Category:

Well, Well, Look What Crawled Out of the Woodwork

8/23/2022

A report in RTO Insider says, "Skelly's Grid United Eyes HVDC Intertie in West Texas."

That's right... after his spectacular failure and wasting of $200M on his "Clean Line" projects, Skelly has crawled back out from under the baseboard where he fled to lick his wounds and dream some new impossible dreams to waste more investor money on new transmission projects that will likely never happen. What kind of a fool gives this guy more money? No, don't answer that. I know which fools, but not why they don't simply invest the money in lottery tickets instead. Probably better returns.

Anyhow, our pal Skelly has assembled a new "team" that looks surprisingly like his old "team" and has finally filed an application for his first Grid United project. Well, it's just an application to interconnect to the Texas grid and find such an interconnection necessary in the public interest for now. Skelly may come back later and ask for an order to construct and operate a transmission project. Gosh, this all sounds so incredibly familiar. Didn't Skelly ask the Illinois Commerce Commission for some sort of necessity finding prior to filing an application for the Rock Island Clean Line? His full name must be Michael Bifurcation Skelly. It's like inching into a room where you're not wanted. Bit by bit, and hoping nobody notices you slinking inside.

Skelly claims in his application to the Texas PUC:

Grid United Texas was created as an electric corporation in 2021. Grid United Texas is
wholly owned by Grid United LLC (Grid United) with a mission to unite the U.S. electric grid by
building new long-distance, interregional transmission lines to ensure that Americans have access to low-cost power when and where it is needed.

We, as Americans, say "no thank you." Or maybe it's more like "no way, get outta town!"

So, where is Skelly brain fart 6.0 going to be located?

The Pecos West Intertie Project (Proposed Project) is a proposed 1,500 MW HVDC interconnection between ERCOT and the Western Electricity Coordinating Council (WECC). The Proposed Project is proposed with an HVDC converter station at the LCRA TSC Bakersfield Switching Station in Pecos County, Texas, and an HVDC converter station at an EPE Station in El Paso County, Texas. Grid United Texas has evaluated interconnection at EPE’s Caliente Station and Newman Station, but the EPE interconnection will be determined following further consultation with EPE and the U.S. Army regarding a potential crossing of Fort Bliss (for the Newman Station interconnection). An approximately 250 to 300 mile ±525 kilovolt (kV) overhead HVDC tie line (Tie Line) will connect the HVDC converter stations at each end of the Proposed Project.

Looks like Skelly has learned absolutely nothing at all from his first routing failure, and wants to add not crossing a military base to his resume.

Oh hey, would you look at that? Part of Skelly's old "team" ended up on the Public Utility Commission of Texas.

Revenge is a sweet, sweet dessert, isn't it, Jimmy? I certainly hope Jimmy isn't going to recuse himself from this case. After all, I like a good laugh now and again.

But wait... there's more... Grid United is also in the "initial planning phase" of a completely different project, the North Plains Connector, that plans to rip through some of the most beautiful scenery in this country in Montana and North Dakota. I was just there. Is nothing sacred?

And, say, remember when Skelly recently bought a parcel of land in Tennessee located adjacent to an electric substation?

Yup. He's crawling among us again. Where's my flyswatter?

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Grain Belt Express: Secrets Revealed!

7/31/2022

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Grain Belt Express filed a new application for its project to cross Illinois at the Illinois Commerce Commission this week. In that haystack of thousands of pages of legal dreck and testimony, I found several needles. I'm going to guess that Invenergy didn't expect anyone to find the needles... but here they are!

In 2020, the Missouri Landowners Alliance filed a complaint at the PSC claiming that Invenergy had changed the design and engineering of its project as announced in a press release. The press release claimed Grain Belt Express would increase the capacity of its interconnection in Missouri to 2500 MW. During the evidentiary hearing, counsel asked Invenergy witness Kris Zadlo some questions about its interconnection requests in Missouri. Invenergy's counsel objected to these questions, but the judge initially overruled. The witness gave evasive non-answers to the questions, and his counsel continued to object to any probing into Grain Belt's interconnection in Missouri. Eventually the judge capitulated and shut down this line of questioning. The complaint was eventually dismissed based, in part, on Zadlo's testimony that the project design had not changed and that Invenergy was pursuing the project as permitted. The permitted project contemplated a connection with the MISO system in Missouri at a point in Ralls County. Turns out that was not true at all at the time Zadlo testified.

