of institutions and motives." And there never will be enough.

Hold your nose and take a look at big wind cheerleader Rob Gramlich's presentation. He claims "it can be done." Unfortunately, he came after Sedano. Gramlich wants to socialize the cost of all this new transmission to serve wind as widely as possible, in ex ante fashion (based on concocted forecasts instead of actual results). He also wants to make permitting and siting a federal responsibility, and he wants DOE to help bulldoze the fly over states. Chance of this happening? Not.a.one.

Just to get that bad taste out of your mouth, finish up with a look at the presentation of Steven Naumann from ComEd. Naumann says:

Impact on Need for New Long-Distance High Voltage Transmission Reduced load growth estimates means transmission expansion needs to be focused locally based on specific load growth; need to consider off- peak energy usage (electric vehicle charging) in ratings for equipment

In areas like PJM, where a states are pursuing off-shore wind, need transmission to (1) interconnect off-shore wind; and (2) develop network to provide optionality to deliver future off-shore wind efficiently

Off-shore wind is alternative to very long distance transmission to deliver western wind, which are not part of public policy initiatives of states to which the western wind would be delivered

For example, if states in the east coast have public policies support off- shore wind, what is the need for long-distance transmission to deliver wind from the Great Plains?

Looking at the system as a whole, need to consider difficulties in transmission siting, i.e., nearby is better, takes less time, less siting issues

Exactly! But then again, ComEd isn't in the business of building inter-regional transmission lines for profit. I've read Naumann's testimony in one of the Clean Line cases and was duly impressed by his knowledge and opinion. This guy has been around for a long time and is extremely bright. He gets it.

What is there to get? Let's go back to that slide that compared two different projects. The NECEC project is an overhead transmission line. The Vermont Green Line is an underground, underwater project. The Vermont Green Line may be built. The NECEC will never be built.

Permitting and siting issues can be avoided entirely by building underground transmission on public rights of way. In other words, it's not us, it YOU! Building a better project that doesn't foment any opposition is the only guaranteed way to avoid permitting and siting issues. Any transmission opponent could have told you that.

If only you'd let us in the room...

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PJM Risks Reliability With Continued Support of Transource

11/26/2018

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Oh, PJM, don't you know that when you lie down with dogs you get up with fleas? PJM has killed its credibility with a recently issued "white paper" that purports to show the Transource Independence Energy Connection is still "needed." Guess what? Nobody believes you, PJM! In fact, it looks like the only one who paid any attention to your white paper was RTO Insider, and even they balanced their story with opposition claims that PJM's recent re-evaluation was rigged.

I'm not even sure what the purpose of that white paper was supposed to be -- was it a publicity stunt? Was it PJM's answer to expert testimony filed in Pennsylvania that showed how costly the project would be to ratepayers in that state, without any corresponding benefit? If this is PJM's feeble attempt to step outside its cartel headquarters and interact with the hoi polloi, it failed miserably.

We've been hearing for more than two months that PJM thinks the IEC is needed "for reliability," but there has been no actual data shown to back up this claim. There's still no public data, just vague assertions that "power flow results" indicate overloads on other transmission facilities that produce instability. Without the actual results, this claim is baseless. In fact, it looks like PJM is just making this stuff up as they go along. But now the potentially overloaded lines (and a transformer) have been identified. PJM claims that without the IEC, a TMI transformer, the Peach Bottom-Conastone, Hunterstown-Lincoln, Lincoln Tap-Lincoln, and Lincoln-Straban lines will overload in 2023. If these are actual, real overloads, PJM had better get cracking on solutions other than the IEC, because the IEC is not going to be approved by the states. PJM has no Plan B. If we believe PJM, then the lights are going to go out in 2023 if the IEC isn't constructed. What have you been doing with your time, PJM? Isn't it your job to keep the lights on? PJM claims, "A solution and estimated cost for a violation of this scope are typically non-trivial." Typically? Is that how PJM devises solutions to reliability issues? By making "typical" determinations? So there's absolutely no science to PJM transmission planning? It's just a bunch of guys pontificating at the snack bar about "typical" things? Doesn't PJM "typically" issue a problem statement on projected reliability violations and solicit competitive solutions? Absent that, doesn't PJM look to the incumbent owners of the problem assets to devise solutions to overloads? That's what "typically" happens. It's not "typical" to re-package a failed market efficiency project as a solution to a developing reliability issue. Perhaps other transmission owners could devise a solution to the reliability issue that is less costly and less invasive than the IEC, presuming a reliability issue actually exists. But since PJM isn't making the "power flow results" that show a reliability issue public, it is subverting competition to the detriment of consumers. Based on the evidence in this "white paper," I'm going to conclude that the purported "reliability" issue doesn't exist.

