Have you heard or seen one of FirstEnergy's vomitrocious "The Switch is On" ads recently?  I heard one on the radio the other night, although it could have been directed at other FirstEnergy distribution customers in surrounding states.

At any rate, FirstEnergy is launching its first major advertising campaign in 19 years!  And you're the beneficiary (also the financier -- every time you see or hear an ad, someone adds money to your electric bill, and maybe kills a puppy, but I'm not sure about that last part).

What's this campaign about?  It's about FirstEnergy's environmental stewardship.  FirstEnergy wants you to know what it has done to protect the environment:

Here's what FirstEnergy promises to do in the future, now that their switch is on:

That's it!  Now don't you feel much more educated about FirstEnergy's environmental stewardship than you did 10 minutes ago?  No?  Not much of a plan, is it?  It is worth the millions of dollars this campaign is costing you?  And why would you care about what's going on with FirstEnergy's Ohio rate case?  My radio gets some funky stations from time-to-time, but none from Ohio.  So I'll assume there are some other benefits West Virginians are getting for their advertising dollar.

Maybe this video of CEO Chatty Chuck Jones explaining his company's environmental stewardship will do it?

WAKE UP!!!

Did Chatty Chuck put you to sleep, too?  Sorry about that.  Engaging TV personality he's not.

Wait?  Did Chatty Chuck say, "We've supported energy efficiency throughout our 5-state region?"  What five states would those be... let's see... Ohio, New Jersey, Pennsylvania, Maryland and... not West Virginia?  He can't mean to include West Virginia in that, can he?

Why, just this morning I read an article about how FirstEnergy is blocking an important energy efficiency bill at the West Virginia Legislature!  SB 370 has been sent to "purgatory" in the Rules Committee because FirstEnergy has "come forward with a potential problem" with the bill.  In other words, FirstEnergy does not support energy efficiency in West Virginia.  The bill would "allow local governments to adopt energy efficiency partnerships with commercial building owners to help finance energy efficiency improvements on the property."  Isn't that energy efficiency, Chuck?  It doesn't sound like you're supporting it.  In fact, your corporate motormouth, Toad Meyers, says:

What is up with that?  What is up, Chuck?  (My lunch, after watching your video, but I digress).  You'd better grab Toad by his power cord and reprogram him, Chuck!  He's turning you into a liar!  Worse than that, Toad has managed to contradict himself in just a few short paragraphs.  After stating that "FirstEnergy already offers low-income customer and commercial lighting programs in West Virginia," Toad also says, "there has been significant pushback over the years from businesses and residents in states with mandatory programs who don’t like paying the costs every month to subsidize other customers’ appliance purchases and other rebates."  But isn't that exactly what the majority of West Virginia's ratepayers do?  Residential ratepayers pay monthly energy efficiency fees to support programs that are only available to low-income and commercial lighting programs!  Like, duh, Toad!

So, FirstEnergy is not supporting energy efficiency in West Virginia.  They're also belittling West Virginia's local governments, presuming them too stupid to govern anything to do with energy.  Because that's best handled by utilities (so they can make sure nothing a local government does harms their greedy bottom line).  Ain't that right, Chuck?

And what's that you say about being most proud about your employees?  I will agree that your front line employees are your ONLY redeeming asset.  But why is it that you want to harm them with "Right to Work" legislation, cutting benefits, and union-busting?  The way you treat your employees is shameful.  Proud my ass.  Just remember, without them, you are nothing.  When's the last time you hiked your bulk up a utility pole, Chuck?  I fear you're not contributing to keeping my lights on!

And how come there were no little video clips of your corporate employees, like Toad mouthing off to reporters and contradicting himself?  Aren't you proud of him, too?  I didn't see one corporate stuffed suit in that whole video, except for yours, Chuck.

Maybe it's because that snooze-fest was "Produced by the Communications and Marketing Department?"  While I'm thrilled you didn't waste any of my money hiring a real advertising firm to create an engaging and entertaining campaign, tell your Communications and Marketing Department not to quit their day jobs.  Even Charles Ryan could have done a better job than that.  Like maybe they could have given you a banana phone for a prop, Chuck, or perhaps even a clown hat?  Everybody loves a clown!  And wouldn't it have been fun to subject a cute puppy to your filthy environmental practices, and then show him still alive (but a bit dirty and singed around the edges) after 30 days?  Doesn't that just tug on the heart strings?

The switch is on.... but nobody's home!

Clean Line has been "developing" its numerous transmission projects for 7 years now.  Seven years!  And not one of the projects is approved and ready for prime time.

As a "merchant" transmission company, Clean Line has no captive customers from which to collect its costs.  Clean Line must shoulder all financial risk of its own projects.  Unlike other transmission projects ordered by regional planning authorities that collect their costs from regional ratepayers, Clean Line may only collect its costs from customers who sign contracts to use its project capacity through negotiated rates.  This means that even if Clean Line gets a project approved, it still must find customers to financially support its construction and operation.

Initially, Clean Line's business plan depended on big utilities to sign contracts to use its capacity.  In the past, Clean Line made much of a Memorandum of Understanding it signed with government power marketing authority Tennessee Valley Authority.  Clean Line liked to pretend this MOU meant TVA was a confirmed customer.  However, the MOU simply indicated that TVA might be interested in using the project in the future.  It was not a contract.  But it was an indication that Clean Line was depending on large utilities in "states farther east" to buy huge chunks, or the entire amount, of its capacity. 

