I'm guessing these professionals don't have a particular hankering for vanilla panna cotta with GBE sauce, like the Kansas regulatory staff does. The Missouri PSC Staff thoroughly and carefully went through all the evidence Invenergy filed in the Grain Belt Express application to amend its permit and they have refused to rubber stamp it while gorging themselves on utility sweet treats.
All testimony is available here by entering Case No. EA-2023-0017. I urge you to read it yourself, I'm only providing a very high level summary. You will enjoy all the juicy details by reading it in its entirety.
The Staff provided its Report summarizing the testimony of 9 separate witnesses. They were quite thorough. And they weren't buying GBE's nonsense.
The Staff Report says that Invenergy's purported "changes" to its project are not presented in their entirety. There have been lots of changes that GBE simply skipped over without notice in their application to amend. These changes matter. For instance:
All testimony is available here by entering Case No. EA-2023-0017. I urge you to read it yourself, I'm only providing a very high level summary. You will enjoy all the juicy details by reading it in its entirety.
The Staff provided its Report summarizing the testimony of 9 separate witnesses. They were quite thorough. And they weren't buying GBE's nonsense.
The Staff Report says that Invenergy's purported "changes" to its project are not presented in their entirety. There have been lots of changes that GBE simply skipped over without notice in their application to amend. These changes matter. For instance:
- The project does not have bi-directional capabilities whereby it may reverse flow from west to east to east to west. The Commission's permit says it does.
- The project is going to take a lot more than 9 acres of agricultural land out of production. Even though the PSC touted that fact in its approval, Invenergy has since changed the monopoles to 4-legged lattice towers with a much bigger footprint.
- Invenergy has petitioned the Federal Energy Regulatory Commission for approval to charge captive customers who don't use the project for "reliability" and "resilience" services. The PSC's permit says none of GBE's costs will be recovered from Missouri customers who don't sign up to use the line. That may no longer be possible. If FERC approves the cost shifting, there is nothing the PSC can do about it, except fail to approve the project.
There's more... read it!
The Staff Report also says "...much of Invenergy’s evidence 'depend[s] on puffery, evolving understandings of the project itself, and the constant changes in supply, demand, and pricing of electricity in the market and for that potential supplier or customer.'"
The Staff Report questions the MJMEUC contract because it does not note geographic changes in interconnection location. How much does the change cost customers in new transmission charges? Is the contract still valid?
Most importantly, the Staff Report recommends against approving Invenergy's two phase project because the Commission's original approval noted that the project's economic feasibility depended upon selling service in PJM to make up for below cost contracts like MJMEUC's.
Individual witnesses had more to say.
Shawn Lange wrote about MISO's Long Range Transmission Plan Tranche 1 and how new lines in that plan provide regional solutions to future energy needs, avoid reliability projects and age and condition replacement projects, increase import capabilities to Missouri by enabling access to subregion resources, and finally, it decreases local resource adequacy needs. Lange brings up an open FERC complaint where Invenergy is arguing that MISO must include an operating GBE in its future base case upon which it begins its planning. Invenergy says that if MISO did so, then some of its LRTP lines wouldn't be necessary because GBE will take their place. Invenergy supplied an analysis to FERC that says says GBE + LRTP would cause negative effect on benefits that LRTP would otherwise bring to certain MISO zones, like Missouri. Missouri would receive less benefits from LRTP if GBE is constructed.
Claire Eubanks questions whether the 150% FMV compensation for Tiger Connections easements actually makes up for the elimination of structure payments. The Guidehouse study that GBE bought and filed as evidence can only be relied on in a general sense because specific results are skewed. The Study assumes bi-directional operation and does not account for LRTP benefits. Here's an interesting quote, "...in a general sense, the wind resources available in Kansas may have a higher capacity factor than those in the east, but the accredited capacity of wind and solar is lower than other resources. In other words, either storage or thermal resources are still needed to alleviate the capacity shortfall driving the 2022/2023 PRA results.”
Michael Stahlman says cost of the project has doubled, but GBE's one contract with MJMEUC has not changed how much it must pay. He recommends against a two phase project.
The Staff Report also says "...much of Invenergy’s evidence 'depend[s] on puffery, evolving understandings of the project itself, and the constant changes in supply, demand, and pricing of electricity in the market and for that potential supplier or customer.'"
The Staff Report questions the MJMEUC contract because it does not note geographic changes in interconnection location. How much does the change cost customers in new transmission charges? Is the contract still valid?
Most importantly, the Staff Report recommends against approving Invenergy's two phase project because the Commission's original approval noted that the project's economic feasibility depended upon selling service in PJM to make up for below cost contracts like MJMEUC's.
Individual witnesses had more to say.
Shawn Lange wrote about MISO's Long Range Transmission Plan Tranche 1 and how new lines in that plan provide regional solutions to future energy needs, avoid reliability projects and age and condition replacement projects, increase import capabilities to Missouri by enabling access to subregion resources, and finally, it decreases local resource adequacy needs. Lange brings up an open FERC complaint where Invenergy is arguing that MISO must include an operating GBE in its future base case upon which it begins its planning. Invenergy says that if MISO did so, then some of its LRTP lines wouldn't be necessary because GBE will take their place. Invenergy supplied an analysis to FERC that says says GBE + LRTP would cause negative effect on benefits that LRTP would otherwise bring to certain MISO zones, like Missouri. Missouri would receive less benefits from LRTP if GBE is constructed.
