StopPATH WV Blog

Prepare for Transmission Permitting Chaos!

9/6/2025

The Third Circuit Court of Appeals issued a Precedential Opinion yesterday in a case that has drawn an enormous amount of attention in the electric regulatory world, but little notice from everyone else.

Transource Pennsylvania LLC v. Steven DeFrank concerns the Public Utility Commission of Pennsylvania's denial of a Certificate to construct the Transource project in the state. After losing, Transource claimed that the PUC was prohibited from making a finding that the project wasn't needed because it must simply accept the finding of need issued by PJM Interconnection.

I wrote about this at the end of last year, after listening to the Oral Argument where the state could hardly get a word in edgewise because the Court simply didn't want to hear it. The Opinion was about what I expected.

The Court confused FERC's jurisdiction to set interstate transmission RATES with PJM's transmission planning finding that the Transource project would lower rates for consumers in Washington, DC and Baltimore. PJM does not set rates, therefore their project planning does not set rates. Only FERC can do that.

What FERC cannot do is site and permit a transmission project that is not within a National Interest Electric Transmission Corridor. Transource is not within such a corridor. PJM is under the regulatory authority of FERC, therefore, the Court reasoned, PJM's planning is an extension of FERC's jurisdiction to set rates. Faulty logic.

Transmission siting and permitting is state jurisdictional. That means that the states have the final say on whether or not a project planned by PJM is approved, sited, and issued a permit to construct.

The Court has effectively neutered state jurisdiction and taken away their ability to make a determination whether the project is needed. The only thing left for the state to do is decide where the project goes. This gives undue authority to PJM over transmission permitting, and obliterates due process for landowners impacted by the new transmission project.

The Court says that states (and presumably others impacted) can challenge PJM's planning process and determination of need at FERC, therefore their due process rights are not impacted.

However, this is not the bargain states have struck with the federal government about transmission permitting. States have historically followed state law when it comes to need determinations, and state law usually requires the utility commission to make a finding of need when permitting a project. Pennsylvania's law is explicit that the PUC must decide whether the project is needed. Other states get there in different ways. West Virginia's law says:

...the commission may approve the application if it finds that the proposed transmission line:
(1) Will economically, adequately and reliably contribute to meeting the present and anticipated requirements for electric power of the customers served by the applicant or is necessary and desirable for present and anticipated reliability of service for electric power for its service area or region;
(2) Will be in the best interest of West Virginia customers and its citizens; and
(3) Will result in an acceptable balance between reasonable power needs and reasonable environmental factors.

There it is under (1)... is necessary...

But now West Virginia is prohibited from making a finding that the transmission line is not necessary. West Virginia must simply accept PJM's determination that it is.

Maybe this would work out great if PJM was actually a place where competing opinions were accepted and where an impartial adjudicator listened to both sides before making a decision whether or not a project is needed. But PJM is not that place. Anyone who has attended a PJM planning meeting knows that it's a one-way ride on the authoritarian train where you can't pull a cord to stop the train. PJM makes decisions in a closed environment and rejects any dissent. Therefore, the only avenue open for states or other parties who do not agree with PJM's findings is to make a complaint at FERC. FERC does not examine each project that PJM approves to assure it's needed. PJM has a big book of rules that are approved by FERC. As long as PJM follows its rules, then FERC just goes along for the ride. However now FERC is going to be examining all PJM's need data on a case-by-case basis for each transmission project PJM approves. FERC doesn't have time for that and the delays for new transmission are going to be astronomical while FERC spins its wheels examining each need determination in detail to make sure it agrees with PJM's rules. No more rubber stamping!

In addition, the tension between PJM and states is thick right now. PJM doesn't need this additional irritation. It could be the burr under the saddle that finally prompts PJM states to exit PJM for good. PJM isn't planning anything in your state if its not a member of PJM.

In addition, states are going to plow new ground creating a meaning for the word "permit". States have authority to site and permit. What does that mean? It means not only does the state decide where the project goes, it also decides whether the project goes. Don't underestimate what the states can do to find ways to deny transmission applications on any other basis but need. What then? Will a court keep whittling away on state authority to permit transmission?

This Opinion is Pandora's Box. Nothing good is going to come out of it except a whole lotta litigation and state refusal to approve new transmission applications. Nobody likes to be told they must accept someone else's opinion without examining it. Trust but verify. That's what states have been doing for decades.

It remains to be seen whether the PA PUC will ask for hearing en banc, where the entire court (all the judges) takes another look at the decision, or whether the PA PUC will take their chances at the Supreme Court.

This story is not over.

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Double Jeopardy... Now With Pictures!

9/5/2025

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Last month, I told you about a proposal that was submitted to PJM Interconnection that would turn MARL into a double-circuit 500kV transmission line between the Fort Martin power station in Morgantown, WV and the new Woodside substation in Frederick County, VA.

Well, PJM has finally posted its new maps and there's one that shows what this NextEra proposal would look like, if you had trouble following along with the narrative I gave you last time.

Here it is:

This map shows a second 500kV circuit beginning at the Fort Martin power station. A double circuit is just what it sounds like... two 500kV circuits on a common structure. It is unlikely that the two circuits will be stacked vertically on the structure. More likely that they will be separated horizontally, with one 500kV circuit on a horizontal arm on each side of the structure. This is going to change the look of the towers, perhaps their height, and perhaps their width. It also doubles the amount of power MARL can carry.

The double circuit structures will end at Gore, VA, where NextEra's segment of the project ends. Because FirstEnergy owns the eastern segment of MARL that continues on from there, NextEra will have to put its second 500kV circuit on new structures on a new 200 ft. wide right of way. This is an enlargement of the Frederick County section.

You would still get Gore-Doubs-Goose Creek 500kV on new poles on one side of the existing easement, plus you would get MARL 500kV #2 on a new 200 ft. right of way on the north side of the existing easement. And don't forget Valley Link, which will add another 200 ft. to all that for its own line of 765kV towers. Impacted landowners would have not only 1,765kV of electricity added to their properties, but an additional 400 feet of right of way as well.

Meanwhile, at the other end of MARL #2, NextEra proposes to add a new 500kV substation at the point where existing lines feeding from Ft. Martin intersect with MARL #1. That part of PJM's map doesn't look exactly accurate, so here's my attempt at mapping where the new Sandy Creek substation may be located north of Bruceton Mills.

Of course, this is going to delay MARL significantly because they're going to have to go back to the drawing board designing the structures. They're going to have to have new Open House meetings to show you their updated project, too. And this project is likely to include parts that are ultimately assigned to FirstEnergy, such as expanding the Fort Martin substation. If FirstEnergy is assigned components of MARL #2, then FirstEnergy would have to start from square one on its part of the project. The new 500kV NextEra line in Frederick County would also have to start from scratch and hold Open House meetings before filing an application.

So, what happens next? PJM will be evaluating this proposal (and 133 others around the region) and discussing them at upcoming meetings with the goal of choosing projects by the end of the year. It's unlikely NextEra will move forward with its application until it knows whether it will be approved to add that second 500kV circuit.

When your friendly, neighborhood land shark... err agent, land agent, shows up to pressure you about signing an easement agreement, perhaps you should be asking him about NextEra's MARL double circuit proposal? There's more you're not being told...

