JCP&L has been consistent on the project’s need, which stems from a decision made by PJM Interconnection, a regional grid operator that oversees 13 states and the District of Columbia – New Jersey being one of those 13. PJM has stated that a 2011 review found that Monmouth County’s electrical system violates reliability criteria.

PJM Interconnection is a regional transmission organization (RTO) that coordinates the movement of wholesale electricity in all or parts of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of Columbia.

Acting as a neutral, independent party, PJM operates a competitive wholesale electricity market and manages the high-voltage electricity grid to ensure reliability for more than 65 million people.

PJM’s long-term regional planning process provides a broad, interstate perspective that identifies the most effective and cost-efficient improvements to the grid to ensure reliability and economic benefits on a system wide basis.

An independent Board oversees PJM’s activities. Effective governance and a collaborative stakeholder process help PJM achieve its vision: “To be the electric industry leader – today and tomorrow – in reliable operations, efficient wholesale markets, and infrastructure development.”

The North American Electric Reliability Corporation (NERC) is a not-for-profit international regulatory authority whose mission is to assure the reliability and security of the bulk power system in North America. NERC develops and enforces Reliability Standards; annually assesses seasonal and long‐term reliability; monitors the bulk power system through system awareness; and educates, trains, and certifies industry personnel. NERC’s area of responsibility spans the continental United States, Canada, and the northern portion of Baja California, Mexico. NERC is the electric reliability organization for North America, subject to oversight by the Federal Energy Regulatory Commission and governmental authorities in Canada. NERC’s jurisdiction includes users, owners, and operators of the bulk power system, which serves more than 334 million people.

In the 2011 RTEP, PJM identified reliability criteria violations of NERC Category P7 (previously NERC Category C) contingencies for the outage of the Atlantic-Red Bank (S1033) 230 kV line and the No. 2, 230-34.5 kV transformer with the loss of the Atlantic-Red Bank (T2020) 230 kV line and the No. 8, 230- 34.5 kV transformer due to failure of a common structure containing both circuits. JCP&L confirmed this contingency may result in more than 700 MW of load loss, well above the 300 MW loss of load criterion limit, which violates the JCP&L Planning Criteria as well as PJM planning criteria. The JCP&L-proposed Project was confirmed by PJM that it adequately addresses the reliability criteria violation.

PJM has not changed their required date for the project, but has listed the projected in-service date as June 1, 2019 in the RTEP Transmission Construction Status database... Note the PJM Required Date is the date the violation is initially identified to occur.

1.7 Obligation to Build.
(a) Subject to the requirements of applicable law, government regulations and approvals, including, without limitation, requirements to obtain any necessary state or local siting, construction and operating permits, to the availability of required financing, to the ability to acquire necessary right-of-way, and to the right to recover, pursuant to appropriate financial arrangements and tariffs or contracts, all reasonably incurred costs, plus a reasonable return on investment, Transmission Owners or Designated Entities designated as the appropriate entities to construct, own and/or finance enhancements or expansions specified in the Regional Transmission Expansion Plan shall construct, own and/or finance such facilities or enter into appropriate contracts to fulfill such obligations.

1.5.8 (j) Acceptance of Designation. Within 30 days of receiving notification of its designation as a Designated Entity, the existing Transmission Owner or Nonincumbent Developer shall notify the Office of the Interconnection of its acceptance of such designation and submit to the Office of the Interconnection a development schedule, which shall include, but not be limited to, milestones necessary to develop and construct the project to achieve the required in-service date, including milestone dates for obtaining all necessary authorizations and approvals, including but not limited to, state approvals.
 
1.5.8 (k) Failure of Designated Entity to Meet Milestones. In the event the Designated Entity fails to comply with one or more of the requirements of Section 1.5.8(j); or fails to meet a milestone in the development schedule set forth in the Designated Entity Agreement that causes a delay of the project’s in-service date, the Office of the Interconnection shall re-evaluate the need for the Short-term Project or Long-lead Project, and based on that re-evaluation may: (i) retain the Short-term Project or Long-lead Project in the Regional Transmission Expansion Plan; (ii) remove the Short-term Project or Long-lead Project from the Regional Transmission Expansion Plan; or (iii) include an alternative solution in the Regional Transmission Expansion Plan.