Clean Line's initial efforts to secure customers focused on big utilities.

But when TVA studied the Clean Line proposal in its Integrated Resource Plan, it found it did not need Clean Line's transmission capacity to provide its customers with the most economic and reliable energy in the immediate future.  And Clean Line stopped talking about the TVA.  In addition, no other big eastern utilities signed up or showed much interest in the capacity Clean Line is selling.

Next, Clean Line advertised two of its projects in an "Open Season" in order to find potential customers with which to negotiate rates.  All interest in its projects came from wind generation companies in Midwestern states at the source ends of the lines.

Clean Line's secondary efforts to secure customers focused on wind generators.

But none of these wind generators had customers to buy the power they generated, therefore, they could not sign contracts for Clean Line capacity.  The wind generators were speculative -- as yet unbuilt -- and the generators need customers to raise money to build their projects.  However, no user utilities showed interest in buying generation from non-existent generators.  How do you price something like that?  How do you set delivery amounts and dates?  It's a fungible commodity.  Depending on generators to buy its capacity, Clean Line stands at one end of a string of dominoes that may or may not topple in line.  Too much uncertainty and too much risk for utilities, who can instead purchase a known quantity of renewable generation, at a set price, with a set delivery date, from an existing generator and shipped via existing transmission lines.  The price just isn't that good to take on Clean Line's kind of risk, if it's even possible to sign a contract to purchase energy from a non-existent generator delivered via a non-existent transmission line that may or may not ever be built.

Clean Line is not an energy generator.  It can't sell energy.  It is only the extension cord proposed to bring future generation to customers at a set price.  It's an extension cord that isn't plugged into anything.  Buying capacity on Clean Line commits utilities to purchasing energy from future generators in a set geographic area at an unknown price.  If the generators aren't built, or their generation costs are higher than anticipated, the purchaser of Clean Line capacity would be locked into purchasing energy at whatever price is offered by the generators.  The generators would have market power over the captive customers to charge whatever they want.  If a captive utility customer chooses not to buy energy after all, it's still on the hook to pay for the capacity on Clean Line's extension cord, whether it uses it or not.

So, we've yet to see any contracts for Clean Line's capacity from wind generators.

Clean Line's latest quest for customers focuses on municipal public power entities that provide power at cost to their own cities and towns.  These are much smaller chunks of each Clean Line's 3500 MW capacity, coming in at 25 or 50 MW each.  It's going to take a whole lot of municipal customers to make a Clean Line financially feasible.

But not only is Clean Line trying to sell municipalities on future energy prices it cannot guarantee, it's also "offering" the municipalities the "opportunity" to invest municipally-astounding sums of money into its project and take on the risk of losing the municipality's investment in the project in its entirety if the project is never built.  Clean Line's proposals are being reviewed by municipal power employees that may not understand its merchant transmission business model and wrongly believe their investment would be "guaranteed" to produce a return, or be refunded if the project goes belly up.  It just can't happen -- Clean Line has no customer base from which to produce a return on equity, and no bond in place to guarantee a refund of investment if the project doesn't pan out.  In addition, the municipal contracts must be approved by city council or other elected officials who have no knowledge base about electricity or power purchases.  Whatever Clean Line tells the city about its proposal could be bought hook, line and sinker, without independent expert review.

So far, Clean Line has convinced the City of Tallahassee to "buy up to 50 MW of wind power from its wind transmission project."  I highly doubt that.  The only thing Clean Line can sell is capacity on its proposed transmission line, not energy.  If the City of Tallahassee thinks it's bought a certain amount of wind power from Clean Line, delivered on a certain date at a certain price, it needs to think again.  Who knows what Tallahassee committed to do -- the actual agreement hasn't been published, and the press release was obviously less than honest.

Clean Line has also attempted to sell the City of Hannibal energy at a quoted price, or an investment in its project.  The City has tabled the issue for the time being, but municipal power employees vow to come back with the plan at a later date.

Word is that Clean Line is courting numerous municipal power agencies to sign up for similar deals.

What Clean Line is doing is essentially transferring its project risk onto the backs of struggling municipalities by signing them up for capacity commitments or "investments" in its projects.  If the project is never approved and built, the cities end up holding the bag.

Clean Line's whole business plan is based on transferring its corporate risk of project failure onto the backs of potential customers.  First, it was big utilities.  The utilities, no strangers to the power purchase game, did not become customers.  Next, it was future wind generators, who would, in theory, sign up to purchase capacity which they would wrap into their delivered price of energy.  That didn't pan out because the generators had no customers upon whom to transfer the risk.  Now it's municipalities, who struggle to find economic and reliable energy sources for their citizens.  If the big utilities and the energy generators didn't want to shoulder Clean Line's brand of risk, why would a municipality want to carry the company's water?  I think it's because they don't know any better.  And that makes me sad.

So, in Clean Line's honor, I'm going out this afternoon to give $20 to the first panhandler I see.  Maybe he'll offer to sell me some energy at a mind blowing price! 

Hannibal Board of Public Works General Manager Bob Stevenson says that he has "spent my career in coal-based energy plants and electric utility systems."  So, you'd think Bob would know the basics of how the electric grid operates, right?

Except Bob recently told a reporter for the Hannibal Courier Post that MISO, the Midcontinent Independent System Operator, would own a Clean Line substation once it was completed.

MISO does not own any transmission assets, including substations.  As an independent transmission system operator, MISO merely operates the transmission assets owned by utilities.  It cannot own any assets and maintain its independence. 