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How to Respond to the Transmission Company's Notice of Intent

8/28/2025

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This week, both NextEra and Potomac Edison made filings at the West Virginia Public Service Commission indicating that they intend to file applications for their respective segments of a new 150-mile 500kV electric transmission line. The line moves coal-fired electricity from a substation in Greene County, Pennsylvania to a substation in Loudoun County’s “data center alley.” Data center alley is home to the largest concentration of data centers in the world. Regional grid operator PJM Interconnection planned the project, and assigned a different segment to each company to complete.

NextEra Energy has responsibility for the 105-mile segment from Pennsylvania to a point in Frederick County, Virginia. NextEra named their segment MARL. The new transmission line continues with a 45-mile segment from Frederick County, Virginia to Loudoun County, Virginia that is assigned to FirstEnergy, Potomac Edison’s parent company. Potomac Edison named their segment Gore-Doubs-Goose Creek, after the substations it connects.

Each company is responsible for securing a state utility commission permit in every state which its project crosses. A Notice of Intent to file an application is required by West Virginia law to be filed at least 30 days before the actual application, and expires after 90 days.

The West Virginia Public Service Commission has opened a permitting docket for each company’s application.

The Case Number for Potomac Edison’s segment is NOIE Potomac Edison 25C.

The Case Number for NextEra’s segment is NOIE NextEra Energy 25A.

The new dockets enable concerned persons to formally file comments and/or petitions about the projects at the PSC. To do so, visit the PSC’s website and select “Submit a Comment” from the left hand menu. Then select “Formal Case” from the next screen. Agree to the disclaimer on the next page, and it will bring up a form to fill out with a space to type your comment. Be sure to include the Case Number in your filing.

If you would rather mail your comments in, send them to:

West Virginia Public Service Commission
201 Brooks Street
Charleston, WV 25301

Be sure to write the Case Number on your comments.

If you previously submitted comments, Resolutions, or letters to the PSC about these projects, you may need to resend them with the correct case number on them in order to have them become part of the official record in the docket. You may file comments on either, or both, docket(s). There is no limit on how many comments you can send. You could send them one every morning over coffee until a decision is made. It’s up to you.

Next Steps:

The companies will file their applications in their respective dockets. Once the application is filed, the company must notify impacted landowners by certified mail at least 30 days before the deadline to intervene in the case. The PSC will set a deadline to intervene in the case after the application is filed. It may be as soon as 30 days after the application is filed, but not sooner than the company sends you a notice via certified mail.

Intervening means becoming a legal party to the case, with the right to file testimony and cross-examine the company’s witnesses. Intervenors may also file briefs, recommending a decision to the PSC, and only intervenors have a right to appeal the PSC’s decision in the case.

Persons with an interest in the case, whether as an impacted landowner or electric ratepayer, may intervene and request party status. Intervenors may hire an attorney, or they may participate pro se, which means representing himself or herself without an attorney. Intervenors may also join together and hire one attorney to represent an organized group of intervenors, which can make representation less costly. We will have more information about intervening coming up soon.

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MARL and Gore-Doubs-Goose Creek are the SAME project!

8/27/2025

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The companies assigned to build one of the components of PJM Interconnection's project B3800 have made an absolute mess of the public's understanding of the project. Congratulations, NextEra and FirstEnergy! This is all your fault!

PJM doesn't invent and assign cutsie-poo names like MARL or Gore-Doubs-Goose Creek to the projects it approves and orders. It gives them numbers. B3800 was assigned to this project when it was approved in December 2023. Names like MARL and Gore-Doubs-Goose Creek are inventions of the companies that PJM assigns to build the projects it orders. Different names do NOT mean different PJM projects. They're all B3800.

Here's the only thing you need to know about MARL and Gore-Doubs-Goose Creek.

A picture is worth a thousand words, right? If you study this one, you'll figure it out, despite the stupid stuff NextEra and FirstEnergy are saying right now. Block all their nonsense out of your mind. This is one continuous 500kV transmission line. It's all connected, just like a gigantic extension cord. Pay attention to the key on this map. There is a table called "Transmission System Enhancement" that lists the different color-coded line segments and the companies that PJM assigned to build each segment of this ONE 500kV line.

Starting at the top of the list is a dark pink/purply segment assigned to AEP. AEP stands for American Electric Power, who owns a section of existing 500kV line between the Kammer substation and the 502 Junction substation. AEP's part of this project was to study its existing line to assure it could pump more power from Kammer. Kammer is the name of the substation at AEP's Mitchell Power Generation station in Marshall County, WV. AEP is not building a new line here (at least not in this project).

Next the table lists yellow for Dom. That stands for Dominion. Dominion is the Virginia-based utility that will be building the last 3 miles of this 500kV circuit from Edwards Ferry to Goose Creek in Loudoun County, Virginia. It's really impossible to see the yellow part of this map because it's tiny compared to the rest of the line's mileage. Just know it's there, at the eastern end of the line.

Then we have red for Exelon. Exelon owns a short segment of existing line and easement in Montgomery County, Maryland that would be reconfigured to change a corridor containing one 500kV line and two 230kV lines into a corridor that contains three 500kV lines and two 230kV lines. One of those new 500kV lines in Maryland is part of B3800, the continuous 500kV line from 502 Junction to Goose Creek. You can barely see the red if you look hard.

And now we're getting to the real meat here... blue and peach. The blue part of the line is owned by FirstEnergy (FE) subsidiary Potomac Edison. The FE part of the line begins at a point in Frederick County, Virginia where the NextEra part ends and runs east through Jefferson County, WV, Loudoun County, VA, and Frederick and Montgomery Counties, MD to a point at Edwards Ferry where Dominion picks up the construction of the 500kV circuit. The blue part of the line is approximately 45 miles long. The blue part of the line plans to tear down an existing 138kV circuit on 65 ft. tall towers and replace it with double circuit 500/138kV lines on a new tower 185 ft. tall. FirstEnergy named this part Gore-Doubs-Goose Creek.

And last, but certainly not least, the peachy colored part of the line that is assigned to NextEra. This 105-mile long segment begins at 502 Junction substation and ends at a point in Frederick County, Virginia were FirstEnergy's segment of the project begins. We're literally talking about two adjacent transmission towers carrying one continuous 500kV circuit, except one tower is owned by NextEra, and the other is owned by FirstEnergy. These are not two separate projects physically. The separation only exists in legal documents and the balance sheets of competitors NextEra and FirstEnergy. NextEra named its peach MARL.

To put the parts of the map in order from west to east: dark pink (AEP), peach (NextEra), blue (FirstEnergy), red (Exelon), more blue (FirstEnergy), and then yellow (Dominion), which connects to a substation that serves Loudoun County's data centers.

PJM approved and ordered ONE 500kV circuit between 502 Junction and Goose Creek and then assigned the project to 3 different companies to build. Each company has made up its own name for its segment. NextEra calls its 105-mile portion of the project MARL. FirstEnergy calls its 45-mile portion of the project Gore-Doubs-Goose Creek. Dominion has not come up with a name for its 3 mile section in Virginia because it has not presented the project to the public yet.

This confusion about who owns what and what the project is called and what connects to what can be flung directly on the door step of NextEra and FirstEnergy.