The UD and Princeton team showed conservatively that, with some upgrades to transmission lines but without any need for added storage, the PJM grid can handle over 35 gigawatts of offshore wind—that’s 35 billion watts—enough to power an estimated 10 million homes. They also found that the PJM grid could in the future handle twice that amount, up to 70 gigawatts, as wind forecasting improves, allowing the power operator to better predict and harness more wind.

While EEI recognizes that it does not have the right, as a non-party, to submit a request for
rehearing, it is nonetheless submitting this Request for Reconsideration within the time allowed for rehearing requests under 16 U.S.C. § 825l(a).

The move Tuesday at the winter policy meetings of the National Association of Regulatory Utility Commissioners in Washington was "unusual" said Elizabeth Jacobs, a member of the Iowa Utilities Board and vice chairwoman of NARUC's Electricity Committee.

"It wasn't supposed to be directed at any one project," said Jacobs. Rather, she said the resolution "was supposed to be about defending state jurisdiction [over transmission siting] going forward."

But there was some confusion "that made people really nervous," in particular its specific mention of the Plains and Eastern Clean Line proposed by Clean Line Energy Partners LLC, she said.

"I think some people had concerns with language about NARUC taking all necessary actions" to challenge the line, Jacobs said, and thought "Let's think this one through a little more."

The resolution was proposed by Sam Britton, a member of the Mississippi Public Service Commission. He did not return a call seeking comment.

Britton had explained to the NARUC committee that the resolution was "resource neutral" and not anti-wind or anti-renewables, said one attendee.

WHEREAS, Provision “(d) Relationship to Other Laws” of Section 1222 states that “Nothing in this section affects any requirement of ... (2) any Federal or State law relating to the siting of energy facilities; or (3) any existing authorizing statutes,” and
 
WHEREAS, On March 25, 2016, the DOE announced its plan to own the portion of a proposed power line that would traverse the State of Arkansas and rely on Section 1222 to exercise a Federal right of eminent domain in that state; and
 
WHEREAS, DOE has stated that it does not plan to request a site permit from the State of Arkansas but will instead rely on the federal Condemnation Act, which it says authorizes DOE to exercise eminent domain authority over any property so long as DOE has the legal authority to acquire the property, and so long as the project will constitute a public use; and
 
WHEREAS, NARUC has a long-standing position that the siting of electric transmission facilities should be subject to the exclusive jurisdiction of the States, notwithstanding the limited “backstop” siting provision in Section 1221 of the Energy Policy Act of 2005 (which NARUC opposed); and
 
WHEREAS, Without taking any position whatsoever on the wisdom of constructing any transmission project in which DOE wishes to participate or the type of power envisioned to be transmitted over such project, NARUC wishes to state its position on the proper interpretation of Sections 1221 and 1222;

We have analyzed the phrase "withheld approval for more than 1 year." Read by itself, the phrase does not include the outright denial of a permit application within the one-year deadline. We have also considered the phrase in the context of the entire statutory provision in which it appears. A reading of the entire provision reveals that Congress intended to act in a measured way and conferred authority on FERC only when a state commission is unable to act on a permit application in a national interest corridor, fails to act in a timely manner, or acts inappropriately by granting a permit with project-killing conditions. The broader context of § 216(b) thus confirms that the meaning of "withheld approval for more than 1 year" is plain: it means that action on a permit application has been held back continuously for more than one year. The continuous act of withholding approval does not include the final administrative act of denying a permit. Because Congress's intent is clear, our review under Chevron proceeds no further. For these reasons, we reverse FERC's interpretation of the phrase "withheld approval for more than 1 year."

A group of state electric utility regulators tabled a resolution critical of the Department of Energy's plan to take an ownership stake in a 720-mile interstate transmission project from the Oklahoma Panhandle to Tennessee.

The galvanizing issue for some NARUC members is DOE's unprecedented use of its authority to take an ownership stake in a line under Section 1222 of the Energy Policy Act of 2005.

The Plains and Eastern line is ranked No. 9 in a list of 50 high-priority infrastructure projects circulating among governors, lawmakers and the business lobby. And the line could become a topic of debate if Congress and the White House develop economic stimulus legislation aimed at infrastructure development.

The 50-project document touted the line as a "national security project that can add resiliency to our electric grid," citing its ability to "move cheap, clean, wind power energy" that could power more than 1 million homes in the mid-South.