Here's a corporate overview of MISO.  MISO membership includes "52 Transmission Owners with $31.4 billion in transmission assets under MISO’s functional control."  That's right, the transmission assets MISO controls are owned by others.

Eastern grid manager PJM Interconnection is a little more blunt about who owns the transmission assets it controls: 

ISOs and RTOs are federally regulated regional grid managers.  The coordinate electricity flow, markets, and undertake planning to order utilities to build new transmission assets when needed.

Clean Line is not part of any ISO/RTO grid plan.  Instead of having its own plan vetted by the regional transmission organizations to determine if there was a need, Clean Line skipped that process.  Because Clean Line is operating outside the ISO/RTO planning process, it must shoulder all financial burden for its project.  There is no federal, or other, guarantee that the company may recover its costs from electric ratepayers.  Instead, Clean Line is taking a risk that its project will be found beneficial and useful by market participants who voluntarily negotiate a rate to use it.

When transmission projects are found needed and ordered by RTOs/ISOs, the costs of building the project are allocated to electric ratepayers in the region.  Because utilities are ordered to build these projects, they can be granted a special federal incentive that allows the company to collect its investment in the project from ratepayers, even if it is later abandoned and never built.  This is where the "guarantee" comes in.  Clean Line was not ordered by any RTO/ISO and therefore isn't even eligible to apply for this guarantee.

There is no guaranteed return on an investment in Clean Line.  Instead, an investment in Clean Line at this time would be incredibly risky.  Anyone who invests in a Clean Line-owned converter/substation would lose their entire investment if the project is not permitted and built and/or attracts no customers willing to pay to use it.  At this point in time, the Missouri Public Service Commission has denied Clean Line a permit to build the project.  It cannot proceed.  In addition, Clean Line has no customers signed up to pay to use the project.  Clean Line has nothing to back up any investment made by Hannibal or any other investor.  Clean Line will simply spend Hannibal's investment on whatever it wants to attempt to get its project permitted, built and attracting customers.  If that isn't successful, Hannibal loses its entire investment.

I'm not sure where Bob gets his idea that there is a guaranteed 10% return a year through MISO.  Perhaps Bob thinks that the standard 10% ROE for transmission owning MISO members who collect their regional rates through federal formula rates applies to Clean Line?  It doesn't.  Clean Line doesn't have a federal formula rate.  Instead, Clean Line has federal negotiated rate authority, whereby it may negotiate rates with potential customers in a non-discriminatory, just and reasonable fashion.  In order to succeed, the rates Clean Line negotiates with its customers must be high enough to recover its cost of service and return.  Because it is a market-based project, Clean Line will be able to collect any return the market supports.  Clean Line's return is not set or guaranteed by regulators.

If Bob is telling the Hannibal City Council that an investment in Grain Belt Express is guaranteed a 10% return, perhaps the City Council should ask Bob the following questions:

1.  Who is guaranteeing this return?
2.  How is the return collected?
3.  Who is the return collected from?
4.  Where is this guaranteed return set out in a regulatory order?

It's not.  Because Grain Belt Express has nothing to do with MISO regional rates and does not have a formula rate through which to collect its cost of service and return from regional ratepayers.

Whether Bob is getting his misinformation from Clean Line representatives (who should know better!) or making it up on his own, misinformation like this is not serving the people of Hannibal.  Instead, this inexpert review of Clean Line's offer to Hannibal could result in a $12.5 million dollar loss.  The City Council must have any Clean Line offer reviewed by independent experts, just like any other utility contract the city signs.  Failure to do so could be costly.

Let's review:

1.  Clean Line is responsible for all costs of its project.
2.  Clean Line currently has no rate structure.
3.  Clean Line  has no customers from which to collect rates.
4.  There is no guaranteed return for an investment in Clean Line.

Any investment in Clean Line would be based on speculation that the company could permit, finance, build and attract customers to pay for its project.  If those things don't happen, Clean Line, and any investment in the project, disappears forever.

It's great that Hannibal wants to buy more wind energy for its citizens.  But Clean Line is not the only option.  It's the most risky option.  Hannnibal could purchase wind energy risk-free through MISO's energy market, and have it delivered through MISO's existing or planned transmission system.  It doesn't take a gigantic, new, privately-owned transmission line to deliver wind to Hannibal.  There are better, much less risky, options for Hannibal to lower rates for its customers by buying renewable generation.  Perhaps Hannibal should issue a request for proposals to supply wind power, and examine all its options, before jumping on the first one-trick pony to ride through town?

The Hannibal Bureau of Public Works "stepped back" from Clean Line this week.  Can we get a Hallelujah, brothers and sisters?

The Herald-Whig reports:

Good idea, that research thing.  Clean Line's claims to the BPW haven't quite added up.  Although, I do think other municipalities should observe developments between Hannibal and Clean Line before moving forward themselves, instead of the other way around.  Looks like when push came to shove, there was no contract.  Why couldn't Clean Line put its offered prices in writing? 

In other news:

Well, lookie there, that's how energy contracts are supposed to be evaluated and signed.  Because, "an agreement that would commit the utility to do nothing except be a good witness in front of the Missouri Public Service Commission and be willing to work toward a final arrangement" isn't a bid, an expert evaluation of bids, or a contract.  It's nonsense, and it's selling Hannibal short.

Ahh, so maybe Bob has realized that Hannibal shouldn't be such a cheap date.  Hannibal has something Clean Line desperately wants, and they shouldn't give it away cheaply.