PJM is layering other transmission projects on IEC being built that may cause false reliability violations. Approving new projects that require a transmission project that is not approved by the states and will not be built is a planning failure. In addition, building IEC does nothing to update old transmission lines to increase their capacity. The old lines will still exist. Perhaps the entire AP South issue only exists because PJM refuses to update existing lines to increase their capacity. It wasn't too many years ago when the rebuilding of one of the AP South lines to increase its capacity obviated the new $2.1B PATH transmission project. PJM has learned nothing and continues to waste ratepayer cash on new projects while allowing existing lines to rot and fail. Rebuilds, PJM, rebuilds! Quit wasting our money and putting reliability at risk!

PJM also manages to confirm the testimony of Pennsylvania OCA's witness who says the "benefits" figure excludes the increases in costs to other zones. PJM says:

New production cost simulations based on these updated parameters results yielded a $600.73 million present value of net load payment benefit (for zones where payments decreased).

For zones where payments decreased -- this means that any zones where payments increased were left out of the equation. To calculate an actual benefit, PJM should have included all the zone payments, including those that increased. That's the benefit number that should be used in the benefit/cost ratio analysis. Instead, PJM used an artificially high benefit number devised only from zones that showed a decrease. This is crap, PJM! Even a third grader could see where you screwed up your math. When the decrease is balanced with the increase elsewhere, the benefit for the entire region is nominal.

And speaking of nominal, PJM says it used "Nominal Project Cost" in its evaluation. What's a "nominal" project cost? Nominal is an adjective.

(of a price or amount of money) very small; far below the real value or cost

So PJM used a project cost value far below the real cost and described it as "nominal."

We've got an artificially high "benefit" number compared to an artificially low "cost" number. This is magic math. It's not credible. PJM's benefit/cost ratio is artificially manipulated to fit guidelines. PJM's evaluation of benefit/cost has lost all credibility.

And speaking of costs, PJM says that it performed the required "independent cost evaluation" on the IEC several years ago as evidence that the current "nominal" costs are accurate. An evaluation of a prior cost estimate does not magically make all new cost estimates valid. If the costs change, then a new evaluation should be performed. From the PJM manual:

For new economic enhancements or expansions with costs in excess of $50 million, an independent review of such costs shall be performed to assure both consistency of estimating practices and that the scope of the new Economic-based Enhancements or Expansions is consistent with the new Economic-based Enhancements or Expansions as recommended in the market efficiency analysis.

Uh huh. "New" enhancements (transmission). When does a market efficiency project become "new" and when does it become "old." Wouldn't it be "new" until it's actually built? Or does PJM's manual purport that a project becomes "old" after the initial evaluation? That makes no sense when cost estimates can change, along with the method by which they are calculated. A "new" cost figure requires a new evaluation. Did any "independent" review of Transource's recently revised cost estimates occur? Because it sure looks like Transource used magic math to devise an estimate that would compare favorably with PJM's recently revised "benefit" number. Transource's cost estimate has no credibility. A new review is warranted. Without it, PJM's credibility is zero.