Invenergy recently re-announced its offering of 2500 MW in Missouri. Grain Belt's ICC application demonstrates that Zadlo was prevaricating. In testimony, Invenergy witness Carlos Rodriguez stated

One 1018 MW interconnection request (queue number GI-083) was submitted to AECI (Associated Electric) in June 2019, with a point of interconnection to the McCredie 345 kV substation.

and

Four interconnection requests were submitted to MISO in April 2019. The point of interconnection for all four interconnection requests is breaking Ameren’s McCredie – Montgomery 345 kV line, approximately 0.5 miles East of AECI’s McCredie 345 kV
substation. Two of the interconnection requests (total 1,500 MW) are being processed per MISO’s Merchant HVDC Transmission Connection Procedures (“MHCP,” Attachment
GGG) and the two remaining are being processed per MISO’s Generator Interconnection Procedures (“GIP,” Attachment X).

So Invenergy changed its proposed interconnection points and sizes in 2019, although Zadlo testified at the PSC in 2021 that nothing had changed and Invenergy was still pursuing to interconnect 500MW in Ralls County.

So, what is Invenergy planning now?

The converter in Missouri is proposed to be interconnected with the MISO system along the Ameren 345 kV AC transmission line connecting the McCredie substation and the Montgomery substation. The proposed connection will be made via a single 345 kV circuit from the converter station to a nearby tap point along the Ameren 345 kV transmission line. The proposed converter will also interconnect with the AECI system at the McCredie 345 kV substation. The proposed connection will be made via a single 345 kV circuit from the converter station to AECI’s McCredie 345 kV substation.

It looks like MLA was on to something before the PSC shut it down during the evidentiary hearing. More importantly, MLA was RIGHT all along. Invenergy had begun making plans to change its interconnection size and location. I highly doubt the amazing Zaldo had no knowledge of this.

Also revealed in the new application is more information regarding Grain Belt's interconnections with SPP, MISO and PJM. Bottom line is that GBE has NO approved interconnections. The SPP one needs to be restudied because of the increased capacity, the MISO ones won't be finalized until sometime next year, and the PJM ones won't be finalized until at least 2025-2026.

Another tidbit Missourians may find interesting... GBE says it will use monopoles in Illinois unless the landowner agrees to lattice, or the lattice structures are needed to support a turn in the line or a long span, such as over a body of water. Missourians were also promised monopoles, but once approved and purchased by Invenergy, GBE announced that all structures will be lattice.

Invenergy also revealed that it has a slightly different plan for use of the line. The public service commissions of Kansas, Missouri and Indiana permitted the project on the condition that no costs would be involuntarily allocated to the state's consumers. Word has it that Invenergy has been pursuing MISO to include GBE in its regional plan and that GBE claimed it was doing that so that it did not have to pay for system upgrades it caused and that they would be involuntarily allocated to all ratepayers in the MISO region. The plan to pay for the project that was permitted relied on federal Negotiated Rate Authority, where GBE negotiated voluntary contracts with customers to pay to use the line. In that scenario, GBE would sell its service to its voluntary customers. However, in its ICC application, GBE now claims it may sell or lease the project to others, instead of, or in addition to, selling service itself.

Subject to additional oversight and approval by the Federal Energy Regulatory Commission (“FERC”), Grain Belt Express may sell and/or lease an undivided interest in the project to potential buyers and/or lessees, and Grain Belt Express and those buyers/lessees may seek to provide transmission service over the line to eligible customers as defined by FERC on a non-discriminatory basis under a FERC-approved open access transmission tariff (“OATT”). Any co-owner or lessee of Grain Belt
Express that seeks to provide transmission service will be required to operate pursuant to an OATT on file with FERC that will meet the requirements of the Federal Power Act and FERC’s regulations. Grain Belt Express may also sell a cotenancy interest or lease a long-term leasehold interest in the transmission line, in which case it is not providing transmission service to such buyer/lessee because the buyer/lessee has control over that undivided interest.