NextEra has been playing pretend games that its 105-mile segment of PJM's 500kV circuit is a separate project not connected to anything else. NextEra says it begins in PA and ends in Frederick County, Virginia. The media has added the narrative that MARL connects with "a data center in Frederick County, Virginia" which is just false. There are no significant data centers in Frederick County. All the data centers are in Loudoun County. Loudoun and Frederick are not even contiguous counties. Jefferson County, WV sits between them. We need some basic geography here!

NextEra may have created this false narrative in the press because it thought that it could escape any bad data center juju being attached to its project. Didn't work. We all know MARL is a data center extension cord. All that narrative did was confuse the heck out of people when Jefferson County popped into the picture on Monday when FirstEnergy filed a Notice of Intent at the PSC.

FirstEnergy, for its part, contributed to this confusion by refusing to name its project, or to do any public relations about it until just recently (and still its attempts can be called anemic at best). The citizens of Jefferson County have been fighting FirstEnergy's part of PJM's 500kV circuit for 2 years now. Because FirstEnergy refused to acknowledge the project, we named it for them, and we called it MARL, adopting NextEra's name for this 150-mile long 500kV circuit.

So, when FirstEnergy's Potomac Edison filed its Notice of Intent at the PSC, it said the project was "also referred to as MARL". That is absolutely 100% true.

And the media circus began. The stories pumped out don't even make sense, and the confusion becomes deeper and deeper. Take a deep breath... just look at the map!

I'm guessing that NextEra got its corporate panties in a wad yesterday because FirstEnergy had used their MARL name in their Notice of Intent at the PSC. FirstEnergy tried to issue a retraction yesterday. This confused things even more.

And, using my best mom voice, here's some advice that NextEra and FirstEnergy should take to heart.

GET OVER YOURSELF, KIDS!

Stop your bickering and squabbling and not wanting to be associated with each other. It's going to come back and bite you in the butt at the PSC.

The PSC will have two separate applications for two different segments of the same transmission line. Are the companies going to keep pretending they have nothing to do with each other before the PSC? That's going to be a little uncomfortable for PJM's witness, won't it? You'll never get away with it. And it would serve you right if the PSC denied one of these segments because they didn't know the other was connected to it.

FIX THIS MESS!

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Double Jeopardy!

8/23/2025

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PJM Interconnection, our regional grid operator and planner, is always planning something. PJM regularly presents problem statements to transmission developers and solicits proposed solutions as part of a competitive transmission process. Each RFP for transmission solutions is called a "window". PJM presents its problem statement, and willing developers submit proposed solutions. PJM's competitive transmission windows are what brought us the MARL, Gore-Doubs-Goose Creek, and Valley Link projects.

Once the open "window" closes, developers submissions are posted on PJM's website with a lot of "competitive" information redacted so that only a skeleton of the proposal is available to the public. These bare bones proposals are turned into maps and tables that PJM's Transmission Expansion Advisory Committee (TEAC) discusses at its monthly meetings with the goal of selecting one of more of the proposals to address the problem PJM described. The discussion and selection usually takes place over the course of several months, and once PJM's TEAC has selected a project or projects, it must read them into the record twice at committee meetings before submitting them to PJM's Board of Managers for approval. If PJM's Board of Managers approves the new projects, they are added to PJM's Regional Transmission Expansion Plan (RTEP) and assigned to their transmission developer sponsors. PJM signs what's called a Designated Entity Agreement (DEA) with the developer and the developer begins routing and engineering studies and eventual public information sessions that they call "Open House" meetings. This is the exact process that MARL, GDGC and Valley Link have followed.

PJM opened a new competitive window in June of this year to solve a number of problems with the transmission system. The main problem, as always, is that Northern Virginia demand is skyrocketing due to new data center proposals. You can look at the factors PJM was considering by reviewing PJM's TEAC meeting slides from last month. PJM said that some of the lines bringing power from the west would be overloaded in 2032. Here's one of their maps.

I will share that PJM's meetings and information are high on the techno-speak level and may appear confusing to most people.

PJM's 2025 Window 1 closed on August 18. PJM received many new transmission proposals. Not all proposals submitted will ultimately be selected. However, we have a first look at what has been proposed so that we can follow PJM's evaluation of these proposals and selection of the projects it wants to move forward. Here's the full list of proposed projects (expand the 2025 RTEP Window 1 link). They are simply referred to by number, and each number has a brief description of the project, with much of the specific information redacted to protect competitive information. The name of the proposer is always redacted, however there's much we can garner out of the information that is not redacted that gives us clues about who may have proposed them.

One of the proposed projects is numbered 896. This proposal, which may have been made by FirstEnergy or NextEra, calls for turning MARL into a double circuit 500kV transmission line, and adding a second 500kV line to the first segment of GDGC across Frederick County, Virginia.

The proposed MARL double circuit begins at FirstEnergy's Fort Martin power station in Morgantown, WV.

Convert the 500kV single circuit 502 Junction - Woodside 500kV project under development (PJM Baseline Upgrade ID b3800.102) to a double circuit configuration between Fort Martin and the NEETMA/APS interconnection point in Frederick County, VA, to accommodate Circuit 1 (b3800.102: 502 Junction – Black Oak – Woodside 500kV) and Circuit 2 (Fort Martin – Sandy Creek – Woodside 500kV).

The project calls for a new 138kV line from Ft. Martin to a new substation in Mon County that would be called Sandy Creek. The proposed Sandy Creek substation will intersect with MARL and feed power directly from Ft. Martin to the new 500kV circuit proposed to be added to the MARL project. The Sandy Creek substation is described:

AC Air Insulated Substation (AIS): New proposed 500-138kV Substation. New 500kV ring switchyard with three (3) line terminals, three (3) 500kV, 5000A, 63kAIC breakers, one (1) 500-138kV, 485 MVA transformer bank.

The new 500kV circuit will be added to MARL's proposed towers so that MARL would consist of TWO 500kV transmission lines, possibly hanging from the same new tower. The proposer says this doesn't make any difference because MARL has not been constructed yet so they can change the towers and the circuits.

Approved 502 Junction - Woodside 500 kV project (PJM Baseline Upgrade ID b3800.102) has not been constructed so no existing hardware will be impacted.

The entire circuit shall be upgraded to a double circuit from a single circuit from the point where the Fort Martin - Sandy Creek circuit joins the 502 Junction - Black Oak circuit until the point at which the Sandy Creek - Woodside circuit transitions to single circuit towers.

This includes the entire portion of MARL from a point in Mon County to the place in Frederick County, Virginia where the MARL project ends and the Gore-Doubs-Goose Creek project begins. It would impact Mon, Preston, Garrett, Allegany, Mineral and Hampshire Counties. The proposer says it will use "existing right-of-way" but that right-of-way doesn't actually exist yet and will only exist if MARL is approved and built. It only exists on paper right now because NextEra has not actually obtained any right-of-way for the MARL project in those counties yet. Talk about counting your chickens before they hatch, right?

Existing right-of-way to be used for upgrading the single circuit to a double circuit. ROW Adjustments may be required in specific locations to mitigate engineering and/or operational risks.