And one last thing... how about a nice bowl of alphabet soup? PJM says that IEC will increase CETL for the BGE LDA. But that's mere gold-plating. Increasing CETL for any LDA (zone) is not necessary (if it were, it would be a reliability issue). CETL stands for Capacity Emergency Transfer Limit. It's the maximum amount of energy that can be transferred into a zone on existing transmission lines. Sure, IEC may increase the amount of energy that can be imported to BGE (Baltimore Gas & Electric), but increased imports are not needed for reliability purposes. They are "needed" to import lower cost electricity into BGE, instead of using higher-priced electricity available in BGE. And doesn't PJM's white paper say this already? The addition of CETL does nothing to increase need for IEC from a reliability standpoint, and that's the purpose of CETL. EMERGENCY, right? BGE needs to have enough capacity to import energy in an emergency to keep the lights on. Price is not an emergency! There's plenty of power in BGE to keep the lights on in an emergency without the addition of IEC. Therefore I can only conclude that PJM's introduction and use of CETL in its white paper is nothing more than an effort to confuse people with technical mumbo-jumbo that they don't understand. Maybe that works with the average consumer, but it's not going to work on the regulators who are evaluating this project.

So, since PJM likes alphabet soup so much, here's what I found in my bowl to describe PJM's recent efforts to bolster IEC:

FUBAR
SNAFU
SUSFU
TARFU
FUBU
BOHICA

Go ahead, look it up. Here's a link.

I guess it's all in how you stir your soup!

PJM's Transource IEC white paper is a complete and utter waste of time. Reading it was like sipping a big cup of dumb.

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Clean Line Tries to Sell Grain Belt Express

11/13/2018

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Well, surprise, surprise, surprise!

Clean Line is trying to put together a deal to sell its failed Grain Belt Express project. No surprise, really, the writing has been on the wall for at least a year now. What is surprising is that some dunderheads signed an intent to buy it. Musta been cheap. I mean really cheap. Fire sale cheap.

Despite Michael Skelly's blathering about how he was going to build the project (while his company fell apart completely) and how the lack of Clean Line employees was mere "personnel changes," it looks like this deal was a last minute thing. Invenergy must have driven a hard bargain on price because without that last minute deal, Skelly was facing having to admit failure of the project in Missouri yesterday. Yesterday was the deadline for Clean Line to file supplemental testimony detailing any changes to its situation at the Missouri PSC. You can read Clean Line's and Invenergy's testimony here. (Look up Case #EA-2016-0358).

Oh, and what a change! Clean Line says it has entered into an agreement to sell the project to Invenergy. Of course, this deal isn't final and is contingent upon both Missouri and Kansas approving the sale of the project in separate, newly filed proceedings. Everything changes!

The owner of the project changes. All the deals and contracts Clean Line has entered into on behalf of GBE will end and Invenergy will sign new contracts. Might as well file a whole new application in both states, Invenergy, because this change changes everything. Why in the world would both states approve GBE (or a permit extension) with a new owner based on the promises of people who don't even work for Clean Line anymore, much less Invenergy? The whole premise is absurd!

So, welcome to the fray, Invenergy. It's really not true that communities love you. In fact, it seems some of them hate you. Really hate you. At least owning GBE and being hated by landowners in 3 states won't be anything new, will it? But why? Why would Invenergy want to purchase a failed merchant transmission project? It's not like they can repurpose it as their own personal 700-mile generation tie line. Perhaps Invenergy is just trying to keep up with its competitor, NextEra, who bought a different failed "clean" line in an attempt to bugger Invenergy's Wind Catcher deal with AEP. Is this nothing more than some slapping and hair pulling between competitors?

NextEra: Hah! We own Plains & Eastern Clean Line!

Invenergy: Oh ya? Well, hold my beer! We now own Grain Belt Express!

Honestly, what a waste of time and money. Neither one of these projects are ever going to happen. The reasons are myriad, such as...

Oh wait... why would I help you chuckleheads out? There's a regulatory process in the works. Surprise! Surprise! Surprise!

See ya in the funny pages, Invenergy!