Claire Eubanks questions whether the 150% FMV compensation for Tiger Connections easements actually makes up for the elimination of structure payments. The Guidehouse study that GBE bought and filed as evidence can only be relied on in a general sense because specific results are skewed. The Study assumes bi-directional operation and does not account for LRTP benefits. Here's an interesting quote, "...in a general sense, the wind resources available in Kansas may have a higher capacity factor than those in the east, but the accredited capacity of wind and solar is lower than other resources. In other words, either storage or thermal resources are still needed to alleviate the capacity shortfall driving the 2022/2023 PRA results.”
Michael Stahlman says cost of the project has doubled, but GBE's one contract with MJMEUC has not changed how much it must pay. He recommends against a two phase project.
“The Commission previously found that the economic feasibility of the project is dependent on the project’s ability to sell to PJM as the revenues from the Missouri converter station, based on the MJMEUC contract, were insufficient to cover the project’s costs.”
He noted that GBE has applied for a DOE loan for up to 80% of the project's costs. The DOE loan would limit Invenergy's financial risk.
He attacks the Repsher study Invenergy bought and filed as evidence. He says it assumes a generation mix that does not exist and does not consider the cost of generation. It also relies on both project phases, not just one to produce benefits. It assumes a generation mix that does not exist. It does not consider the cost of generation. It relies on unreasonable renewable generation capacity factors (74%).
He attacks the Repsher study Invenergy bought and filed as evidence. He says it assumes a generation mix that does not exist and does not consider the cost of generation. It also relies on both project phases, not just one to produce benefits. It assumes a generation mix that does not exist. It does not consider the cost of generation. It relies on unreasonable renewable generation capacity factors (74%).
“...the impact of generation that fluctuates hour to hour may ultimately increase prices. The injection of wind or other intermittent energy in a given area can result in the energy markets needing more expensive generation that can handle the ramping up and down of energy supply. Such generation is often more inefficient, which can paradoxically result in higher emissions, not less. A comparable example is the fuel efficiency of a vehicle at highway speeds compared to the same vehicle in stop-and-go traffic.”
He has concern that the Commission will have no jurisdiction over phase 2 once phase 1 is constructed, as that may shift jurisdiction to FERC.
Michael Rush says GBE is not a “national security” asset any more than any other transmission project. He questions claims that GBE could support national security assets because the claim is not backed up by any contracts. He says the testimony of GBE witness Monken should not be relied upon.
Krishna L. Poudel says GBE is not included in Ameren or Evergy integrated resource plans, even though GBE claims it could help meet the these goals.
Cedric Cunigan says, “Staff recommends that the Commission order the Company to provide documentation that all relevant permits have been received prior to approval or, in lieu of that, the Commission should condition any approval on all relevant permits being approved and submitted prior to beginning construction of the Tiger Connector.”
Alan Bax says the permitted Ralls Co. AC connector line was located near the converter station. The Tiger AC connector line is 40 miles away from the converter. Tiger is a substantial change as it requires 40 miles of new right of way. And he says the new Ameren substation located at the Tiger interconnection point could be charged to captive Ameren customers.
Whew! It looks like the Missouri PSC professional staff is not feeling the love. Of course, GBE is permitted to file a rebuttal to the Staff's testimony, and then the evidentiary hearings will allow for cross examination of all the witnesses, both Staff and GBE.
Will the Commission listen to the warnings of its professional staff? Or will they wander off and make a political decision that does not protect Missourians? Only time will tell!
Michael Rush says GBE is not a “national security” asset any more than any other transmission project. He questions claims that GBE could support national security assets because the claim is not backed up by any contracts. He says the testimony of GBE witness Monken should not be relied upon.
Krishna L. Poudel says GBE is not included in Ameren or Evergy integrated resource plans, even though GBE claims it could help meet the these goals.
Cedric Cunigan says, “Staff recommends that the Commission order the Company to provide documentation that all relevant permits have been received prior to approval or, in lieu of that, the Commission should condition any approval on all relevant permits being approved and submitted prior to beginning construction of the Tiger Connector.”
Alan Bax says the permitted Ralls Co. AC connector line was located near the converter station. The Tiger AC connector line is 40 miles away from the converter. Tiger is a substantial change as it requires 40 miles of new right of way. And he says the new Ameren substation located at the Tiger interconnection point could be charged to captive Ameren customers.
Whew! It looks like the Missouri PSC professional staff is not feeling the love. Of course, GBE is permitted to file a rebuttal to the Staff's testimony, and then the evidentiary hearings will allow for cross examination of all the witnesses, both Staff and GBE.
Will the Commission listen to the warnings of its professional staff? Or will they wander off and make a political decision that does not protect Missourians? Only time will tell!
RSS Feed