Once this new double circuit 500kV line gets to the demarcation point between MARL and GDGC in Frederick County, Virginia, it proposes to run on a new 200 foot right of way for 17 miles across Frederick County until it reaches the proposed Woodside substation owned by NextEra.

The approximately 17-mile route in Frederick County, Virginia travels eastward from the MARL NEET/FE handoff, paralleling the existing Mt. Storm to Doubs 500kV corridor where feasible. The route will have a 200 ft ROW width. The proposed ROW will be an expansion of existing transmission line corridors for approximately 20% of the route length, the remainder will be greenfield ROW.

They can't simply continue the double circuit on the same new towers when they get to Frederick County because that is the point where the Gore-Doubs-Goose Creek line is already planned to be constructed as a double circuit with the existing 138kV line. The second 500kV circuit would need a whole new right-of-way parallel to the existing configuration. And don't forget that Valley Link is coming along behind it and creating its own new 200 ft. right-of-way. Frederick County is looking at not only the new 185 ft. tower for the first 500kV circuit, but the addition of two new lines on parallel rights-of-way that would add 400 feet to the existing 250 foot wide corridor. Total if this is selected and completed: 650 feet wide right-of-way with three 500 kV lines, one 138kV line, and one 765kV line. That's a whole lot of power and a whole lot of expansion for Frederick County!

Meanwhile, back in Mon County, Fort Martin's substation must expand for this plan.

Expand the existing 500kV double breaker double bus (DBDB) switchyard by adding (2) 500kV breakers to create (1) new bay with (1) new line position. Replace (9) existing 500kV breakers.
Assumes that fence line must be expanded to west to accommodate upgrades.
Based on publicly available parcel data and imagery, upgrades are expected to fit on transmission-owner owned property.

The new line from Fort Martin to the new Sandy Creek substation will be constructed for approximately 1-mile and parallels the Hazelton to Lake Lynn 138 kV in Mon County on a proposed new 100 ft. right-of-way. A second new 138kV line from a nearby substation will also parallel Hazelton to Lake Lynn for an additional 2 miles of new 100 ft. right-of-way. That's three miles of new right of way in Mon County, and a new substation.

Seems like double jeopardy for impacted landowners, doesn't it? As if it's not bad enough that MARL is proposed for your property, now the transmission companies want to double your pain with a second 500kV circuit and miles of new right-of-way, and a new substation, in Mon County and Frederick County.

For what? To get power to data centers in Northern Virginia.

It really emphasizes the fact that these new transmission lines are NOT for West Virginia, and they are NOT needed to attract new data centers in the West Virginia counties they cross. They are for Northern Virginia data centers, they are not for us!

PJM's TEAC meetings are open to all "stakeholders". We are all stakeholders in this and anyone may attend the TEAC meetings where these projects are discussed to ask questions or make comments. PJM TEAC meetings are held once a month, during the work day, and may be attended via Webex or over the telephone. If you want to attend, you can sign up on PJM's website. You must have a PJM account and pre-register for the meetings. If that's not your cup of tea, you can simply get updates from citizens who regularly attend these meetings and save your written comments for PJM's Board of Managers if this proposal is ultimately selected by PJM's TEAC.

Remember, this is only a proposal right now and there is no guarantee it will be selected. However, MARL and Valley Link were once only just proposals like this, so consider this a heads up on what PJM may be cooking up to invade your community in the future.

Transmission extension cords from West Virginia will never be enough for Virginia's insatiable appetite for electricity and it is expected that PJM's planners will keep adding more and more unless West Virginia stands up and says NO.

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Digging Into MARL

8/8/2025

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West Virginia's talk news has been all over the subject of the MidAtlantic Resiliency Link, or MARL, for the past couple of weeks. Despite their heroic efforts, they've barely scratched the surface of the truth about MARL. It's much more complicated than can be explained on a brief radio show, obviously, and probably more than can be covered in a brief facebook post. Isn't it time for everyone to dig a little deeper? I promise it won't be too complicated. I've learned to distill understandable facts from of the energy industry's big jug o' technospeak over the past 17 years. This won't hurt a bit!

I'm going to concentrate on a recent MetroNews Talkline radio interview of NextEra's Kaitlyn McCormick. Listening to it was pretty rough because Kaitlyn kept fading in and out and it was hard to understand much of what she said. Was she talking on a cell phone while driving through West Virginia's beautiful mountains? Or was she just waving her phone around while trying to talk on speaker? Take your pick. I'm going to use the equally bad transcript to try to decipher exactly what she said.

Let's begin with the fact that MARL is only one part of a larger project approved by PJM Interconnection. Even Kaitlyn admits that, although the radio hosts insist on treating it like an individual project. This is a map of the project PJM approved:

MARL is the light peachy-colored line here that begins at the 502 Junction substation in Greene County, PA and ends just over the state border at Gore, VA. The blue line is a continuation of the new 500kV line to be built by rival company FirstEnergy. They are calling their project "Gore-Doubs-Goose Creek" after the substations it will connect. FirstEnergy's portion of the project begins where NextEra's ends and heads east to continue the electricity extension cord to its ultimate destination, a substation in Loudoun County's "data center alley" called Goose Creek. Neither one of these projects can stand alone. PJM needs BOTH of them to be built to deliver this power to a whole bunch of new data centers planned in Loudoun County. MARL is not delivering power to a data center in Frederick County, Virginia. It is simply plugging into FirstEnergy's portion of the project in Gore. If one of these two line segments isn't built, the other one won't be built either. It's all or nothing because PJM needs both segments to deliver the power from 502 Junction to Goose Creek.

And let's talk about 502 Junction for a moment, shall we? 502 Junction is an existing substation located in Greene County, PA. Think of 502 Junction as the Grand Central Station of electricity. It collects electricity generated by plants in the area and re-directs it to new destinations. Just because 502 Junction is located in Pennsylvania doesn't mean that all the electricity that passes through there is generated in Pennsylvania though. In fact, most of the electricity passing through 502 Junction is generated in West Virginia! Here's a map of PJM's transmission system showing 502 Junction and the lines that connect there.

This map shows what generators connect to 502 Junction to deliver their electricity for re-direction elsewhere. To the west is AEP's Mitchell plant. Connecting from the south is FirstEnergy's Harrison plant. In Morgantown, lines connect both the Longview and Ft. Martin power generators to 502 Junction. On its way to the southeast, this project will connect with lines feeding out of Dominion's Mt. Storm power station in Grant County, WV. That's over 7,000MW of hot, juicy, 100% West Virginia coal-fired electricity, and Virginia's green virtue signaling data center companies are hungry, hungry, hungry for it!

And they're hungry because Virginia has closed down many of its fossil fuel generators that can run when called in favor of intermittent solar and wind projects. Virginia has closed more generation than they have brought online, creating a power deficit. In addition, Northern Virginia is practically exploding with new data centers proposed by some of the wealthiest companies on the planet (Amazon, Google, Microsoft, Meta). Virginia has no way to power all the stuff it's building. Virginia just keeps demanding that PJM import more and more power to Virginia, and PJM has only one place to get it... West Virginia!