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"Some" Landowners Interfering With Investors' "Overhead Cash Registers"

11/10/2018

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The arrogant renewable energy folks had a "forum" this week. On the day of the "forum" a renewable energy news outlet ran a series of three obnoxious articles telling people that the electric transmission grid is outdated and overly congested. The solution? Lots more new transmission "for renewables." (read wind).

This is never going to happen. The reasons why are clear, if slightly beyond the thought capacity of an industry that continues to lie to itself. Merchant transmission has been a gigantic failure. The articles gush on about troubled projects that have racked up one failure after another, while also noting the complete failure ("the wheels came off") of many others. News flash: They're all going to fail eventually! Not one "renewable" merchant transmission project has been built. They can't be built.

Reasons why include:

1. No customers to pay for them! Even when Clean Line thought it had the green light for its Plains & Eastern project, it failed to attract any customers to pay for it, and Clean Line bailed at the first opportunity to unload this cash cow onto a utility wannabe who thought it could use part of the project as leverage to profit off a real utility's plan to construct a wind farm and the world's longest generation tie line.

2. RTO's are not designed to facilitate exports. RTO's are purposed to serve their region and therefore costs of serving the region are visited upon the consumers in that region. Exporting electricity to other regions does not serve anyone in the region. Asking different regions to build new transmission to patch regions together to serve the renewable energy industry doesn't benefit anyone in any of the regions either. One article even claims that new "renewable" transmission lines "represent potential overhead cash registers for their owners." So, this is all about an industry cashing in for their own benefit? But yet...

3. "Some" landowners oppose transmission. Why the modifier "some?" What is that supposed to represent anyhow? That only a handful of landowners object to superrich investors and foreign corporations erecting an "overhead cash register" on their land using the power of eminent domain to take private property? Sorry, but you're wrong about "some," if that's supposed to mean a small number. Eminent domain for private gain is widely opposed by both affected and unaffected landowners. Only "some" landowners are in favor of it, those who don't live on the land and are looking for a quick payday, or perhaps those who obliviously believe they're going to be richly compensated for the use of their land (or quid pro quo payments for being a public advocate for the transmission project).

Or perhaps "some" is an attempt at denying the power of landowners to derail transmission proposals? Even though landowners were the biggest impediment to Clean Line's projects, Clean Line still wants to claim its projects failed due to the efforts of "a major utility, and prominent state politicians" and "some landowners." As if the landowners were not the impetus for the political opposition, and as if a major utility opposed more than one of Clean Line's projects? It was the landowners, Sherlock! They are powerful, and they are the primary reason transmission projects are cancelled. Wasn't it Sun Tzu who said "know your enemy"? Denying the power of your most stalwart enemy is a fool's paradise.

Here's the basic truth: Eminent domain for the purpose of erecting an "overhead cash register" on private property is frowned upon. Sure, there was that awful Supreme Court decision that eminent domain could be used for "economic development" purposes, but that came with overwhelming backlash. Eminent domain's historical use by utilities to serve all customers cannot be extended to erect "overhead cash registers" on private property. New "renewable" transmission isn't necessary to provide electricity. The grid we have is managing to keep the light on (for the most part). One person's desire to obtain a different kind of electricity does not override another person's right to own and enjoy property. If a company desires to erect an "overhead cash register" on private property, it's going to need landowner buy in.

How to get there? It's not any of the ways renewable energy companies and environmentalists have proposed. Landowner aggregation schemes, increased easement payments, even royalties, are not adequate for "some" landowners. "Some" landowners simply do not want to sell an easement for any reason. The "eking out and incremental solutions" (in the words of Jayshree Desai, former CLEPT-O, now spending some other investors money as ConnectGen) doesn't reside in erecting "overhead cash registers" on private property. It resides in new ideas for buried transmission on existing rights of way, along railroads or highways. That's the solution. That's the way to "...figure out longer-haul, bulk transmission to really change the fundamental supply-demand balance of renewables in this country," Ms. Jayshree. Jayshree and her band of Don Quixotes wasted more than $200M of investor cash trying to build "overhead cash registers" on private property. And still one of the Dons persists because he can't pull his head out of the clouds (or another place closer to the ground).

