WECC-California is at risk of energy emergencies during periods of normal peak summer demand and high risk when above-normal demand is widespread in the west. Prior to summer, the planning reserve margin (which is based on existing and firm capacity) for the California-Mexico assessment area was below the 18.4% Reference Margin Level that WECC calculates is needed for maintaining loss-of-load risk below a 1-day-in-10-year benchmark (a 400 MW shortfall at peak demand). Probabilistic studies indicate 10,185 MWh of energy in the area is expected to go unserved this summer. Over 3 GW of additional resources are expected for this summer with most coming in the form of new solar photovoltaic (PV) generation. These generation plants can provide energy to support peak demand; however, solar PV output falls off rapidly in late afternoon while high demand often remains.

Imports to the area are needed to maintain reliability when demand peaks in the afternoon and to ramp up even further for several hours as internal resources draw down. California will have 675 MW of new battery energy storage systems on-line at the start of the summer that can continue to supply stored energy for periods when needed. Reliance on non-firm imports to cover high demand or low resource output conditions heightens the risk that operators will need to use energy emergency alerts (EEA)—and trigger the shedding of firm load in above-normal heat conditions—to maintain a stable BPS at times. Planned resource additions of 1,300 MW over the summer, including 825 MW of new battery storage, are expected to help mitigate late-summer risks.

Additionally, transmission networks can become stressed when events such as wildfires or wide-area heatwaves cause network congestion. The growing reliance on transfers within the Western Interconnection and falling resource capacity in many adjacent areas increases the risk that extreme events will lead to load interruption.

Operation of the BPS can be impacted in areas where wildfires are active as well as areas where there is heightened risk of wildfire ignition due to weather and ground conditions. Wildfire prevention planning in California and other areas include power shut-off programs in high fire-risk areas. When conditions warrant implementing these plans, power lines (including transmission-level lines) may be preemptively de-energized in high fire-risk areas to prevent wildfire ignitions.

Variable energy resources from wind and solar are critical to meeting peak electricity demand in ERCOT. Periods of low wind generation or higher-than expected thermal outages create a reliability risk during peak load hours. ERCOT appears to be in a weather cycle that may increase the risk of intensifying drought conditions and higher than normal summer temperatures. These weather factors could result in actual summer peak demand exceeding the forecast, which already anticipates record peak demand levels. Thermal outages may increase during severe and prolonged drought conditions due to cooling water supply and temperature issues.

Highest risk for unserved energy at peak demand hour, late afternoon (Risk can
extend for 1–2 hours after peak as solar PV output diminishes. Periods of low-wind, which usually occur 1–2 hours before peak demand, can also result in extended shortfall risk.)

The full report identifies the extent of the possible deficiencies, and Robb told reporters of his own concerns about how the energy transition might be impacting reliability.

"In our hurry to develop a cleaner resource base, reliability and energy adequacy have to be taken into consideration," he said.

The latest reliability assessment is "quite concerning," John Moura, NERC's director of reliability assessment and performance analysis, told reporters.

Summer 2020 and winter 2021 were "difficult to say the least," Moura said, and the latest assessment signals "similar risks" lie ahead.

In the long-term, system operators must do extensive analysis to ensure the addition of variable resources will not negatively impact reliability, he added. "As we look forward, it really just looks more stressful," Moura said, "because of the different resources coming onto the system."

Officials at PJM said they were also reviewing the PUC’s decision and that it “appreciates the commission’s consideration.”

“PJM will commence the appropriate planning studies to determine next steps, including identifying any potential reliability issues due to removal of the project from the Regional Transmission Expansion Plan,” the RTO said in a statement.

The OCA also noted that Transource’s assertions regarding “reliability” as a basis for need refer to a single generation deliverability test performed by PJM in 2018.  Further, the OCA noted PJM neither, performed its full suite of reliability tests to confirm that these reliability violations will result in 2023, nor, performed another generation deliverability test since 2018 which may confirm or refute the results of the 2018 test.  