And this leads us back to WHY PJM Interconnection ordered this project. PJM did NOT select the two end points for this project. PJM only selected one, Goose Creek, where the data center load is located. PJM was open to any transmission extension cords bringing up to 7,500MW of new electric supply from anywhere, as long as it connected to Goose Creek. It was NextEra who decided that there was an opportunity to suck up to 7,500MW of coal-fired electricity out of West Virginia. Here's a PJM slide that verifies this need, as well as what the need is for.

PJM needed new transmission to address reliability problems that would develop on its system if it connected 7,500MW of new data center load in Northern Virginia. If the only tool you have is a hammer, every problem looks like a nail. While PJM's job is to keep the lights on by making sure power flows throughout the region when needed, PJM's only tool to get the job done is transmission. PJM cannot order new generation to be built, and Virginia is taking advantage of that. Virginia considers itself a "clean" state and passed a "Clean Economy Act" that relies on importing more and more coal-fired power from West Virginia. It's okay for Virginia to pollute our state, but not their own. West Virginia is just their dirty little energy colony. It's time to stand up and say enough is enough!

MARL is located in West Virginia simply because West Virginia is in the way of the extension cord from 502 Junction to Loudoun's data center alley. There's no way to get West Virginia generated electricity to those Virginia data centers without destroying West Virginia along the way. NextEra doesn't care about that. They're going to make billions! Virginia doesn't care about that. They're also going to make billions in new tax revenue if they can build new data centers powered by West Virginia coal imported via gigantic transmission extension cords.

Kaitlyn made much of MARL connecting to an existing substation at the Mineral/Allegeny border. That substation is called Black Oak. It's been there for decades. MARL needs to connect there for what PJM calls "voltage support." When transmission lines are long and don't connect anywhere along their path (such as a line from 502 Junction to Goose Creek) they can get unstable and need injection of reactive power along the way to maintain the correct voltage. MARL is connecting with Black Oak to suck power out of that substation in order to stabilize its voltage, not to deliver power to either county. PJM has stated that there will be no new substations planned along MARL's route. MARL isn't for West Virginia, or any community along the way. MARL's entire capacity is already called for by data centers in Loudoun County, VA. There is no way for West Virginia to benefit from additional substations. That's not how new demand is planned.

In order to plan to build new load in any location, there has to be an actual customer who requests electric service. No utility (or PJM) plans to build power lines or generators with the hope that doing so would attract new load. All utility infrastructure must be used and useful to the consumers who pay for it. So, a real data center must request electric service in your county. Then the utility that serves your county must evaluate whether they can serve the load with the existing system. If so, the new load is connected. If not, then the utility sends a load request up to PJM, who includes that in their next transmission planning load forecast. This is exactly how MARL was planned. It wasn't planned for us, it was planned for data centers in Virginia.

Kaitlyn's blathering about congestion and reliability in West Virginia avoids the real issue... connecting more data center load in Virginia is what destabilizes the system because Virginia is not also connecting more electric generation to match its load request. There are only congestion and reliability issues in West Virginia if those data centers in Virginia are connected. If West Virginia doesn't approve MARL, then those data centers will have to wait longer to be connected, or will simply go elsewhere that has available power. PJM will not connect new data centers that will cause blackouts on the system. PJM's first job is to maintain the reliability of the existing system.

Kaitlyn tries to pull a fast one on these radio hosts and listeners. She says that everyone's goal is to minimize overall impacts. This presumes that everyone agrees that MARL must be built. West Virginians do NOT agree it needs to be built, or that MARL is a fait accompli. West Virginians believe that this project is not logical or helpful to West Virginia and that it can be stopped!

Kaitlyn prattles on about paralleling existing transmission lines as a least impactful solution. That's only if you don't live near those existing lines. Where's the equity in property impacts between those properties already doing their part to host unwanted public infrastructure and the rest of us who don't have to do anything to help? Paralleling existing transmission lines is actually MORE impactful because it cannot deviate around homes or other land uses like a line sited on unburdened land. Paralleling is only "better" in the minds of transmission executives and PJM planners who think landowners who live next to existing easements will be a push over. How about now? How about one of the biggest waves of transmission opposition in PJM history? Is paralleling still such a great idea? It's not. It's an idea that needs to die.

MARL will cost West Virginians hundreds of millions of dollars. Kaitlyn really needs to find out how those rates are set. This is the second time she's told a lie about the state utility commissions setting rates for MARL. Even after she was invited to her own company's annual formula rate update meeting! Maybe she's just playing dumb so she can lie with a straight face? Transmission rates are set by the Federal Energy Regulatory Commission. State utility commissions have no jurisdiction to set those rates and must pass them through to their state consumers unscathed. Kaitlyn needs to stop making me think she's dumb as a box of rocks and perhaps get some training about transmission cost allocation and rates.

The only way we're going to get to the bottom of this is to keep digging!

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Take Back Your Power, West Virginia!

8/5/2025

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For years, West Virginia has been the target of big green lawsuits, and the butt of arrogantly rude jokes. Our state has mined coal, burned coal, and exported the electricity produced for more than 100 years. West Virginia is one of only two consistent electric power exporters in our PJM Interconnection grid region. States to our east, however, have adopted their own "clean energy" legislation that causes fossil fuel electric generation within their borders to close, such as the Virginia Clean Economy Act. However, these "clean" states have no qualms about importing increasing amounts of dirty coal-fired electricity from West Virginia though. Virginia's plan to supply its "clean" economy with electricity relies on increased imports of electricity from West Virginia.

Virginia's economy has created "data center alley," the largest concentration of data centers in the world. The whole world! And Virginia has been powering them with our dirty coal-fired power from West Virginia. This is what has made Loudoun County, Virginia, the wealthiest county in the nation. The whole nation!

And there Virginia sits, sneering at West Virginia and making jokes about how we're at the bottom of many state achievement lists and maligning us as a bunch of hillbillies who actually LIKE being trodden by Virginia's polished boots on our neck. If there's something the "civilized" in Northern Virginia want that comes with impacts, they look right away to West Virginia as their sacrifice zone.

Today's West Virginia is DONE with that!

Now Virginia wants to build out a network of AI data centers, the largest in the world. But Virginia also doesn't want to have the infrastructure necessary to power those data centers in their own back yard. Virginians would yell and scream about the protection of their environment, while demanding that the infrastructure they don't want be moved to West Virginia.

Instead of building the infrastructure to power the data centers Virginia wants near the load they are creating, Virginia is playing a coy game with regional grid operator PJM Interconnection. They simply encourage new AI data centers to make load requests to Virginia public utility Dominion Energy. Dominion sends these impossible load forecasts up to PJM Interconnection, and PJM uses the only tool at its disposal to meet the load request of a public utility... transmission! PJM does not and cannot order the construction of new generation. It can only plan and order transmission, and that's exactly what it's done... planned and ordered new transmission extension cords from West Virginia's coal-fired power plants to serve the new AI data centers in Virginia. West Virginia's public utilities, owned by corporations based in Ohio, are thrilled with this arrangement because they not only make money selling more electricity produced in West Virginia, they also rake in billions of dollars building new transmission extension cords.

This has to STOP!