Overhead merchant transmission is dead! The renewable energy industry and its environmental sycophants should should stop wasting their money and efforts on "overhead cash registers" and invest it in underground solutions. The cost of these solution must be borne by the beneficiaries, in this case it's the renewable energy industry, or its customers. The rest of us aren't going to pay for it. You want to make money? You gotta spend money! The answer is at hand. Don't make me grab you by the scruff of your neck and rub your nose in it.

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Market Monitor Says PJM needs to reevaluate its rules governing cost benefit analysis and cost allocation for economic projects

11/9/2018

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Ut-oh, PJM! Trouble in paradise! The independent monitor (MMU) of your activities thinks your "market efficiency" process isn't so efficient. And it's probably costing electric consumers in the PJM region money in their electric bills.

In its recently released Quarterly State of the Market Report, the MMU recommended:

The MMU recommends that PJM reevaluate the rules governing cost benefit analysis and cost allocation for economic projects. (Priority: Medium. New recommendation. Status: Not adopted.)

This is a new recommendation of medium priority. Time to get hopping, PJM, as if you ever take constructive criticism well.

Let's combine this with one of MMU's long standing recommendations:

The MMU recommends the creation of a mechanism to permit a direct comparison, or competition, between transmission and generation alternatives, including which alternative is less costly and who bears the risks associated with each alternative. (Priority: Low. First reported 2013. Status: Not adopted.)

This all adds up to fail. PJM is failing to properly plan market efficiency transmission projects. In PJM's world, the road to new market efficiency transmission projects is long. However, the congestion to be alleviated by new transmission is fleeting and short-lived. PJM knee-jerked when implementing FERC's competitive transmission Order 1000 to open a project window to alleviate congestion on its AP South Interface in 2014. That's four years ago and counting. By the time PJM got around to selecting and ordering a project to alleviate the congestion, the congestion had alleviated itself. But PJM kept on with the project, believing that it is captive to its own bloated processes. The project PJM ordered is the Transource Independence Energy Connection, and it's no longer needed.

But because Transource was granted an "incentive" to build its project by the Federal Energy Regulatory Commission that allows the company to recover all its sunk costs on the project (plus 10.4% return on its equity), no harm will come to Transource or PJM if they continue this unneeded project. All the cost and risk is borne by electric consumers.

How unneeded is this project? A look at the MMU's Congestion and Marginal Losses report section informs that congestion is now elsewhere. The AP South Interface is a minor issue.

Differences in CLMP among eastern, southern and western control zones in PJM were primarily a result of congestion on the AEP - DOM Interface, the Cloverdale Transformer, the Tanners Creek - Miami Fort Flowgate, the Graceton - Safe Harbor Line, and the 5004/5005 Interface.
The AEP - DOM Interface was the largest contributor to congestion costs in the first nine months of 2018. With $120.4 million in total congestion costs, it accounted for 10.8 percent of the total PJM congestion costs in the first nine months of 2018.

Get that, PJM? Congestion has shifted. AP South no longer has a serious congestion issue. In fact, it's minor. In fact, it only contributes 1.8% of total congestion in PJM.

PJM could spend our money better chasing the 9 constraints that cause more congestion than AP South. Of course, if they do, by the time they select and order transmission projects to alleviate this congestion, the congestion will have moved on elsewhere. PJM is chasing its own tail planning market efficiency projects. And this is why it needs to reform its rules on market efficiency transmission planning.

Once a project is approved and ordered, PJM will never admit failure. Instead, PJM will continue to prop up unneeded market efficiency projects and throw good money (OUR money) after bad through questionable cost benefit analyses that keep the project (barely) alive.