Mario Hurtado, executive vice president at Clean Line who leads the Plains and Eastern Clean Line project, welcomed the NARUC decision.

"Resolutions in a collegial body like this are supposed to be noncontroversial," he said.

"It's not really the role of NARUC to decide on projects. I think a lot of the commissioners were not comfortable passing judgement on single project in this informal association that's supposed be about broad policy," Hurtado said.

"To now to try to relitigate things is sort of like you're trying to start the clock again, and that's not really fair for investors," he said.

...the line could become a topic of debate if Congress and the White House develop economic stimulus legislation aimed at infrastructure development.

For Iowa's Jacobs, the siting issue is getting greater attention by regulators as "the citizens and the consumers are getting more and more involved in major infrastructure projects that deal with energy."

"Consumers would not feel comfortable that the federal government is making a decision that could impact them within miles of their home," she said. "We're hearing it more and more."

The trend in opposition "gives play to the old adage that all politics is local. That's really where we are right now. That whole populist sentiment is really strong out there," Jacobs said.

Jennifer Murphy, NARUC's assistant general counsel, emphasized that the tabled resolution does not negate the organization's opposition to even limited "backstop" siting authority granted to the Federal Energy Regulatory Commission, also in the Energy Policy Act of 2005.

"We have a resolution from 2009 that states our position on backstop siting. And until we have another resolution about backstop siting, that's our position on backstop siting," Murphy said.

Perhaps the new mantra is “we’re going to make transmission great again,” Skelly said.

The organization, an initiative of the Energy Future Coalition, has held regional transmission conferences, but this was its first national event.

The coalition was formed in 2002 by former Sen. Tim Wirth, a Colorado Democrat; Republican C. Boyden Gray, who served as White House counsel to President George H.W. Bush; and Democrat John Podesta, a former aide to Presidents Bill Clinton and Barack Obama who chaired Hillary Clinton’s 2016 presidential campaign.

“I’d love to have more load growth. It ain’t going to happen,” Craig Glazer, PJM’s vice president for federal government policy, told the gathering.

Weak load growth will make it more complicated to finance upgrades for aging transmission, and the lack of a federal carbon tax or renewable mandate is making it difficult to integrate renewable generation, Glazer said.

Hoecker and Brown discussed FERC’s inability to gain “backstop” siting authority, saying it’s still very difficult to prevent individual states from blocking a project. The Energy Policy Act of 2015 amended the Federal Power Act to give FERC the authority to site electric transmission lines blocked by states, but court rulings have blocked the commission’s attempts to use it, prompting some in Congress to propose additional legislation strengthening FERC’s authority.

Brown said that Order 1000 hasn’t really helped SPP much with large regional projects.

“We need to decide what we want this grid of the future to look like,” Glazer said. For example, should it be a “localized grid” that can harness distributed generation? he asked. “There’s an added complication; it’s not even clear who is in charge,” Glazer said. FERC, state utility commissions and governors all have a say in siting decisions, he said.

If each governor is asked what infrastructure projects they want, the country will end up with a lot of state-based projects, not interstate ones, Clean Line Energy Partners President Mike Skelly said.

Perhaps the new mantra is “we’re going to make transmission great again,” Skelly said. The power to select infrastructure projects should not be taken away from transmission planners and placed in the hands of Congress, he said.

Skelly and others cautioned the Trump administration not to skimp on project reviews or stakeholder input. The key is that all projects must have “timelines” for regulatory approvals to avoid infinite delays, he said.

The executive director of the AFL-CIO’s Industrial Union Council, Brad Markell, said the labor movement agrees with the need for “hard timelines” to shorten the permit process.

Markell said that labor unions have been in contact with the Trump administration on potential infrastructure efforts.

“From our point of view, more power for the federal government and less power for the states [on electric infrastructure] would be a good thing,” he said.

Others deemed that unlikely. “I think we’re stuck with the system we have,” Glazer said.

Mary Anne Hitt, executive director of the Sierra Club’s Beyond Coal campaign, said that — contrary to what conference participants may have heard — her organization doesn’t oppose all power lines, only those that appear aimed to “prop up fossil fuels.”

The environmental group opposed the abandoned “coal by wire” Potomac-Appalachian Transmission Highline (PATH) project in PJM. On the other hand, it has backed the Plains and Eastern Clean Line Project, designed to move renewable energy from Oklahoma to Tennessee.