In its Exception No. 8, Transource asserts that the ALJ’s recommendation to deny Project 9A is based on “faulty findings” without specifying any alleged factual or legal error.  In footnote to its Exception, Transource takes issue with certain specified findings by the ALJ and asserts, as a general matter, that all the ALJ’s findings of fact and conclusions of law should be disregarded to the extent the findings “are inconsistent with [Transource’s] Exceptions, Briefs and Testimony in this proceeding.”  Transource Exc. at 39, fn. 27 (emphasis added). 
 
We note that Transource’s Exception, as stated, fails to conform with Commission Regulations for stating exceptions, and lacks sufficient specificity to enable our review.  See 52 Pa. Code § 5.533 (pertaining to exceptions, requiring that the exceptions be stated with supporting reasons for each exception).  A general assertion that all the ALJ’s factual findings and legal conclusions should be disregarded to the extent they are “inconsistent” with a party’s filings does not state a supporting reason to disregard any of the findings and conclusions.  

... “need” from a PJM planning perspective may or may not be, as Transource asserts, “consistent with the standard for need under Pennsylvania law.”  It is for this Commission, not PJM, to decide whether the PJM planning perspective is, or is not, in line with the Pennsylvania standard for “need” under the Code, Commission Regulations and relevant caselaw.

Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it's the only thing that ever has.

Dominion Energy Virginia is seeking public feedback and advice about linking its planned wind farm, 27 miles off the Virginia Beach shore, to the 500 kilovolt backbone of its statewide power grid at the Fentress substation on Centerville Turnpike in Chesapeake.

Is there a "good" way to present a transmission line proposal to the public?  Not if you're approaching the communities with a fully-formed idea of what you're going to build and where you're going to put it.  The only good way to involve a community in a transmission proposal is to approach them with a need before making decisions about what to build and where.  Presenting a community with a problem to be solved and allowing meaningful input into the solution selected is the only way a transmission company can get community buy-in and support for the proposal.  Everything else is nothing more than a battle to push a bad idea the community doesn't want off onto someone else.

The power company has part of the route nailed down: the 27 miles of underwater cable to a landing point at the state military reservation at Camp Pendleton. It also has proposed an underground route through the southernmost reaches of Naval Air Station Oceana, to comply with regulations restricting structures near airfields, which the Navy must still review.

Its research into what’s on the ground, in terms of neighborhoods, wetlands, wildlife and historic resources has led it to six options for the final roughly 15 miles to the Fentress station.

“We can look at maps and desktop it, but it’s not until we talk to people that we’ll really understand these alternatives,” said Kevin Curtis, Dominion’s vice president, electric transmission.

One option for one of these routes would be to bury the lines for a stretch. That could create much more disruption during construction and mean they were costlier to install and repair than running lines overhead but would mean that portion of the lines would not be visible.

Five routes would run along the never-built Southeast Parkway, now an open space corridor through the most densely populated neighborhoods between Oceana and an area southwest of Princess Anne Road, between the Virginia Beach National Golf Course and the Princess Anne Athletic Complex.

My name is Michael Skelly and I am founder and CEO of Grid United, an early stage transmission development company. I have spent the last 25 years developing a wide variety of energy projects. I got involved in the US wind industry in the late 90’s, and helped put together thousands of megawatts of new wind projects. In 2009 I started a company called Clean Line Energy which focused on interstate power lines to move renewable energy around the country. We successfully permitted a three-state high voltage, direct current transmission line. We sold off our projects several years ago to other developers who are carrying them forward. Indeed, our Western Spirit project is now under construction in New Mexico.

A decade ago, we as a country did not have such a fantastic opportunity set in front of us. However, in the ensuing years, both utilities and independent developers have been sorting through the nettlesome siting, permitting, cost allocation and grid connection challenges.

Transmission plays a role in replacing the carbon and other pollution in these population centers with renewable sources of energy, thereby improving air quality for residents, and addressing long-standing environmental injustices.