AI data centers can be built practically anywhere that there is power and water available. They don't need to be located within Northern Virginia's data center alley. AI data centers could actually be built in West Virginia, in communities that want them and their tax revenue. That's exactly what West Virginia's elected officials were thinking this year when they passed The Power Generation and Consumption Act (aka HB 2014). However, it seems that data companies are hardly beating a path to our door. Instead, there was a big announcement recently where Pennsylvania became the home to many new data centers in the planning stage.

Apparently it takes *more* than just allowing data centers to build their own generation. And it's all about who pays! West Virginia's Power Generation and Consumption Act makes the data center pay to build its own power. Other states simply push the service requests up to PJM interconnection, who orders new transmission that electric consumers pay for. West Virginia is also a vertically integrated state where utilities own generation, transmission and distribution. Generation built by our utilities is paid for by West Virginians. When data centers get built in other states, West Virginians end up footing the bill to power them! Frankly, that is OUTRAGEOUS!

After all these years, West Virginia finally has something other states want. West Virginia needs to quit giving it away and being satisfied with the crumbs left from the other state feasts.

Take back your power, West Virginia! Don't allow new transmission extension cords that drain our power to be built in West Virginia! West Virginia has the final say whether new transmission extension cords are built in West Virginia. If West Virginia keeps allowing other states to siphon off our power, there's nothing here to attract data centers. They'll locate in surrounding states and suck all our power out of West Virginia.

Say NO to new transmission extension cords providing OUR power to surrounding parasitic states! If we keep feeding new data centers in Virginia, they never have any reason to build here instead. Keep our power here, providing economic development to our own state.

Take back your power, West Virginia! Say NO to new transmission extension cords across our beautiful state!

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What's a Transmission Open House?

7/29/2025

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Yesterday, landowners in Virginia began receiving letters from FirstEnergy's transmission group with information about the first of several transmission extension cords ordered by regional grid operator PJM Interconnection to power Loudoun County's data centers with West Virginia generated coal-fired electricity. The letters also invited landowners to several "Open House" meetings to be held along the project route in mid-August.

Tuesday, August 12, 2025
6:00-8:00 P.M.
Lovettsville, VA
Lovettsville Volunteer Fire Hall
12837 Berlin Turnpike
Lovettsville, VA 20180

Wednesday, August 13, 2025
6:00-8:00 P.M.
Shepherdstown, WV
Shepherd University Wellness Center
164 University Drive
Shepherdstown, WV 25443

Thursday, August 14, 2025
6:00-8:00 P.M.
Winchester, VA
Museum of the Shenandoah Valley
901 Amherst Street
Winchester, VA 22601

If you didn't get a letter (yet), you can read the letter by downloading this file. Sorry, but FirstEnergy is withholding access to its website until August 12. Be sure to mark that down to include in your comments to the Public Service Commission... withholding of information and insufficient time to meaningfully interact with the community during routing.

firstenergy_gdgc_open_house_letter.pdf
File Size:	1443 kb
File Type:	pdf

Download File

You are encouraged to attend these Open House meetings to get more information and to ask questions, lots of questions. Feel free to attend any (or ALL) of the meetings, but the meetings will be identical. So, if you forget to ask a question, or need more information, hit repeat the next night at a new location.

The Open House meetings for transmission projects are always the same format, and I've been to lots of them. It's NOT a "Town Hall" or other form of meeting with a formal information presentation with designated speakers followed by a Q&A for everyone at the meeting to take turns asking questions. Instead, these meetings are a place for individuals to hunt for little bits of information at certain "stations" set up around the room. Bring your Sherlock Holmes outfit, not a prepared speech. It's pure divide and conquer. Each station will cover a specific topic and be staffed by one or more FirstEnergy subject matter "experts". You are supposed to enter the room and sign in to give FirstEnergy all your contact information so that their land agents have an easier time harassing you in the future. Then you are supposed to filter through and interact with each station set up along the perimeter of the room like cattle in a chute. When you finally get to the end of the stations (back where you began) you will be asked to fill out a comment card and let FirstEnergy know what you think about the project. This is a diagram of their set up:

There is no place for you to make a public comment to all the meeting attendees, so don't bother writing one. Instead, you will talk one-on-one with FirstEnergy employees and contractors. If you insist on having a moment and making a shouted announcement to all the attendees inside, count on FirstEnergy to have security at the meeting who will escort you out.

Open House meetings are loud and confusing. There are hundreds of people talking at once in a confined space. It is extremely hard to hear what anyone is saying, even someone right next to you.

Sometimes, the companies go all out and provide food, drink and freebie souveniers, such as keychains, notebooks, or cheap Chinese Yeti knockoffs with their project name on them. FirstEnergy ain't having none of that at the Maryland meetings for Gore-Doubs-Goose Creek (aka MARL). There will be nothing for you except paper handouts. Not even a drink of water. Bring your own so you can stay hydrated. It's been hot out there!

And speaking of hot out there... feel free to stage a protest outside the Open House meeting. Wave signs, sing songs, chant, but don't block the entrance or waylay people on their way inside. They'll probably be back to join you after getting their own dose of "information" from inside. Get to know other people in your community who are also affected by the transmission project. Exchange contact information. Create a petition against the project for people to sign. But remember, keep it peaceful and don't interfere with what FirstEnergy is doing inside. Sorry I won't see you there, but we can talk afterwards.

Here are some photos from FirstEnergy's June Open House in Montgomery County, Maryland.

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Is the Deep State Conspiring with Grain Belt Express?

7/28/2025

1 Comment

It didn't take long for the deep state at DOE to "resist" Secretary Wright's cancellation of Grain Belt's conditional loan guarantee by spilling to some obscure fake news media outlet. In doing so, they really step in it... deeply! Secretary Wright ought to investigate these leakers... and fire every last one of them. They admit to breaking the law and conspiring with Grain Belt Express to hide the truth about the project in an attempt to fool President Trump and to push through a loan guarantee whose application process was not complete. The DOE never finished GBE's Environmental Impact Statement, which is supposed to guide its decision on whether or not to take an action (such as making a conditional loan guarantee). The admissions here are stunning. Is the DOE Deep State really that ignorant about energy laws? Or was this done arrogantly and on purpose with full intent? I'd like to ask these leakers some questions...

The Energy Department pulled the project's $4.9 billion conditional commitment against the advice of its attorneys — and without career staff.

You say that like it's a bad thing, but is it because they're the Deep State who issued that conditional approval as an attempt to guarantee the loan even though Grain Belt Express had not completed its EIS? And then the Deep State conspired with Grain Belt to hide the project's true purpose from the incoming administration!

When the second Trump administration took office, LPO staff worried that a requirement to secure wind and solar contracts for a certain portion of the line’s capacity could prevent the loan from moving forward — particularly after the publication of an executive order that made it much harder to build wind power. Right up until the last few weeks, sources told Latitude Media, both the office and Invenergy were discussing how to bring the Grain Belt Express agreement more in line with the administration’s priorities, by expanding offtakers beyond wind power.