Invenergy may just build the project and "flip" it to others, who may or may not be a public utility providing public use of the line for public benefit. Those entities would have to come up with their own rate scheme at FERC and find their own customers, and Invenergy would be off the hook to negotiate rates under its Negotiated Rate Authority.

Grain Belt Express has been granted negotiated rate authority from FERC, which
may be updated. Under this authority, Grain Belt Express is required to broadly solicit interest in taking service on the Project from potential customers and accordingly, will offer the opportunity to contract for firm and non-firm transmission service to eligible customers, and to provide transmission service over its available transmission capacity to all eligible customers on a not unduly discriminatory basis. Grain Belt Express will provide eligible customers with the opportunity to contract for transmission service where available transmission capacity exists on the line and cannot and will not unduly discriminate against any transmission customer in favor of another transmission customer. All eligible customers will have equal opportunity to obtain firm and non-firm transmission service through these means. If Grain Belt Express sells or leases one or more undivided interests to potential coowners/lessees, Grain Belt Express may be required to seek FERC approval of such a sale or lease if Grain Belt Express is a public utility subject to FERC jurisdiction at that time pursuant to Section 203 of the Federal Power Act. Furthermore, if any co-owner/lessee seeks to provide transmission service to eligible customers, such co-owner/lessee will be required to comply with FERC’s statutory and regulatory open access requirements and similarly be obligated to provide available
transmission service on its portion of the line on a not unduly discriminatory basis.

Oh, it may be updated? Or maybe not, and maybe Invenergy plans to chuck its Negotiated Rate Authority altogether. I wonder... is Invenergy's NRA even valid any longer, since they never notified FERC that the project was sold and a new entity is in charge? Why hasn't Invenergy broadly solicited interest in the project since it bought it?

Grain Belt Express expects that its co-owners, lessees and transmission customers will consist principally of (i) entities with wind and solar energy ownership interests located in southwestern Kansas and (ii) buyers of electricity—particularly buyers seeking to purchase electricity generated from renewable resources—located in MISO and PJM who take delivery at the respective delivery points. These buyers of electricity are expected to be principally participants in the wholesale markets (utilities, alternative retail electric suppliers (“ARES”), other competitive retail suppliers and brokers and marketers) but could include retail purchasers. The ultimate beneficiaries of the Project will be retail consumers of electricity in Illinois and other parts of PJM, MISO and adjacent markets who purchase and consume electricity from renewable resources that the Project delivers to the MISO and PJM delivery points.

It expects? So GBE doesn't have these customers now? I see. Still no customers. No customers, no revenue, no project. After all these years, Grain Belt Express still does not have enough customers to make construction of the line financially feasible. So how does it plan to generate revenue?

At this time, all of the costs associated with the development, construction and operation of the Project are expected to be recovered through a combination of sales/leases, as well
as FERC jurisdictional services including transmission service agreements with customers and other rates and charges pursuant to FERC approved tariffs and rate schedules. Grain Belt Express does not intend to seek to recover all of the costs of the Project by regional cost allocation to retail
customer load using the transmission cost allocation processes of PJM or MISO.”

So it plans to recover some of the costs by regional cost allocation to involuntary customers? Is this because there are no voluntary customers? Without customers, there can be no financing of the project.

The projected cost to construct the total Project and place it into operation is approximately $4.95 billion (not including network upgrades). Grain Belt Express has a viable plan for raising the capital necessary to finance the cost of constructing the Project on a project financing basis. Specifically, after advancing development and permitting activities to a status at which developers of wind and solar generation facilities and other potential customers of the transmission line are willing to enter into commercial agreements for an undivided interest (purchase or lease) or long-term contracts for transmission capacity on the Project, Grain Belt Express will enter into such contracts with interested subscribers that satisfy necessary
creditworthiness requirements. Grain Belt Express will then raise debt capital using the
aforementioned contracts as security for the debt. Grain Belt Express may also raise additional equity capital.