There's no amount of magic math that will make the Transource IEC economically beneficial. It's time to let this project go. PJM has had plenty of opportunity to fall gracefully on its sword and stop the ratepayer bleeding. Its recent re-evaluation of IEC was rigged, and even then IEC barely jumped the threshold. Another opportunity arose when Transource recently adjusted its in-service date ahead 5 months. PJM's Designated Entity Agreement with Transource required the project to be in-service by June 2020. PJM could have cancelled the project instead of allowing the in-service shift. The failure to meet milestone dates in the DEA is a breach of contract, and in that event PJM (the Transmission Operator) can default on the DEA. Over and done.

Instead, PJM keeps wasting our money on its bad idea. PJM is failing consumers. Not only that, now it's been called out on its failure by its Market Monitor. It's time to cancel the Independence Energy Connection.

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What's Transource IEC Going To Look Like?

11/5/2018

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I would have used the headline "Fun With Photoshop," except I used that one years ago. Transource, bless it's blackened money-grubbing heart, is still trying to convince the communities that its transmission project will be an asset. It's not working. There's pretty much nothing Transource can say or do at this point to ameliorate the wide-spread, entrenched opposition to the project. Telling further lies that contradict past lies isn't a magic wand.

For some reason, Transource sent out a "Project Update" on Friday that was akin to kicking itself in the ass. Way to go, Transource! Among the lies and half-truths were some images depicting what the project would look like if built. Even though the pictures were incredibly tiny and presented an extremely long range view, they still managed to convey the awfulness of the Transource project. I've often wondered why transmission companies do this to themselves... why do they send out photoshopped images of what their project would look like? Do they try to make these images as horrid and frightening as possible? It wouldn't be logical to create photoshopped images that look worse than reality. Instead, we can probably discern that these images use all sorts of eye-tricking perspective and shading tricks to make the new lines as unobtrusive as possible. Reality will probably be worse. Much worse. And still, Transource's photo simulations of its proposed project are a trainwreck.

How about this beautiful view?

I'm told that a group of artists was on location painting this stunning vista last week. I'm sure they won't mind altering their paintings to look like the "after" photo. Why, you can hardly notice the new power line stretching across the horizon! (Except you can actually see the shadow of the lines from the "after" photo on the "before" photo.)

Even trying to make the line as light and blurred as possible, it's still beyond awful. And where are the birds who will roost there and poop all over the crops grown below? The photoshopper seems to have left some things out. Also notice how the "after" picture is from farther away and includes a wider view? These are not "before" and "after" of the same photo.

Here's another.

Lovely barn with a distribution line crossing the view. I wonder how many photos and angles they had to sort through to find one that looked like that. Now here's what happens "after."

Look, a whole bunch of new wires that aren't connected to anything! No towers at all! Or maybe they're connected to some of those special rusty towers that blend in so well they can't be seen? They're pretty saggy, too. I'm betting they're going to be much higher in reality. And why is the sky in the vicinity of the new lines so much grayer than the rest of the sky? It's all about that contrast!

And these are the photo simulations Transource wanted you to see! Reality will be much different, but not in a good way.

Visual simulations are based on the level of design available at this time. Moderate changes in structure height and location may occur following subsequent engineering and design refinements and minor modification of the alignment.

In other words, they're going to be taller and towers will be visible. You're not doing yourselves any favors here, Transource.

I've heard that Transource has lots more of these photo-fibbed simulations for its entire route. Maybe you should ask your friendly neighborhood land agent to show them to you? Just so he knows why you object and perhaps will quit stopping by...

Barron Shaw from Citizens to Stop Transource took on a whole bunch of the other lies contained in Transource's email update. You can read the facts here.

I'm only going to touch on a couple more things here, the first of which is Transource's insinuation that its failure to update its project costs before PJM recalculated benefits is the fault of landowners.

Why didn’t Transource have updated costs at the time of PJM’s annual cost / benefit analysis?
Transource is following a planning and engineering process that requires a variety of data. For example, land surveys provide Transource valuable data needed for construction bids. Since winter 2017, the company has been working with landowners to access properties to be able to complete that work. The survey information is one example of information that was part of the bid package provided to potential suppliers.