While not a perfect policy tool, an Investment Tax Credit can make up for this deficiency in the planning process. The ITC would have the effect of lowering the denominator in the benefit to cost test. More lines would make it through the planning process, and we will end up with a lower carbon grid.

The other type of transmission lines that get built are called “merchant” lines. These are typically built outside the conventional planning process, and their economics rely on generators paying the developers of merchant lines to deliver their power across long distances to get to market. An ITC will help reduce the cost of the transmission service, and therefore more lines would get built, and more renewable energy projects will follow.

Among other indications that Grain Belt now intends to materially change the original project are these additional, unequivocal statements from their press release:
● “Invenergy Transmission, the owner and developer of the Grain Belt Express transmission line project (‘Grain Belt’) today announced plans to increase local clean energy access and accelerate billions of dollars in economic investment in Kansas and Missouri.” The statement does not say Respondents “might” or “are considering” those plans. It says they are hereby announcing them.

● “Economic recovery and long-term economic competitiveness in Kansas and Missouri depend on new investment, more jobs, and tapping into low-cost, homegrown clean energy, which Grain Belt is moving full speed ahead to deliver, said Kris Zadlo, SVP [with Invenergy] .... Grain Belt is proud to increase our investment in Kansas and Missouri to rebuild the economy, deliver billions of dollars in energy cost savings, and meet growing renewable energy demand.” (emphasis added). No ambiguities there.

● “As the new owner of Grain Belt, Invenergy Transmission plans to increase the project’s delivery capacity to Kansas and Missouri to up to 2,500 megawatts of the line’s 4,000 megawatt capacity .... Previously, 500 megawatts of the transmission line’s capacity was slated for delivery to Missouri.” (emphasis added). Again, Respondents’ plan to increase delivery of power to these two states was expressed in unequivocal terms.

● ”Grain Belt will provide critical power infrastructure to the region benefiting residents for decades to come.”

● Governor Laura Kelly of Kansas is quoted in the press release as stating that “[t]his impressive project is the latest example of Kansas’ place as a wind energy leader in our region and beyond.”

● According to the Kansas Secretary of Commerce, “the unwavering commitment from Governor Kelly to further support renewable sources is paying off in many ways, including this tremendous step forward in the Grain Belt Express.” He is further quoted as saying that the revised project “will deliver a significant economic boost to our rural communities in particular. The news couldn’t come at a better time.”

Clearly, these statements from the two Kansas officials would have been authorized for inclusion in the press release only if those individuals had been convinced that Respondents actually plan to move forward with the changes announced in the press release. Had Respondents told them that the revised plans were merely under consideration, the reaction from the Kansas officials would no doubt have been different from what they are quoted as saying in the press release.

● A representative of Renew Missouri is quoted in the press release as saying that “the benefits of Grain Belt have only grown with billions of dollars of added savings ....” Again, this statement is nonsensical unless the speaker had been led to believe that Respondents are committed to moving forward with the changes announced in the press release.

● Perhaps the clearest commitment by Respondents to materially change the original project is the following statement from the press release: “With increased delivery to Missouri ... Grain Belt will double its overall economic investment in Missouri to $1 billion .... Grain Belt will now make available as much as half or more of the project’s total capacity for Missourians.”

The importance of this statement lies in how this additional $500 million is to be spent on the project. As Mr. Zadlo acknowledged, the additional $500 million announced in the press release represents the added cost of increasing the capacity of the Missouri converter station by five-fold: from the original 500 MW to 2,500 MW.35 One could hardly argue that this change is not material.
And Respondents did not state that they were merely “considering” or “contemplating” the additional $500 million investment, which was earmarked for quintupling the size of the Missouri converter station. Instead, the press release states unequivocally that the new plans for the project “would” double the investment in Missouri to $1 billion.
In addition to the press release, in a letter sent from Respondents to landowners just this past December, Respondents included the following statements, again made unequivocally and with no hint that the plans announced therein were anything short of a firm commitment:

● “As you may be aware from recent news, Grain Belt Express has announced a proposed plan to increase the project’s delivery capacity for Kansas and Missouri consumers.”
● “Under this plan, up to 2,500 megawatts of Grain Belt’s 4,000-megawatt capacity would be delivered to Kansas and Missouri consumers .... This requires expanding the already-approved converter station in northeast Missouri.” Again, Respondents do not equivocate. The new plan “requires” the expansion of the Missouri converter station. As it turns out, it requires a five-fold increase in the size of that converter station. ● “Grain Belt Express will be seeking regulatory approval for this plan.” Again, this is a firm commitment to proceed with the project as modified by the announced changes. If Respondents had not already committed to making these changes, there would be no need to state that they “will be seeking regulatory approval” for the changes. This statement also recognizes that the changes being made are “material” enough to require Commission approval under the terms of the CCN decision.

● The letter also states that Respondents will be seeking approval to begin construction of the line prior to obtaining approval for the Illinois segment of the project. This statement confirms the description of the new project in the press release as constituting a “phased construction plan.”

And as counsel for Respondents conceded, “if phasing was to occur so that the Missouri and Kansas portion of the line was built before the Illinois and Indiana portion of the line, then we would likely consider that a material change and be before the Commission.” So the newly announced phasing plan definitely constitutes a material change to the project.

● A series of emails shown at Exhibit 6 indicate that a woman named Kimberly, acting on behalf of Grain Belt, was soliciting comments from the Governor of Kansas to be used in the August 25 press release. In an email of August 6, she informed a number of Kansas officials that “The project is moving into its next phase and the company plans to announce this development.” (emphasis added). She did not tell the Kansas officials that the project might be moving into a new phase. Instead, she unequivocally assured them that the project “is” moving into the next phase.
● Finally, in his response to Data Request No. 8, Mr. Zadlo simply answered “yes” to the following question:
Do Respondents presently plan to eventually seek regulatory approval from the Missouri Commission for the changes described in the press release attached as Exhibit 1 to the Complaint in this case, assuming no other significant changes are proposed to the project as originally approved?

This answer says, plainly and simply, that Respondents do in fact “presently” plan to seek Commission approval for the changes they announced in the press release. Mr. Zadlo did not say they might do so, or that they were considering that as an option. He said they will be seeking approval for those changes, which necessarily means they have already decided to make the revisions announced in the press release. It follows that Respondents have abandoned the project as approved in the CCN case.
The press release also mentions that Grain Belt will seek regulatory approvals “to the extent necessary” for the revised project. That of course is a given. Respondents have no choice but to seek regulatory approval for what amounts to a new transmission project. But that fact has no bearing on the question of whether they have already decided, as they have said, to move “full speed ahead” with the revised project. And again, the statement reinforces the fact that Respondents themselves consider the proposed changes to be “material” enough to require Commission approval.

In attempting to explain away their answer to Data Request No. 8, Respondents claim that the revisions announced in the press release are merely “contemplated changes.” But that explanation misses the point. As of today the specifics of the new plan may well be in the “contemplated” stage, with final details still to be determined.

However, that does not mean Respondents have not already committed to building the project in accordance with the announcements in the press release, as opposed to the project approved in the CCN case. In fact, they have as much as promised officials in Kansas that those changes will be forthcoming.
Perhaps at some point Respondents realized the potential consequences of their announced changes to the project. But taking them at their word up to that point, they have clearly stated they are already committed to making material changes to the project originally approved by the Commission. For Respondents to now dismiss the press release as nothing more than “a marketing exercise” simply demonstrates a complete lack of transparency and credibility.

The same holds true for their after-the-fact attempt to dismiss the press release as merely announcing the supposed benefits of the line and “an openness by Grain Belt to increase the converter station and dropoff in Missouri.” That document goes well beyond that characterization. In fact, the additional consumer benefits would materialize only if the chances announced in the press release were implemented.

The more credible statements from Respondents concerning this project are those made before the Complaint was filed here. Assuming Respondents were not deliberately misleading Missouri landowners, public officials, and the general public up to that point, those statements can only mean that they have already decided to materially alter the project approved by the Commission.
Based on the foregoing, the design and engineering of the project presently being pursued by Respondents is materially different from that approved in the CCN case.