So, let me get this straight... the DOE staff was advising Invenergy to remove all reference to wind (and solar) from its website and to leak that bogus story about building a gas plant and negotiating with coal-fired generators? And the DOE staff did this knowing Grain Belt's eligibility for a DOE taxpayer-backed loan is tied to Title XVII of the Energy Policy Act of 2005 (EPAct) (42 U.S. Code [U.S.C.] 16513), as amended. Section 1703 of Title XVII (the Clean Energy Financing Program) defines eligible projects as those that, “avoid, reduce, or sequester air pollutants or anthropogenic emissions of greenhouse gases [GHGs]; and employ new or significantly improved technologies as compared to commercial technologies in service in the United States at the time the guarantee is issued” (Public Law [P.L.] 109-58, Section 1703(a)). When Grain Belt's "clean energy" premise went away, so did its eligibility for the loan. How was DOE staff planning to explain how a transmission line carrying gas- and coal-fired power was avoiding, reducing or sequestering air pollutants or greenhouse gases? Or was DOE planning to have two faces... one for Trump and his administration, and one for the public and the courts? How did they ever think they would get away with this? Fact is, they didn't.

But, even when their horrible duplicity could have been buried forever and forgotten, these same Deep Staters decided instead to parade it around like a virtue and thumb their nose at everyone, drunk on their own power. These are people who survive on your tax dollars, arrogantly doing whatever they want. It's time to clean house at LPO, and probably a lot of other places, too. It's not "resistance", it's insubordination and law breaking.

And what else here breaks the rules?

...LPO staff worried that a requirement to secure wind and solar contracts for a certain portion of the line’s capacity could prevent the loan from moving forward ...

That requirement by DOE VIOLATES GBE's Negotiated Rate Authority issued by FERC. In GBE's original Negotiated Rate Authority Order (which may or may not have been amended, extended, or renewed recently) the Commission was emphatic that Grain Belt Express could not use generation source as a factor when selecting customers.

Grain Belt Express has not proposed in its application, and we do not approve, selection or ranking criteria based upon the type of generation that a potential transmission customer might seek to interconnect.

If the DOE was requiring that GBE use generation source as a factor to select its customers, then that means that GBE has violated it's Negotiated Rate Authority and therefore has no authority to negotiate with customers. And without voluntary customers... there is no Grain Belt Express! So the DOE Deep Staters were also thumbing their nose at the Federal Energy Regulatory Commission. How arrogant can those little government functionaries be?

And here's another...

Notably, the agreement didn’t require the federal government to shell out direct funds; instead, LPO agreed to act as a guarantor for the project, reducing risk for private lenders, but not making any payments itself unless the project failed.

Let's go back to that same FERC NRA Order...

To approve negotiated rates for a transmission project, the Commission must find that the rates are just and reasonable. To do so, the Commission must determine that the merchant transmission owner has assumed the full market risk for the cost of constructing its proposed transmission project.

The federal government using American taxpayers as a loan guarantor for the construction costs of Grain Belt Express means that the risk of the project has been shifted to taxpayers. If the project fails, then the taxpayers will pay for it. Taxpayers are being used as the insurer of last resort for a 100% voluntary, unneeded transmission line whose only purpose is to make a profit for Invenergy. LPO doesn't have any of its own money, it simply plays Monopoly with OPM (Other People's Money).

That decision, Latitude Media has learned, was made against the recommendation of career attorneys inside LPO, who advised the agency that rescinding the conditional commitment would constitute a breach of contract, and would be illegal. It was also made without the involvement of career staff who worked on the deal.

Ya know what else might be illegal? Issuing a conditional loan guarantee before the EIS was completed. And completely ignoring a FERC Order that DOE was aware of. And conspiring to thwart the intent of Title 17 of the EP Act.

In the case of Grain Belt Express, DOE is asserting that the project isn’t going to meet certain milestones that are required to finalize the loan.
But Grain Belt Express, which has already gone through two years of due diligence with LPO, still had a window of at least four months to reach financial close. Indeed, in the early months of this year, LPO career staff believed the project was moving in the right direction.

Right... was that during the time when DOE staff thought their cover up of GBE's windy purpose was working with the Trump administration? Even if it had another four years, I don't think GBE could find enough customers to provide collateral necessary for this loan. Wait... what? Collateral? Something pledged as security for repayment of a loan, to be forfeited in the event of a default. Does this mean that DOE was planning to guarantee a loan using tax payers as collateral WITHOUT ASSURING THAT GBE HAD ENOUGH CUSTOMERS TO REPAY THE LOAN? Due diligence, my ass!

...when Energy Secretary Chris Wright stepped in to order the cancellation of the loan guarantee in mid-July, DOE’s general counsel didn’t seem to look to offtake numbers for legal justification at all.

What the heck? Offtake numbers? That means nothing! It's only signed contracts from customers obligated to pay for capacity on Grain Belt Express that matter, and GBE has exactly NONE of those. The one contract GBE has said it has is completely optional and the Missouri municipalities can get out of it whenever they want. Does this mean that DOE pretended that "offtake numbers" in the form of Memorandums of Understanding, or simply a utility's future renewable plans unrelated to Grain Belt Express, were used as a form of collateral? No bank would ever rely on such flimsy collateral, and neither should DOE. That's how DOE got into trouble before with Solyndra.

In the spring, the far-right Senator Josh Hawley of Missouri began to publicly take issue with the project and its impact on farmers...

Sorry, far-left reporters, but Senator Hawley has been concerned about Grain Belt Express for the past several years, at least. Don't make it sound like he just found out about it.

The International Energy Agency estimates that nearly 50 million miles (80 million kilometers) of power lines will need to be added or replaced globally by 2040 in order to meet climate and clean energy goals

Well, there's another Deep State agency waste of taxpayer money. The federal government doesn't currently have any climate and clean energy goals, therefore this statement is irrelevant.

According to Rob Gramlich, president of the transmission and power markets-focused consultancy Grid Strategies, federal support could be particularly impactful for interregional transmission lines “where it’s hardest to find any other way to recover costs.”

“It is very hard to find state regulators to approve cost recovery for a multi-state line like this,” Gramlich said. “I’ve always thought that DOE should have a big pot of money for interregional transmission, and that should be the main focus of DOE spending across all of its programs.”

Rob Gramlich is not the federal government. In fact, he works for dark money organizations pushing a political agenda. He continues trying to get "permitting reform" passed so that the federal government can control transmission permitting. Doesn't look like it's going to do him much good right now, is it? The Trump administration is intent on building power generation on site with those new data centers, not doing something as inefficient as trying to transmit it hundreds of miles from generation to load. There's really no use for these kinds of transmission lines.

It's time to clean the Deep State out of our Department of Energy. I'm betting Gramlich knows exactly who they are. Who knows? Maybe they're having cocktails right now celebrating their "resistance"?

That was a close call. Never think that your vote doesn't matter. It stopped this Deep State hustle in its tracks.

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Weekend at Mikey's

7/24/2025

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"All I'm saying is why don't we just pretend he didn't die? Just for a bit?"

Introducing...

It sure took GBE a long time to make a statement after the DOE cancelled their taxpayer-backed conditional loan yesterday. And then what profound wisdom did Grain Belt finally have?

America is energy dominant and an AI powerhouse, and Grain Belt Express will be America’s largest power pipeline. While we are disappointed about the LPO loan guarantee, a privately financed Grain Belt Express transmission superhighway will advance President Trump’s agenda of American energy and technology dominance while delivering billions of dollars in energy cost savings, strengthening grid reliability and resiliency, and creating thousands of American jobs.