So, like I said... no customers, no financing, no project. Is this really a "viable" plan? Invenergy admits it cannot finance the project until it has customers. It currently does not have enough to pull this off. Coulda. Woulda. Shoulda.

It looks like GBE is just as far away from constructing this project as it has ever been. But yet it continues to tweak the project and condemn private property for a project that still has no customers or signed interconnection agreements. How many more "changes" and additions to this project will the public have to suffer before Invenergy comes up with a workable plan?

When will the PSC stop approving speculative transmission projects and visiting financial pain and uncertainty on the citizens of Missouri?

It's about time that Invenergy takes off its sheep costumer and reveals the wolf within, don't you think?

Still thousands of pages of haystack to paw through... what needle is going to fall out next?

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Hiding Information in Plain Sight

7/25/2022

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I've watched a lot of transmission projects come and go, but never have I seen a project that has been so hidden from public notice. Think about it: If the public never finds out about it, then they won't form opposition, hire lawyers, and intervene at the PSC. They also won't generate any negative media or political unpopularity. A transmission project hidden from public notice is traveling a stressful road richly studded with hidden landmines. In my opinion, it's a stupid idea headed for failure.

Grain Belt Express "Tiger Connector" transmission project was barely mentioned in Invenergy's press releases earlier this month. It was hidden in plain sight on the second page of the release, a place reporters rarely go, especially if the "important" talking points are bulleted for them on the first page. Local press didn't even mention it. No story, no public notice, no participation, no opposition.

When the project was announced, the few maps that circulated were vague dotted lines on a zoomed out map that only included major roadways. Transmission developers ALWAYS have detailed aerial photography maps available at Open House dog and pony shows, and increasingly these developers share their maps online well in advance of the "meetings". Seeing a detailed map of their property with a new transmission line drawn in is often the trigger point for landowners. But if Invenergy keeps these maps hidden until just two days before the Open House, then less landowners will have an opportunity to see them. Less notification, less participation at the Open House, less opposition.

And speaking of those Open House "meetings" they are always, and I do mean ALWAYS, the subject of a well-circulated press release for local media, along with paid advertising in print, radio, TV and internet. The idea of holding these meetings is to gather public input. But if the public doesn't know about these meetings because the transmission developer has not adequately advertised them with plenty of notice, then the public probably won't attend. No attendance, no maps, no participation, no opposition.

Invenergy mailed a letter to what it called "impacted landowners" notifying them of the Open House meetings just two weeks in advance. Actual delivery of the letters was well within that two-week window. And who is checking to make sure Invenergy's list of "impacted landowners" is accurate? Even the best transmission developers miss large numbers of "impacted landowners" at this stage, which is why they also buy advertisements and press reporters for news stories. They may actually want the public to find out and attend the "meetings." But if a landowner doesn't get a letter, or has a scheduling conflict, then they miss out. No notification, no attendance, no participation, no opposition.

Invenergy has performed a parody of "public notice" for its Tiger Connector transmission project by not using industry best practices for public notice and hiding "information" in plain sight in places landowners would never look.

The Public Service Commission should be very concerned about these shady practices. Your elected officials should also be concerned about it. Please let them know how disappointed you are in "public notice" shortcuts for this project.

You can submit an online comment to the PSC here. The case number is EA-2023-0017.

Invenergy has created a "virtual public meeting" on its website. According to earlier statements, it will only be available for a very short time. You can visit it here.

Be sure to check out the aerial photographic maps all the way at the bottom of the page. If you don't see them, or can't make them function (which has already been a complaint) you may need to change or update your internet browser. Don't give up! But, then again, if half the internet visitors can't access the maps because they are not designed to operate in a wide-variety of internet browsers, then less people see them (we're really developing a theme here!)

The rest of the page is what I call propaganda. Let's review.