As well, the Missouri PSC and its experts thoroughly vetted Grain Belt Express before making its determination that the project did not benefit consumers last summer.  Hannibal should consider that carefully before making inexpert, snap judgements of its own on the merits of the project.  And so should any other municipalities being courted to "be a good witness" for Clean Line, before signing up.

If the project has merit, it will swim, not sink, on its own before the PSC.  And nobody needs another Prairie State.  Good job, Hannibal BPW!

Clean Line goes home with a big, fat goose egg, as my friend Dave in Arkansas opined.  But something wonderful happened in Hannibal nonetheless.  The Hannibal Ratepayers for Smart Energy grassroots group has formed, and will hopefully continue their efforts to become involved in Hannibal's energy choices going forward.  Public participation is always a good thing!

Nobody.

Not even the residents of those cities, apparently.

For the last 100 years, faraway cities have depended on the sacrifice of rural America to power their progress.  Appalachia has been plundered for its natural resources, and the people who live there have sacrificed their health and welfare to mine coal, burn coal, and ship the electricity it produced to faraway cities via gigantic electric transmission lines.  All the profits from doing so ended up in the pockets of mining and energy companies located in other faraway cities.  The people of Appalachia have been left with nothing.  And so it is that we stand poised to repeat the same mistake.

Faraway cities have developed a sense of entitlement.  Entitlement to cheap, plentiful energy without any of the nasty infrastructure that comes along with it.  And what's worse is that politically connected legislative and regulatory bodies continue to perpetuate the myth that faraway cities are entitled to continue to receive benefits without any skin in the game.

Bloomberg distributed an article recently that proclaimed the benefits of "Tapping the Power of the Great Plains to Light Up Faraway Cities."  But it forgot to chronicle the costs of its bright idea.  Tapping the power of the Great Plains causes sacrifice to those who live there.  Gigantic wind farms that cover the horizon as far as the eye can see, along with proposed new transmission lines, remove farmland from production.  They burden those who make their living off the land with increased production costs, decreased land value, and encumber their traditions and sense of place with industrial blight.  And Bloomberg didn't think balancing its article with the thoughts and opinions of those who must sacrifice for its great idea was relevant.

But it is.  Thousands of rural Americans across eight states* have joined forces to protest the approximately 3,000 miles of new "Clean Line" transmission touted by Bloomberg as a $9B "opportunity" for the transmission industry.  These transmission stakeholders don't want to sacrifice to light up faraway cities, and they will continue to oppose Clean Line's get rich quick transmission scheme and hold on to what is theirs.

Bloomberg says that transmission lines to ship energy from Great Plains wind farms to faraway cities are "missing."  That's just not true.  Regional grid operators plan and order necessary transmission for reliability, economic and public policy purposes.  An electric provider that wants to buy wind energy has numerous opportunities to do so.  What the regional grid operators don't do is build transmission lines for generators that don't exist and customers who have not expressed a need.  Enter, Clean Line.  Clean Line purports that if the company builds it, they will come.  And since Clean Line's fanciful notion is not backed by any demonstrated need, it is not included in any regional transmission plan.  Therefore, Clean Line must shoulder all financial risk of its own business plan.

Except it doesn't want to.  Clean Line wants to transfer its financial risk to rural landowners and public power providers like Hannibal, Missouri.  Clean Line wants states to grant it the power of eminent domain reserved for utilities building infrastructure planned to satisfy an electrical need within the state or region.  This is because landowners have resoundingly rejected Clean Line's purported "market leading compensation package" to secure easements.  Obviously, if Clean Line's compensation package was so wonderful, it wouldn't need eminent domain to secure easements.  Using eminent domain to secure easements from landowners who reject Clean Line's compensation package keeps Clean Line's land acquisition costs lower than they would be if the company had to negotiate with landowners in a free market.  In this way, Clean Line is foisting a portion of its financial risk onto landowners.

When the State of Arkansas rejected Clean Line's application for public utility status to acquire the power of eminent domain, Clean Line requested that the U.S. Department of Energy get involved to use its eminent domain authority to override the State of Arkansas and enable the taking of private property.  It's not about the federal government issuing a permit for a transmission project after determining a need for it, it's about the federal government overriding state authority in order to own and enable a speculative transmission project that will pay financial return to its super-rich, foreign investors.  This is picking winners and losers in the energy industry.  And it's not a done deal.

Bloomberg supposes that "these projects are seen as essential to helping states comply with President Barack Obama’s Clean Power Plan."  Seen by whom?  Clean Line is not part of any state's Clean Power Plan compliance.  Adding insult to injury, the Clean Power Plan itself has been stayed by SCOTUS pending judicial review.  This only adds an additional layer of uncertainty -- shall Clean Line be built as "essential" to a state's plan for compliance with a rule that could be vacated by the courts?  Should states, utilities, and regional transmission organizations continue to spend taxpayer and ratepayer funds on plans to comply with a rule that may later be invalidated?  That seemed to be the basis for SCOTUS's decision to issue the stay in the first place.  It's only a matter of time before the complaints about wasting money on compliance plans begins.  We can start with Kansas.

Not that anyone sees the fate of the CPP as changing the migration away from coal.  The CPP is but an unnecessary motivation to complete what market forces have already begun.  Cheap gas has gutted coal.  Do we really even need the Clean Power Plan anymore?  Maybe just to fuel statements that projects like Clean Line are seen as "necessary" for compliance.  And that's picking winners and losers in the energy biz, not any economic necessity for ratepayers.