In other words, Transource says it would have had its costs updated last year if landowners had fully cooperated with surveying, cutting and drilling on their properties for a proposed project that has not been approved. Working with landowners? Whaddya mean, Transource? You were working with lawyers, judges and the courts to force entry onto private property. You live a rich fantasy life! The real reason Transource waited until after PJM recalculated the benefits is so that it could estimate its costs at a made-up number that scaled the necessary benefit/cost ratio of 1.25. Magic math! Reality is that there is no cost cap for Transource's project. It can and will spend whatever it wants and when its actual costs don't meet the benefit/cost ratio it will be too late. Ratepayers will be locked in to paying for it. The best we can do right now is rely on the expert testimony that has been filed which correctly pegs the Transource project at returning 3 cents for every dollar poured into the project. Ratepayers lose 97 cents of every dollar they spend on this project. What an outrage!

Here's another I take issue with:

Landowners are encouraged to work with right-of-way agents now, during the design phase of the project, to best incorporate property owner desires into the final placement of the facilities.

Final placement of the facilities? You mean in the trash? Because that's where the idea for this project is going to end up after state regulators fail to approve it. I'm sure landowners may have other desired locations for the "placement of facilities." Check your back, Transource! Doesn't that statement seem a little, well, coercive to you? Transource tries to make believe that this project will be approved and it's only a matter of where to put it. No, the issue is whether to build it at all and that's far from being decided. The way things stand now, it's not looking good for Transource, therefore landowners should continue to resist. And hey now, didn't Transource say their cost update was delayed by not being able to design the project because of resistant landowners? And now they have an updated cost, so we'll assume they're done "designing" it. If there was a magic "design" window, it's already closed.

And then, there's this:

Transource has not filed condemnation on anyone

Except in its last "project update" in September, Transource said this:

The PUC process requires utilities to submit a condemnation filing during the application process. This filing includes property owners with whom the company has not yet secured a signed option to grant an easement agreement. Transource provided written notice and information explaining the process to landowners before filing the report in May.

Transource made a "condemnation filing." Except they have not filed condemnation on anyone. Which is it? Is Transource lying now, or where they lying then? Or are they simply lying all the time?

Like this:

Regions where IEC is proposed to be built — Franklin County, Pennsylvania, and Washington and Harford counties, Maryland — are located in benefiting power zones, as identified by PJM.

Where's York County? Isn't something like 12 miles of this proposed project in York County? That's right... York County will receive no benefit. That's zero benefit. Did Transource think nobody would notice their "clever" omission?

And finally, Transource thinks it knows better than Pennsylvania Administrative Law Judges:

Does Pennsylvania Act 45 of 2018 apply to IEC?
Transource PA has been granted utility status by the PA PUC. Act 45 excludes “public utility facilities” from the required approval and has no effect on this project's proceedings.

The judges reviewing this project have already made the determination that Act 45 does apply. They did it months ago! And in this scenario, their opinion is the only one that matters.

And speaking of the PUC judges' opinion, take a few steps back when you read the latest "project update." Why, it reads like a rebuttal to the expert testimony recently filed by the PA Consumer Advocate, doesn't it? Is this what Transource's rebuttal testimony is going to consist of? Photoshopped awfulness and carefully worded half-truths? Good luck with that, Transource. You've got nothing.

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Market Monitor Says PJM needs to reevaluate its rules governing cost benefit analysis and cost allocation for economic projects

What's Transource IEC Going To Look Like?

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About
StopPATH Blog

Need help opposing unneeded transmission?
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Archives

Categories

Great Moments in Wasteful Government Workshops

PJM Risks Reliability With Continued Support of Transource

Clean Line Tries to Sell Grain Belt Express

"Some" Landowners Interfering With Investors' "Overhead Cash Registers"

Market Monitor Says PJM needs to reevaluate its rules governing cost benefit analysis and cost allocation for economic projects

What's Transource IEC Going To Look Like?

About the Author

AboutStopPATH Blog

Need help opposing unneeded transmission?Email me

Archives

Categories

About
StopPATH Blog

Need help opposing unneeded transmission?
Email me