Sure says a lot of nothing even though it took all day to write. Sorry, Invenergy, but Trump isn't buying your nonsense about Grain Belt Express. The DOE actually took a look at your project and decided it was never going to pencil out financially. It's over.

There's a reason Grain Belt opted to apply for a DOE taxpayer backed loan under Title XVII of the Energy Policy Act of 2005 (EPAct) (42 U.S. Code [U.S.C.] 16513), as amended. Section 1703 of Title XVII (the Clean Energy Financing Program) that defines eligible projects as those that, “avoid, reduce, or sequester air pollutants or anthropogenic emissions of greenhouse gases [GHGs]; and employ new or significantly improved technologies as compared to commercial technologies in service in the United States at the time the guarantee is issued” (Public Law [P.L.] 109-58, Section 1703(a)). Applying for this loan cost Grain Belt a bundle and it required an Environmental Impact Statement, the cost of which has been said to have made other energy executives have meltdowns in the Secretary of Energy's office. Surely if private financing was available, Grain Belt would have pursued that instead. Except other commercial financing usually requires some proof of enough revenue to repay the loan. Grain Belt's only customer is a collection of Missouri municipalities that might want to purchase up to 225 MW of transmission capacity on Grain Belt, less than 5% of its total available capacity. That isn't going to make the loan payments, especially because Grain Belt gave the municipalities a loss leader price for signing up in order to secure Missouri PSC approval. And on top of that, the Missouri munis want to purchase wind energy from Kansas and have inked a series of contracts to purchase energy from wind farms over the years. I'm pretty sure the munis don't need to import coal or gas from Kansas... they've got enough of that right there in Missouri. The other possibility for Invenergy would be to find itself a sugar daddy Skelly-style. However, it's not just $200M that Invenergy needs, but $11 BILLION. Who's got that kind of money to risk it all on Grain Belt Express? And doesn't GBE's reputation precede it in this circle of influence, where investors lost hundreds of millions on the project already when it was owned by Clean Line? GBE had a reason for applying for the DOE loan and perhaps that was because it thought DOE was going to loan it money it would never be able to repay. Isn't that what happened with Solyndra?

My guess is that Invenergy really hasn't decided what it wants to do with Grain Belt yet, so for now it's going to parade it around like Bernie and pretend it's still viable. It's a project idea whose time has come and gone and it is not adaptable to new energy sources or new purposes. Grain Belt has been trying to find customers for its project since 2010. And they have found none, other than a gullible group of municipalities that thought there was a free lunch somewhere. If Grain Belt Express was needed, or provided any ratepayer savings, or had any useful purpose, then customers would be lined up around the block to purchase capacity. The fact that they are not speaks for itself. Speculative merchant projects do not work unless they have buyers up front.

But Grain Belt continues its charade, pretending it's now a transmission line for gas and coal-fired electricity. Just a day before the DOE cancelled its conditional loan, Grain Belt craftily leaked to Axios that Invenergy was planning to build a gas-fired generation station to provide power to Grain Belt Express and the company is "also in active discussion with a company to bring existing coal-fired generation onto the proposed Grain Belt Express project." Invenergy wants to change how the line is perceived.

Perception is the least of Grain Belt's problems. The real problem with GBE is that is was a project designed for a very specific purpose... to export electricity produced by wind turbines in Kansas to east coast cities. When that purpose is removed, GBE is nothing but an extension cord in the middle of nowhere that isn't plugged into anything. When the proposed wind turbines are gone, GBE's beginning is in a generation desert in southwest Kansas. There's nothing there to connect and therefore GBE isn't needed. Invenergy's ambitions to build a gas plant are not even logical. Is there enough natural gas available near GBE's AC Collector transmission system in Kansas? Where are these existing coal plants? Are they anywhere near the AC Collector system?

Why not build the new gas plant somewhere near load, Invenergy? There is no load to serve in southwestern Kansas. Building a gas plant there serves no purpose... except to try to create a "need" for GBE to move those electrons to load...when the actual gas generation plant could be built near load and avoid the cost of transmitting the energy 825 miles.

Or, how about this? If Invenergy builds new gas plants in southwestern Kansas, how about if new load moves there to use the energy? Again, transmitting the energy 825 miles is completely unnecessary. And what load could Kansas build near new generators in the southwestern part of the state? AI data centers. Data centers have made Loudoun County, Virginia, the wealthiest county in the nation. Why wouldn't Kansas want a little of that tax revenue for themselves, instead of continuing with the Grain Belt Express farce that simply ships power out of state so that other states can build AI data centers and realize the tax revenue? Wake up, Kansas! There are now better ways to monetize your energy potential than Grain Belt Express! President Trump is looking for places that would welcome new data centers that bring their own power generation. Kansas no longer needs Grain Belt Express at all!

But, back to the puzzle of what Invenergy WAS going to build and what it says it WILL build now...

Invenergy has long been planning two enormous new wind farms to generate the energy for Grain Belt Express.

That's a total of 1,800 MW. Grain Belt was supposed to deliver 2,500 MW of power to Missouri. And how was Invenergy going to connect its new wind farms to Grain Belt Express? Using the recently approved GBE AC Collector system shown on the below map.

Lines up perfectly with the Mako and Thresher projects, doesn't it? Because of the location of the collector system, all energy development for Grain Belt must take place south of Dodge City. And what's south of Dodge City?

This is a map of the electric grid around Dodge City. There's nothing but wind south of Dodge City... and lots of open space without grid infrastructure at all. Where are you going to put your gas plant, Invenergy? And why isn't there any actual plan for it that you can point to? What about those coal plants Invenergy is having talks with? The only ones anywhere nearby are in Dodge City and Holcomb to the west. Both of these plants are what would be considered TINY plants by West Virginia standards. How would they even have any need to ship excess capacity anywhere? These coal plants are nowhere near the AC Collector system. What's supposed to happen to Mako and Thresher? Are you cancelling them? Are you cancelling the AC Collector System?

Grain Belt's claims about remaking the project into one that exports coal and gas-fired electricity are about as realistic as Bernie. It's just pretend.

Grain Belt Express was only logical when it was supposed to export wind energy from Kansas. And even then it was too expensive to be financially viable. Now it's just a hot mess of pretend projects that are propping up a dead transmission line and marching it around to commercial and private financing sources pretending it's still alive.

It's time for Kansas and Missouri to re-think their approvals (Illinois doesn't have to because that approval was reversed). GBE is no longer the project they approved and everything has changed. Missouri has already taken the first step to request updated economic studies. Kansas needs to follow suit in the best interest of its people and state (and not in the best interest of a company from Illinois). Unwinding the Grain Belt Express is going to be complicated, but it can be done. It's no longer needed. Any new plans are just an attempt to prop up an unneeded transmission line... and throw good money after bad.

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Prepare for Transmission Permitting Chaos!

Double Jeopardy... Now With Pictures!

How to Respond to the Transmission Company's Notice of Intent

MARL and Gore-Doubs-Goose Creek are the SAME project!

Double Jeopardy!

Digging Into MARL

Take Back Your Power, West Virginia!

What's a Transmission Open House?

Is the Deep State Conspiring with Grain Belt Express?

Weekend at Mikey's

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