The first step for the faraway cities is to take responsibility for their own needs.  If they need to light up their cities all night to bolster their own tourism and sense of place, they should look a little closer to home.  There is a vast, untapped renewable resource in their own backyard.  The elephant in the room is offshore wind and wave energy, something that gets forgotten in articles like Boomberg's.  The faraway cities are only falsely convincing themselves that rural America is eager to provide for their needs.  It's just not true, and the quicker faraway cities are to build their own clean energy infrastructure, the cheaper it will be, and the quicker they will get there.

*See Block RICL
Preservation of Rural Iowa Alliance
Block GBE-MO
Arkansas Citizens Against Clean Line Energy

Clean Line Energy Partners was back in Hannibal, Missouri, last week, where "Development Director" Mark Lawlor continued his desperate courtship of the Hannibal Board of Public Works.

The goal of the evening was an "agreement that would commit the BPW to nothing accept [sic] 'being a good witness' in front of the PSC and being willing to work toward a final arrangement."

This wasn't about cheaper energy for Hannibal, it was about Clean Line using Hannibal as a witness at the PSC.  What are the qualities of a "good" witness, I wonder?  Does a "good" witness represent the interests of the citizens of Hannibal, or does a "good" witness represent the interests of Clean Line?

Clean Line made several presentations to Hannibal.  One of the presentations cooked up by Clean Line was a table showing "wind options" for Hannibal.  The table compared 4 wind power purchase agreements with Clean Line's Grain Belt Express project and came to the conclusion that GBE was the cheapest "wind option" for Hannibal.  But, how does the information in this table compare with previous claims made by Clean Line?

The first project in the table is an "unnamed" Westar wind project located in Kansas, part of the Southwest Power Pool (SPP) transmission region.  The energy was priced at $22.70/MWh, but transmission costs to move it through the SPP region into the neighboring MidContinent Independent System Operator (MISO) transmission region to deliver it to Hannibal were pegged at $10/MWh, bringing the total cost of the Westar option in at $32.70/MWh.

The second option was Apex Clean Energy Ford Ridge project located in Illinois, part of the MISO transmission region.  Price for the generation was quoted around $40/MWh.  Because the wind project in Illinois and Hannibal are both located within the MISO region, the transmission cost is estimated at only $2-4/MWh, much less than paying transmission through two transmission regions.  This brought Apex's total in somewhere in the mid $40s/MWh.

The third option was EDF Red Pine located in Minnesota, also part of the MISO region.  The energy price was quoted in the mid $30s/MWh, with transmission costs at $4-6/MWh.  EDF's total was quoted at "High $30s/MWh."

The fourth option presented was an Iberdrola project located in Iowa, also in MISO.  The energy cost was quoted at $30-33/MWh, with transmission costs of $2-4/MWh.  When Clean Line added up this option, they used their highest estimates, instead of the lowest, or even splitting the difference with an average, to come up with a price in the "high $30s"/MWh.  However, using the lowest costs presented here, Iberdrola could come in at $32/MWh, not the $37/MWh quoted by Clean Line.

Apparently that high quote was necessary because Clean Line's estimate of its Grain Belt Express project came in at a remarkable $30-34/MWh.  Using the lowest Iberdrola figures would have made it competitive with Clean Line's quote.

Let's look at Clean Line's quote for using its Grain Belt Express as a wind option for Hannibal.  While the other 4 options were 20-year power purchase agreements with actual wind generators at a set price, Clean Line's option includes only the transmission price and locks Hannibal into a contract to purchase that amount of capacity for the life of the Grain Belt Express project.  A typical transmission line has a life of 40-50 years. 

Clean Line's presentation included a line about whether the quoted project is eligible for the federal production tax credit.  Clean Line claims its project is eligible for the credit.  That's just not true.  The production tax credit is available for generators, not transmission lines.  There is no guarantee that any future wind farms that may use the Grain Belt Express would be eligible for the credit.  While existing wind generators are most likely taking advantage of the $23.00/MWh credit, recent action by Congress to phase out the credit lowers it beginning in January, 2017:

It's doubtful that any wind farms will be built to provide energy for Grain Belt Express before the PTC starts being reduced.  The current $23.00/MWh credit is going to be cut by 60% before Clean Line's proposed in-service date of 2019.  Without the sweet taxpayer subsidy provided by the PTC, wind farm operators will have to add the additional subsidy cost onto their energy price.  Clean Line's quoted energy price doesn't reflect this reality.

And while Clean Line told Hannibal that it was not receiving any government subsidies, the quoted energy price included the production tax credit, which is a 10-year taxpayer-funded subsidy for wind generators.

The Grain Belt Express energy prices of $20-24/MWh quoted by Clean Line are in line with Westar's Kansas project, however Clean Line cannot guarantee or write a contract for those energy prices.  Clean Line can only sell transmission capacity, not energy.  Hannibal would be on its own to negotiate energy prices with any future wind farms that might connect with Clean Line's future Grain Belt project.  And Hannibal would be locked in to receiving its energy from Kansas via Grain Belt Express for 40-50 years, no matter what cheaper options may become available in the future.

Clean Line claims the transmission cost for Grain Belt Express will be approximately $10/MWh, bringing the total cost of the Grain Belt Express option in at $30-34/MWh.  Except that can't be right. 