"New power delivery" In fact, Invenergy claims 2 nuclear power plants worth. Reality: Grain Belt is a MERCHANT transmission project. That means that it will only deliver power to an entity that has signed a contract to pay to use the power line. Grain Belt cannot and will not just "deliver power" in general. "Existing customers" have contracted for just 10% of Grain Belt's capacity, although 20% of its new capacity has been offered for years with no takers. That's right, nobody has purchased 250 MW of service in Missouri that GBE has been offering for years. All the propaganda and marketing spiel in the world cannot make electric distributors in Missouri buy something they don't need. Missourians know the story about painting Tom Sawyer's fence very well. If nobody wants it now, it's probably not marketable.

"New local jobs, spending and tax revenue!" But selling 2 nuclear power plants worth of extra energy into Callaway County directly competes with the reliable sources of energy Callaway already relies on, such as Ameren's Callaway Energy Center. The nuclear power plant currently provides thousands of good paying jobs and millions of dollars in tax revenue and local community charities. Which would provide more? I think it is the Callaway Energy Center, hands down. Absolutely no contest. A bird in hand is worth more than the promise of two in the bush.

Invenergy's "experience." They say, "Invenergy knowns (sic) how to build the right way and has relationships with over 12,000 landowners, more than 80 percent of whom are farmers and ranchers." But reality is that nearly 100% of these "farmers and ranchers" signed voluntary agreements with the company because they were promised royalties or other payments that "share in the wealth" of Invenergy's land use. Transmission lines make a one-time "market value" payment for the perpetual use of your land. No matter how much money Invenergy makes from the transmission line, your compensation will not increase. Invenergy has recently begun condemning the land of folks who won't sign voluntarily.

The cheaper Grain Belt Express is to build, the bigger profit for Invenergy. GBE is approved to sell its service at market rates. The price GBE charges is set by market forces. It is not reliant on its cost to build and operate. While regulators can limit a jurisdictional utility's profit, the sky's the limit with Grain Belt Express! Nobody can hold their profit in check. And the cheaper the project is to build and operate, the more profit is in it for Invenergy! Perhaps that why, after promising single structure "monopoles" to landowners for a decade, Invenergy recently changed the structures after it purchased the bankrupt project from Clean Line Energy Partners. Invenergy says all transmission structures will now be cheaper 4-legged lattice construction. Promising monopoles seems to be a Grain Belt Express bait and switch.

All this same information will be decorating Grain Belt's venue tomorrow and Wednesday on strategically placed poster board easels manned by perky but clueless company representatives. But we all know that the only thing people come to see are the maps.

Make your plan to attend:

Audrain County
Tuesday, July 26
Knights of Columbus
9584 State Hwy 15, Mexico, MO
65265
Meeting 1
12:00 p.m. to 2:00p.m.
OR
Meeting 2
5:00p.m. to 7:00p.m.

Callaway County
Wednesday, July 27
John C Harris Community Center
350 Sycamore St, Fulton, MO
65251
Meeting 1
12:00 p.m. to 2:00p.m.
OR
Meeting 2
5:00 p.m. to 7:00 p.m.

Don't let Invenergy get away with preventing you from getting information about a project that could have devastating effects on your home, your business and your community!

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Missouri PSC Hits The Brakes On Invenergy's Rush To Site and Permit 40 Miles of New Transmission

7/14/2022

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Invenergy seems to have overestimated its power over Missouri in the wake of the complete capitulation of the legislature earlier this year. It seems like Invenergy thought it could do anything it liked to Missouri and nobody would say "boo."

What other explanation could there be for GBE's filing of a "Notice of Amendment" to amend its current GBE permit to:

Increase the capacity of the transmission line from 4,000 MW to 5,000 MW.
Increase the available capacity for delivery to Missouri from 500 MW to 2500 MW.
Relocation of the line’s mid-point converter station from Ralls County to Monroe County.
The addition of an approximately 40-mile transmission delivery line through parts of Monroe, Audrain and Callaway Counties.

Just minor technical changes? No these are material, major changes that landowner groups tried to warn the PSC were coming in a complaint case filed in 2020, which the Commission dismissed. In the meantime, GBE has been filing condemnation lawsuits to take property from private landowners to use for its for-profit project. All the while, it knew it was going to change the project and be subject to new approvals. What happens if the PSC does not approve all these changes? Will GBE have to give back the land it has condemned for its speculative project that has now been re-routed?