No person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a Grand Jury, except in cases arising in the land or naval forces, or in the Militia, when in actual service in time of War or public danger; nor shall any person be subject for the same offence to be twice put in jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation.

Soon enough, eminent domain policies will have to evolve to align with renewable energy policies in order for a complete overhaul of the grid system to be attainable. State and federal lawmakers will eventually have to address the issue by having to revise the definition of “public use” to account for transmission lines transporting renewable electricity.

Financing large-scale, interregional transmission can be particularly challenging for merchant developers, said Shashank Sane, senior vice president and head of transmission at Invenergy.  “The beneficiaries of these projects can be diverse, and so in order to monetize the value of those lines, we have to find the stakeholder who is willing to pay for a certain benefit and create those links,” Sane said. “That’s really not the right model.”

For example, he said, Invenergy’s Grain Belt Express project now under development is aimed at bringing wind power from Kansas across Missouri, Illinois and ultimately to Indiana, providing a connection to MISO and PJM.

“The ITC is the key tool that will enable [the project] because it addresses the cost allocation problem and paying for those multiple benefits a single beneficiary is not willing to pay for,” Sane said.

The tax credit would stimulate both of the main types of transmission projects—regulated rate- based projects and “merchant” lines whose costs are recovered through negotiated or market- based capacity reservations. In the case of regulated lines, a utility or Regional Transmission Organization (RTO) would allocate the costs through a state or federal (FERC) regulatory process across a set of wholesale or retail customers. In that case, the tax credit would reduce the costs paid by those customers and make the cost allocation and approval process easier so more projects can move forward. In the latter case of merchant projects, the transmission capacity reservation costs that developers need to recover from wholesale customers would be reduced by the tax credit. This would allow the transmission developer to offer a more attractive price to customers, increasing the odds of success.

By reducing the cost of electricity, a transmission tax credit can significantly reduce the burden of electricity costs on lower-income Americans. Electricity costs are regressive in that they hit the lowest income Americans disproportionately hard. Electricity accounts for 3.7 percent of total household expenditures for lower-income Americans, versus only 1.4 percent for the highest-income Americans. This is because electricity is a necessity for many aspects of modern life, so the poorest Americans can only reduce their electricity consumption to a limited extent. Unlike other products, it is not possible to use a lower-cost substitute, as a kiloWatt-hour used by a lower-income family is the same and costs the same as one used by a higher-income family. In addition, lower-income Americans have less ability to invest in cost-saving energy efficiency upgrades. As a result, those in the highest 10 percent income bracket only spend twice as much on electricity as those in the lowest 10 percent bracket; for other goods, those in the top 10 percent spend nearly six times as much.In contrast, the federal taxes used to offset the cost of a transmission tax credit are much more progressive, with the top 10 percent of earners paying 60 percent of total federal taxes, and the bottom 30 percent paying negative tax rates due to policies like the earned income tax credit. As a result, a transmission tax credit that moves costs from utility bills to tax bills is very progressive.

Developers of the Grain Belt Express say the massive transmission line remains on track to open up by 2025, connecting wind power in western Kansas with voracious demand in the East.
The 800-mile project promises to add more reliability to the electric grid — all the more enticing since rolling blackouts in February left millions of Americans without power. While the $2 billion overhead transmission line aims at exporting wind energy from Kansas, it will also be capable of moving electricity both directions, which could have helped mitigate the electricity crisis that hit the United States earlier this year.

Zadlo understands the opposition to the project. But he said the benefits for people here and across the United States are immense. Just like railroad cars transport coal from mines to refineries, the Grain Belt will move a much-needed resource to customers, while also strengthening the electrical grid.

"Reliability benefits all people, right? Increasing the reliability of the grid is a good societal impact," he said. "Whether you're in the city or in rural areas, you will benefit from the increased reliability that Grain Belt will bring."