In 2014, Lawlor told Midwest Energy News the price of energy delivered by Grain Belt Express was between $40 and $45/MWh.

(Editorial note: 1,000 kWh = 1 MWh, however I am presenting these quoted figures in MWh for uniformity).

And also in 2014 Grain Belt Express witness David Berry, Clean Line's Executive Vice President of Strategy and Finance, told the Missouri Public Service Commission in his sworn testimony that it would cost $15 to $20/MWh to transmit energy via Grain Belt Express.

In 2013, Clean Line told MISO that its transmission costs for the Clean Line projects were $20 to $25/MWh.

So what happens when we substitute these previously quoted transmission figures for the transmission figure in Clean Line's "Wind Options" chart?  Grain Belt Express' cost balloons to $45 to $49/MWh, the highest priced "Wind Option" on the chart! 

We all know that estimates can vary, but how is it that Clean Line's estimated transmission costs keep getting cheaper and cheaper over time?  It's still the same project.  It's still got the same price tag.  Clean Line is still promising to use the same "local" vendors to supply parts and labor.  Where is Clean Line planning to cut costs?

Clean Line's falling prices also overlook increased project costs over the years.  Time is money on a project like Clean Line.  As a start up with no functioning product, Clean Line has no revenue.  Early time estimates by Clean Line had the projects going on-line by now.  However, due to overwhelming opposition and permitting issues, Clean Line is years behind schedule in generating revenue.  Each year the company operates without revenue adds to the final cost of its product.  Each permitting hurdle costs more money.  Clean Line's first application for a permit in Missouri likely cost several million dollars.  A second application will double that cost.  Every penny that Clean Line spends on unforeseen development costs must get added to the ultimate cost of its product.  Clean Line's $10/MWh transmission cost could be completely cooked in order to make it appear that Grain Belt Express is the cheapest option for Hannibal.

And if Clean Line fudged its own numbers, how much liberty did it take with the numbers from the other projects it included in its "Wind Options" table?  The quoted prices from the other wind options have no validity unless quoted by the companies that own them.  Hopefully Hannibal will request proposals from all these companies before committing to "being a good witness" for Clean Line at the MO PSC.

Is this how Hannibal purchases the cheapest energy for its ratepayers?  By receiving quotes from one company that takes the liberty of quoting for other companies in order to make its own quote the cheapest?

Going back to the "Wind Options" table, take a look at the transmission prices across the board.  Clean Line's cost is one of the highest.  Why is that?  Because all the other transmission prices quoted use existing transmission that is paid for by all ratepayers in the region.  The MISO region includes 42 million ratepayers.  In contrast, Grain Belt Express will be paid for only by the users of this particular transmission line, a much, much smaller population.  Spreading costs over a larger population results in cheaper pricing.  Grain Belt's customer base is limited by the size of its project -- it can only sell a fixed amount of capacity.  Therefore, Grain Belt's costs can do nothing but go up.  Grain Belt's transmission cost is so high because it is user-financed by a smaller group of consumers.

Clean Line's "Wind Options" presentation begs the question:  Is Clean Line even needed?  Clean Line seemed to have no trouble presenting four other options for "cheap" wind energy for Hannibal to be delivered via existing transmission lines planned and operated by a regional transmission organization.  How can we believe that "cheap" wind can't be delivered without building an expensive Clean Line?  This presentation demonstrates that it can.

Regional transmission organizations exist to plan and manage electrical supply in their own regions.  Each transmission organization has a robust planning process that orders new transmission to be built when it's needed, whether for reliability, economic, or public policy purposes.  Clean Line is not part of this process, but is completely superfluous.  No transmission organization has ordered Clean Line to be built for any purpose.  Clean Line is simply a venture capitalist attempt to build an extraneous transmission line in order to make money moving power between regional transmission organizations.

Hannibal simply must do its due diligence before committing its ratepayers to 50 years of higher energy prices, or selling itself out as "a good witness" for billionaires hoping to increase their wealth building nonessential transmission lines.

Get excited, FirstEnergy ratepayers!  Your mega-conglomerate electric company is launching its first major advertising campaign in 19 years!  And YOU get to pay for it.

Yippee Skippy!

FirstEnergy wants you to believe that it is environmentally friendly because it has "invested" lots of money over the years trying to make its antique coal plants meet new environmental regulations.  What happens when FirstEnergy "invests" in plant upgrades?  You pay them back, plus interest!  The more FirstEnergy "invests," the more profit they make for their shareholders.  And it's not like FirstEnergy ever made these upgrades voluntarily, it was dragged, kicking and screaming all the way, by new regulations.  FirstEnergy does the bare minimum to comply, but that's often after spending money trying to influence or prevent the regulations in the first place.  And then they scheme up underhanded plots to prolong the lives of their dirty coal plants by "selling" them to regulated affiliates in West Virginia, or forcing Ohio ratepayers to enter into power purchase agreements with the plants at above-market prices.

The Ohio debacle has been going on for months and FirstEnergy's reputation is in the toilet.  Does FirstEnergy think that pretending to be environmentally responsible will somehow improve its chances of getting its coal plant bailout approved?  Highly unlikely, but it's going to cost ratepayers a mint.  FirstEnergy's uninspired dreck is reminiscent of its failed 2012 advertising battle with rival AEP.  It's too complicated and it's boring.

Like anyone is going to read their sustainability report? 

Or that anyone wants to listen to their CEO in a suit blather on making empty promises? Was that an attempt at plain folks propaganda?  If so, it fails miserably because that guy isn't presented as a "plain" folk.  It's a rich guy disconnected from reality that's just tooting his own horn.  Boring!