In addition, GBE contemplates taking 40 miles of new rights of way from previously unaffected landowners. And it plans to do that in a big ol' hurry, using its previously granted eminent domain authority to take land that was never contemplated to be taken when the PSC awarded it. The PSC must decide whether Invenergy's sudden "need" for this new transmission is in the public interest.

Since GBE's capacity increase announcement is nothing more than a marketing exercise to try to attract customers who have heretofore been uninterested in buying capacity, I can't find any public interest here. It's all private interest for Invenergy to use the people of Missouri as mere pawns in its attempt to make money building transmission that nobody wants.

Missouri law requires that the filing of utility applications be subject to a 60-day notice requirement. This means that the utility must file a notice that it intends to file at least 60 days prior to filing. Invenergy thinks it should receive a waiver of this requirement because,

Good cause exists for the waiver, if necessary, as notice was provided as soon as practical after finalization and the public announcement of the proposed modifications.

So Invenergy's media scheme is reason to ignore the law? And, after harassing Missouri for more than 10 years and not exercising its Missouri permit for a number of years, suddenly there's an emergency to get started as soon as possible without legally required public notice? This is a garbage excuse. The PSC did not grant any waiver, but told GBE to ask again in the correct docket.

The PSC slapped down Invenergy's silly Amendment yesterday and told them they needed to file a complete application to amend the permit in a new docket. This isn't going to be quick or easy for Invenergy, as it shouldn't. These are real people, real lives, real businesses that Invenergy is asking to toss under the bus because its plans for its SPECULATIVE transmission project have changed. That's nobody's fault but Invenergy's... and the MO PSC that thought it was a good idea to grant a permit and eminent domain authority to a merchant transmission project without a confirmed interconnection point, confirmed customers, confirmed financing, and a confirmed route. This new "Tiger Connection" did not need to happen if the PSC had required Grain Belt Express to come with a certain plan, not a speculative wish list.

Hopefully the PSC won't be fooled again. Who's to say that this "amendment" will be the last one? Until Invenergy has signed interconnection agreements and signed customers, it's all subject to "amendment." Landowners should not have to bear the brunt of corporate uncertainty. That's not in the public interest.

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Invenergy Manufactures News

7/13/2022

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The decline of journalism over the past 20 years or so would shock your grandfather, who lived in news' heyday. Investigative journalism is dead. Main stream media no longer reports the facts... it reports an agenda. Reporters are now less valued and more overworked than ever. Today's reporters have grown lazy about verifying facts and have become a staid, incurious bunch. They no longer want to tell both sides of the story. They simply repackage corporate and government press releases without verifying anything or providing any balance to the story. They are nothing more than media puppets. The bad news is that corporations can now pretty much write their own news, true or false. The other bad news is that you need to look elsewhere for the truth. There is no good news. Journalists say that the internet ruined the news industry, but perhaps the news industry ruined itself by losing its impartiality and accuracy to corporate overlords.

And Invenergy took full advantage of it on Monday, pumping out stories like this AP blurb that was sent around the country to use as filler. What does it say?

Grain Belt Express has been expanded so that it would "match" the power of 4 nuclear power plants.
Investment has increased to $7B.
Some municipalities intended to use the line for a "long" time.
There will be some magical amount of "savings."
Some advocacy groups love it.
"Some" farmers don't want the project.

Where's the mention of "Tiger Connector" which is a 40-mile transmission extension through virgin ground? There's "some" more farmers who are going to be furiously opposed to that. How did this happen? Invenergy's press release, news conference, and the fact that the average reporter had about 10 minutes to spend on this story combined to create a "story" full of non-news that buried the real news of an expansion of GBE's route and intent to use eminent domain in Missouri.

As you'll notice in the press release, the Tiger Connector is buried on page 2, past the bulleted list of important points. No reporter read that far. They stopped at the bulleted list because it was there that Invenergy had so conveniently summarized the important points. But those weren't the important points. They were just complete nonsense and fluff designed to bury the Tiger Connector story. And it worked. Thanks a lot, lazy reporters.