Hitt said she was concerned that President Trump’s nominee for EPA administrator, Scott Pruitt, opposed Clean Line in 2015 as Oklahoma attorney general.

Curiously, there are no sessions scheduled there addressing the unsettled question of whether the federal government has any legitimate interest in transmission siting.

The Hannibal Board of Public Works wants to install a wind farm in Hannibal, and on Wednesday it signed a draft contract indicating its support for a future wind farm.

The Missouri Public Service Commission would ultimately grant approval for construction of the wind farm.

After expressing public interest for months in securing low-cost wind energy, the Hannibal Board of Public Works Board took the next step Wednesday by approving a draft power purchase agreement to get wind energy from an an as of yet unapproved transmission line.

"The word tentative is not in the agreement. This is a real commitment to us. That's how we intend to pursue it," he said. "But we all realize that things can happen yet through rulings or studies where we might find a show-stopper type of condition. We reserve the right to go back and re-think (the situation). If nothing changes of any significance they would expect us to sign this deal and live by it."

The HBPW Board was asked to sign the draft agreement as a show of support for both the Missouri Joint Municipal Electric Utility Commission (MJMEUC) and Clean Line Energy as they prepare their testimony to the Missouri Public Service Commission seeking approval to construct the Grain Belt Express transmission line from wind farms in western Kansas, across Missouri, to the Hannibal area.

Among the blanks on the contract is the price Hannibal will be paying for the wind-generated power.

"The initial price for the energy and transmission service is still confidential. Those prices will be revealed to the public during Public Service Commission testimony. We are satisfied they are going to be in the $21 a megawatt (MW) range when they are finally revealed, or less," said Stevenson.

Stevenson did acknowledge there is one "point of risk for the city."

"In the event that the transmission line is completed and the wind generators are for some reason late and can't deliver energy, this contract obliges us to start paying for the transmission service anyway," he said.

Stevenson is not losing sleep over that possibility.

"The odds of the particular generators that would be assigned to us being late are very low," he said.

A liquidated damages clause is written into the contract to pay those transmission charges should the wind generators be late.

In my opinion, this whole project is an attempt by a small group of investors to make a large amount of profit from the wind energy generation from Kansas. They have offered the proverbial 30 pieces of silver to local governments. Some have apparently taken it. I for one will not choose to do so. They promise Ralls County a whole million dollars (they must think this is 1960) to sell out our future. It is asking a lot of us to have our land taken by force to enable a few to get rich. I believe that other elected office holders should think beyond just today.

I think Mr. Tregengo’s assessment of the benefit to school districts and other county taxing jurisdictions is misleading because the facts are materially understated. 

I believe his overall discussion is short sighted because it does not address the tax revenues generated by the Project after it goes into service. Nor does it address the long term net tax benefits or losses. Therefore I regard most of his testimony as having little significance to an overall assessment of the longer term tax benefits to Missourians.

Basically, I believe that he spoke in generalizations which might leave the reader to see a much brighter prospect than actually exists for tax revenue benefits to Randolph and the other seven counties on the line. He omitted a discussion of which taxing jurisdictions receive little or no tax benefit.

Essentially, the value of a property is based on the perception of the buyer. Understanding that perception drives value is the foundation in analyzing the effect that electric transmission lines have on property value.

This perception does not have to be based on a scientific or engineering fact, it is based on what a buyer believes. An example of perception driving value based solely on belief is the haunted house. A home cannot be proven scientifically to be haunted. Yet, there are several homes throughout the nation thought to be “haunted” which stigmatizes the property resulting in a diminished selling price.

Just as in the last case, Grain Belt still has no memorandums of understanding with wind generators, and no firm commitments from any load serving utilities to buy capacity on the proposed transmission line.

Grain Belt fails to mention that MJMEUC may without penalty or cost elect to take no capacity over the new line, and that decision will be made sixty to ninety days before the line is then expected to enter service.

The TSA is nothing more than an option agreement.

In short, there currently is no commitment from MJMEUC to buy any capacity on the proposed transmission line.

The only support provided for the $10 million estimate from the MJMEUC was an eight-row spreadsheet in response to MLA’s Data Request MJM.13.