Their infographic is just a bunch of hot air.  "We're changing!" is but a glittering generality.  How is FirstEnergy changing?  Oh, they promise to reduce their environmental footprint by some unknown percentage, if only Ohio ratepayers prop their dirty coal plants up for a number of years.  Gosh, FirstEnergy, why not start your environmentally responsible game plan right now, close those old plants, and withdraw your request for a ratepayer bailout?  Nothing like a little deed to back up your promises, right?

And speaking of deeds, FirstEnergy is going to spend millions advertising its community largesse during the Super Bowl.  FirstEnergy donated 4 lights to a community project to make over a football field.  That's great!  FirstEnergy employees donated their time to install them (Did the company pay these employees for their donated time?  I doubt it!)  FirstEnergy's actual charity pales in comparison to the amount of money the company is spending crowing about its goodwill on television.  What if... FirstEnergy spent those millions in the community, instead of pissing them away on self-aggrandizing advertising?  How many football fields could be built with $5M?

How much is this new advertising presence intended to support and influence the regulatory process for FirstEnergy's Ohio coal bailout?  And how much is reimbursable "goodwill" advertising?

Compare FirstEnergy's weak advertising campaign with the one launched the other day by competitive Ohio generators pooling their resources as the Alliance for Energy Choice.  In their ads, plain folks are charged $20 for a cup of coffee and $58 for a pizza because the merchant is relying on old and inefficient equipment to deliver the product.  Take a note, FirstEnergy, these are the kinds of commercials to which regular folks pay attention and respond.  Nobody needs an infographic to understand them, nobody needs to read a dry, boring report to get the message, and nobody is wearing a suit and reciting a monologue.

FirstEnergy's advertising ideas as just as uninspired and uninteresting as they've ever been, however the price tag for them is bigger than ever.  What a bunch of dopes!

Hannibal Board of Public Works General Manager Bob Stevenson seemed quite eager to believe the unbelievable sales pitch of Clean Line Energy's salesmen last week.  Bob said his mind was "blown" by offered electricity prices of $.02 kWh. 

"Stevenson termed that power price as 'mind-blowing cheap'."

Since Bob's brains have now splattered everywhere, Hannibal needs to find itself some functioning minds so it doesn't repeat its power purchasing mistakes of the past.  Because when you contract in haste, you are bound to repent at leisure.

In 2007, Hannibal BPW entered into an agreement with the Missouri Joint Municipal Electric Utility Commission (MJMEUC) to purchase an ownership share in a coal-fired electric generating station in neighboring Illinois.  Hannibal's share was 20 megawatts.

At the time, then BPW General Manager Jack Herring seemed to also have blown his mind over the opportunities of Prairie State:

So, Hannibal issued bonds to pay for everything.  And signed a contract that ensured Hannibal "will not be contributing any funds to the project until it starts receiving power from Prairie State."  Hannibal's BPW Board said it had "bided its time" by considering the project over a period of 18 months, during which the project cleared what was described as "an assortment of legal hurdles."  Prairie State was supposed to generate power at 4.2 cents.

Except that's not what happened.  Prairie State was plagued with cost overruns and construction delays.  Even when it came online, it was often operating way below its full capacity.  In addition, power prices have fallen way below even those promised prices.  Meanwhile, Prairie State's costs have ballooned to as much as $.07573 in 2014.  And municipal utilities who signed up for Prairie State's mind blowing deal aren't so happy.

But has Hannibal learned anything from its Prairie State experience?  Do Bob's plans for that money include investing it in a speculative transmission line with no customers?

Beware unregulated companies pushing power purchase schemes, Hannibal!  As history demonstrated with Prairie State, you ratepayers need to look out for yourselves and can't trust your BPW to make smart power choices on your behalf.  And you can't afford another Prairie State!

Clean Line offered Hannibal electricity priced at $.02.  Except Clean Line isn't a generator, and owns no generation resources.  Clean Line can't offer Hannibal any electricity, at any price, because Hannibal could never contract with Clean Line to purchase electricity at a certain price.  The best Clean Line could offer is that Hannibal could sign a power purchase agreement with an un-built third-party generator in a far off place.  That hypothetical generator would set its own price and contract with places like Hannibal, independent of Clean Line's promises, in order to finance its own construction.  Except that's nowhere close to happening.  Fictional power purchase agreements at mind-blowing prices don't exist.

Clean Line offered Hannibal capacity on its proposed transmission line.  The transmission line isn't built yet either.  What good is capacity on a transmission line that doesn't exist to a generator that also doesn't exist?  Just like Prairie State, a purchase of transmission capacity is "take or pay."

Clean Line, a company who told federal regulators that it would shoulder all financial risk for its own project, is looking to sell and pass on its risk to municipal power companies in Missouri.  If munis in Missouri sign "take or pay" capacity contracts to guarantee Clean Line's financing, the munis will bear all the risk if Clean Line fails.

Clean Line has also offered Hannibal a $12.5M "investment" in its transmission project.  In exchange for $12.5M, Hannibal BPW could own a tiny portion of Clean Line's project, if it is ever built.