Also take a look at GBE's website. Where's the Tiger Connector? Oh, here it is, one page deep, where a curious reporter would never find it. And it's not part of the "Route" page where someone would look for the route of the project. It doesn't exist on the route. It has its own separate tab, which is unexplained, and the page contains nothing of any value to anyone. I've been doing transmission for nearly 15 years now and I've never seen a new transmission project rolled out with so little actual information. There aren't even any maps for residents of newly affected counties to see. It doesn't even mention where this project might want to go. It's almost like Invenergy is HIDING this new proposal.

Is Invenergy embarrassed that it has spent so much time and money on a route that isn't even viable for the project because it could not connect to the grid at any points even close to the route it has been buying and condemning for years? Is Invenergy embarrassed because it still doesn't have any customers aside from the loss-leader municipality contract for only "up to" 250 MW?

Nah, I think they did this on purpose as a ploy to keep this information from any landowners who could object to the plan and challenge it at the PSC. If there is no information about it in the news, nobody would know. If the information is hard to find on GBE's website, nobody will find it. If they do find it, there is no detail that might set an affected landowner off. If GBE doesn't mail notification letters to affected landowners until AFTER the news conference, and dangerously close to the "Open House" dog and pony show "meetings," nobody would know. We have yet to see one of these notifications show up, but they may be designed to look like a junk mail postcard you'd toss right into the trash without reading. If that happens, nobody would know. GBE didn't "announce" the details of its Open House meetings until AFTER the news conference, therefore the media would not publish that information and nobody would know about it.

Here's the information. Spread it around because GBE is hiding it and the media isn't interested in public notice.

Audrain County
Tuesday, July 26
Knights of Columbus
9584 State Hwy 15, Mexico, MO
65265
Meeting 1
12:00 p.m. to 2:00p.m.
OR
Meeting 2
5:00p.m. to 7:00p.m.

Callaway County
Wednesday, July 27
John C Harris Community Center
350 Sycamore St, Fulton, MO
65251
Meeting 1
12:00 p.m. to 2:00p.m.
OR
Meeting 2
5:00 p.m. to 7:00 p.m.

The public meetings will be open house format and attendees can come and go as they please during meeting hours. No formal presentation will be given. For those unable to attend in person, there is a self-paced Virtual Open House that is accessible on the website anytime between July 25 and August 5, 2022.

Got it? The information for landowners is only available for 12 days. If you miss that time frame, or the meetings (like say, you did something completely outrageous like GO ON VACATION in the middle of summer), then you're out of luck. You don't get any information. That's outrageous!

Ya know... real public notice that isn't actually trying to HIDE things is always sent to the media, who could help notify the public. What are you trying to pull Invenergy?

Invenergy says Tiger Connector is just a small change and the story is elsewhere. No sane person would believe that! Maybe opposition doesn't need GBE to help tell their story. Maybe Invenergy is about to get slammed. There's no way they're getting this through the PSC as a minor change that nobody minds. In fact, the Missouri PSC said it was not a "change" and that Grain Belt Express has to file a whole new application for these changes. Oops! Nice try, Invenergy, but did you actually think that was going to work?

Next, let's look at those manufactured talking points Invenergy fed to the press and analyze how useful they actually are, and whether they have a chance of biting back.

GBE will now be the equivalent of 4 new nuclear power plants. Sorry, but GBE does not generate energy. Maybe they meant that it could deliver the equivalent of 4 new nuclear power plants, if it actually had interconnection requests to inject that much power (but that's a different blog). But where would that power be generated? Not in Missouri. It would be generated elsewhere and imported. And if Missouri imported the power of 4 nukes located in Kansas, then an equivalent amount of Missouri generation would close, maybe even actual nuclear plants, like the Callaway Generating Station owned by Ameren that employs a lot of people and pays a lot of taxes in Callaway County. Ya know, maybe this wasn't really a smart talking point.

Investment increases to $7B. How in the world did GBE go from its historic $2B price tag under Clean Line Energy Partners to today's $7B price tag? Even with today's sky-high inflation, that's impossible. Even the cost of the Tiger Connector couldn't get this transmission project to $7B. Maybe there's more to this story than a transmission line.