It is a flawed calculation of the cost of transmitting 100 MW and 200 MW of wind power from SPP to MISO. There is no calculation of, or comparison to, buying wind power over Grain Belt. The spreadsheet also contains an error in calculating the loss component of the costs. The total costs end up including addition of megawatt-hours and dollars which is flawed mathematics.

1. Mr. Lawlor asked how we felt about this move. We told him we would be thrilled not to have the line crossing our property, but that we did not want it moved to our neighbor’s property either. We couldn’t bring ourselves to benefit at the expense of our neighbors.
   
   
2. He said that the proposal to move the line seemed like a viable option, but that they expected something in return from us. My husband asked what he meant. Mr. Lawlor never did tell us exactly what they were expecting in return for moving the line off our property, but said it would be nice to have something from us.
   
3. We eventually told Mr. Lawlor that we could not agree to a move that would be detrimental to our neighbors, and that we would continue to oppose the Grain Belt Project. They thanked us for our time and left. That was the last we heard from Grain Belt about rerouting the line.
   

I will rebut Grain Belt witnesses James Arndt’s and Lanz testimonies regarding how the Grain Belt Express project could impact farming operations as well as discuss other issues regarding the negative impacts to farming and land as a result of large transmission projects like the Grain Belt project. Specifically, I will address the following negative impacts: Compaction of Soil; Erosion; Irrigation Equipment Interference; Difficulty in Aerial Applications to Crops and Pastures; Possible GPS Interference; Problems Maneuvering Large Farm Equipment around Towers; Precision Farming Problems; Concerns about Storm Recovery; and Eminent Domain.

Grain Belt Express Clean Line LLC’s supposed promises to sell power to Missouri municipalities should be recognized for what they are: a political stunt to create pressure for approval of this project by giving small benefits to local governments at the massive expense of landowners’ rights. Those municipalities in support will bear none of the burden from Grain Belt’s proposed project. It is instead Missouri’s rural landowners that will experience significant disruptions in their operations if Grain Belt Express Clean Line LLC is given the power to force land sales through eminent domain takings. This development does not change the underlying nature of the Grain Belt Express proposal. The project remains an attempt to engage in the abuse of eminent domain for private gain.

In summary, based on Staff’s review: 1) Grain Belt does not have the consent of the Caldwell county commission for its proposed transmission line to cross the public roads and highways in that county, the validity of its consent from the Monroe County Commission is being challenged in court, and, presently, the prefiled evidence does not include any such consents by the county commissions of Buchanan, Clinton, Caldwell, Carroll, Chariton, Randolph, Monroe and Ralls Counties; 2) There is not a clear need for the Project; 3) Grain Belt is qualified to construct, own, operate, control and manage the Project, but additional expertise will be needed once engineering and safety issues have been resolved; 4) Grain Belt has the financial ability to undertake the Project; 5) It is not clear whether the Project is economically feasible due to the lack of various RTO studies and the uncertainties surrounding the ATXI Mark Twain transmission line and its effects on the Missouri converter station and corresponding congestion; 6) A determination cannot be made at this time as to whether the Project is in the public interest since there is still uncertainty related to the economic feasibility and the safety of the Project.

It is expected that the MoPEP cities will save approximately $10 million annually by utilizing the Grain Belt Express and Infinity wind contract in their power supply after the IPM contact ends in 2021.

Clean Line’s owners are GridAmerica Holdings Inc., a subsidiary of National Grid USA (“National Grid”); Clean Line Investor Corp., a subsidiary of ZAM Ventures, L.P. (“ZAM Ventures”); Michael Zilkha; and Clean Line Investment LLC.

Clean Line Investment LLC is a vehicle for service providers and employees to invest in Clean Line, and is a small, minority shareholder in Clean Line.

Michael Skelly
Michael Zikha
Jayshree Desal    
James Glotfelty    
Mario Hurtado    
David Berry

While all these things seem kind of academic, it's pretty clear from Mario Hurtado's interview with NewsOK that the truthiness of this list isn't going to stop Clean Line from spinning it in a way they can use to preen (beg?) for financing and to pressure landowners.

"When the Trump campaign was looking at infrastructure, we thought it was a good thing to mention. We're just happy to be part of the conversation."

Like, when did you just happen to mention it? Did you run into them in the grocery store? How much did that conversation cost?