And that's just the problem.  By the time the Prairie State investments were made by Missouri municipalities, the project was approved and under construction.  Clean Line's project still faces several permitting hurdles, including approval by the Missouri PSC, who turned the project down once already last year.  The project is under appeal in Illinois, where state regulators made a grave legal error approving it.  There's no guarantee that Clean Line's project will be approved in a timely fashion, if at all.  Even if approved, Clean Line must still find financing to build the project before beginning.  Clean Line has no customers to use as collateral.  None.  Potential wind farms cannot sign contracts with Clean Line until they have their own financing guaranteed by signing contracts with buyers of their own.  No utilities want to engage in that kind of double-layered risk to sign "take or pay" contracts for generation and transmission that has yet to be approved or built.  Instead, Clean Line is sniffing around Missouri municipalities to scrounge up some cash so it may present the mutilated bodies of Missouri municipalities to the PSC during future permitting proceedings with the hope that the PSC will feel an obligation to bail out in-state municipalities who may go belly-up if their investment in Clean Line disappears.

When Clean Line runs out of money, it's done.  There is no chance it may recover the money it has already spent.  An investment in Clean Line is one that can be lost in its entirety.

Any municipality thinking about making a deal with Clean Line should only gamble with what they are comfortable losing.

Clean Line may end up being a bigger loser than Prairie State.

Well, bless their little hearts.  Some WV legislators still believe elections aren't controlled by corporate money.
As if WV's current governor-appointed PSC Commissioners aren't bad enough (completely clueless political favors or biased industry plants), a handful of legislators have set their sights on guaranteeing that future Commissioners are on the utility payroll.

A couple of bills intended to "fix" our awful public service Commission could end up making matters worse.

First up, HB2238 attempts to fix the PSC by geographically spreading out the commissioners to have one from each congressional district.  Whatever.  This one is harmless.

But HB2483 wants to elect commissioners.  And where do these legislators think PSC candidates will get their campaign money?

They will get it from the investor owned utilities they would "regulate" if elected.  And how do you suppose these "elected" commissioners would vote on proposals by their campaign funders?

In other states that elect PSC commissioners, the vast majority of PSC campaign money comes from the utilities the PSC regulates.

Alabama PSC funded by coal.
Georgia PSC funded by utilities.
Louisiana PSC funded by utilities.
Accusations of utility influence fly in Montana PSC race.
76% of Nebraska PSC campaign donations from utilities.
South Dakota PSC candidates accept unlimited donations from utilities they regulate.

Other problems:

PSC Commissioners moonlighting as industry lobbyists.
PSC Candidates funded by utility contractors when law prohibits direct utility contributions.
Candidates for New Mexico's Public Regulation Commission receive public funding for campaigns since 2003.
Oklahoma regulator accepts congressional campaign contributions from utilities she regulates.

And because PSC Commissioners would be elected from three different districts, that would remove the current requirement that at least one of them be an attorney.  It would also toss out the window the current requirement that only two of them can be from the same political party.

Considering a huge majority of the voters electing utility-financed PSC candidates have never heard of the PSC and have no idea what they do, is it a good idea to let these clowns elect commissioners based on TV ads or party affiliation?

As long as the governor appoints commissioners, we stand a chance of getting decent commissioners from a decent governor.  Once utilities can influence PSC elections, there is absolutely no chance of getting a decent commissioner.  None.

Kick this legislation to the curb.  Uninspired and thoughtless "fixes" may just cause further damage.

Samuel Clemens, better known as Mark Twain, grew up in Hannibal, Missouri.  He once said, "We have the best government that money can buy."

And it must have been in that spirit that "top brass" (subtract consonants at your own pleasure) from Texas-based Clean Line Energy Partners descended on Hannibal this week.

Insert carnival sideshow music here.

For a visual depiction of the action, go here to get your poster of Michael Skelly scowling in his Dad jeans, arms crossed in defiance.

Of course, nothing is written in stone, or legally binding.

What's the pitch?

So, Mark, Clean Line is selling power now?  And at two cents per kWh?  Where's your generator?  And how is that power going to get to Hannibal?  How much would that possibly cost?  FOB Kansas, right?

And how about that mind blowing opportunity to invest $12.5 million dollars in the Grain Belt Express project?  What's the guaranteed return on that?  And what happens if Grain Belt is never built?  The entire $12.5 million dollars of Hannibal's ratepayers hard earned cash disappears forever.  You'd think Hannibal has learned their lesson about investing in energy market revenue schemes, after their recent investment in Prairie State, right?

I can't imagine what the good citizens of Hannibal must be paying for power, what with all this energy market investment going on.  How much will rates go up to fund a $12.5M "investment" in Grain Belt Express for which the ratepayers may never see any benefit? 

And it wouldn't even supply half of Hannibal's energy needs, "The 25 megawatt chuck of power the city is interested in would represent approximately 40 percent of the city’s current needs."

What's a "chuck" of power?  Maybe it's this.

Is this deal really about cheaper power for Hannibal, or is it about:

Don't be a cheap date, Hannibal.  That "letter of participation" is worth a lot to Grain Belt Express.  Think of it as Clean Line's precious...

You could probably get Clean Line to pay YOU $12.5M for the letter, if you hold out for a better deal.  Now that's an energy market play with a real return!

But, will the Missouri Public Service Commission really be swayed by Clean Line investors and their non-binding "letters of participation?"  Probably not.  The MO PSC has already rejected this project once, and nothing has changed (except Clean Line's traveling carnival side show barker act at municipal power authorities across the state).  It would be foolish to underestimate the state-wide opposition to this project. 

Samuel Clemens had a lot of wise things to say.  He also said...

My money's on the Grain Belt Express opposition.