What's that you say? $7B of new wind projects? So the investment isn't just a transmission line? What'cha building, Invenergy, and where's the check on your market power when you're "negotiating" with other wind developers to take service from the line? No chance that Invenergy could negotiate a better price with itself than it would negotiate with a competitor. No chance at all...

Invenergy trots out the same old, tired "customers" who got the deal of a lifetime to take service at below cost rates. I notice these customers didn't figure prominently in Invenergy's fluffy press release. Invenergy found some new friends to "cheer" for it. 2-4-6-8 What are we here to validate? Rah! Rah! Rah!

Magical savings. Because Invenergy hired some company to toss a word salad that concludes there will be all these magical savings that real people just can't figure out. It's all made up crap and they won't show you their math. You're supposed to trust the results. But without seeing the figures used to calculate these savings, it cannot be verified. They could have put anything in their equation (and maybe they did!). It's not just you... this savings report doesn't make sense to anyone I know.

Advocacy groups. I really don't think this needs an explanation. Gimme an S. Gimme an H. Gimme an I. Gimme an L. Gimme another L. What does that spell? Rah! Rah! Rah!

"Some farmers." How about "the vast majority of agricultural land owners along with their non-agricultural neighbors"? "Some" would more appropriately apply to the advocates, because they're so few in number. But, despite the backhanded attempt to minimize opposition, some farmers still managed to pollute Invenergy's dream story. That's the best a lazy press could do.

There were a few other giggles in the few stories that were original journalism. I particularly liked this blurb:

Utility regulators in Missouri and Kansas have already approved construction of the line. An Invenergy spokesperson didn’t immediately respond to an email asking if the expansion plans required additional approvals.

Not only does it require additional approvals. It requires a WHOLE NEW APPLICATION.

And then there's this:

“We heard that story over and over: ‘We want to see more of it brought to Missouri,’” said Shashank Sane, who leads Invenergy’s transmission business, after a Monday news conference in St. Louis. “It was really about bringing benefits to the state.”

Invenergy did not disclose which Missouri entities it expects will buy the additional power, but it is “confident that the customer base is there,” said Sane.

Right, mystery customers. The same ones that have failed to buy the 250 MW leftover from the last offering.

Invenergy carefully created a whole stack of hay to hide its "we need a new connection point" needle. But all that hay may end up being too hard to chew.

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Invenergy Releases Paper Tiger on Audrain and Callaway Counties Missouri

7/11/2022

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Winston Churchill once said, "Some people regard private enterprise as a predatory tiger to be shot." It's no surprise, then, that Invenergy named its Grain Belt Express add-on "Tiger Connector."

I've long written about the folly of buying easements and condemning private property for a speculative merchant transmission project, like GBE. Before a transmission project has customers and interconnections, its route is subject to change. The Missouri PSC made a terrible mistake when they approved a route for a speculative merchant transmission project without customers and awarded a private profit corporation eminent domain authority.

Public utilities use eminent domain sparingly, and only as a true last resort, when their route is set in stone and they are ready to begin construction. Public utilities normally condemn less than 5% of the easements needed for a project. But Grain Belt Express is not really a public utility. It's private money speculation. If they can build a transmission line between Point A and Point B using their own money, they bet that voluntary customers are going to find it so useful that they will contract to take service at negotiated rates. And Grain Belt Express began condemning land way before it had customers or an interconnection point in Missouri. GBE is now sort of obligated to the route it has spent all this money trying to purchase or condemn.

But, hey, guess what? Speculative projects often change plans. And now GBE actually wants to make its connection at a different point than originally planned. GBE now proposes connecting its project to the grid at a substation in McCredie, about 15 miles east of Columbia in Callaway County.

Here's a map of the new routes GBE wants to add to its land acquisition in Missouri:

Because GBE has begun assembling land on its original route, it doesn't want to actually re-route the project. No, it wants to ADD more transmission towers and wire to land that currently doesn't have that. Invenergy wants to add a "connector" spur to its project to connect from the original route in Monroe County to its new connection with the existing grid at McCredie. Instead of simply rerouting its project to McCredie and sparing Monroe County, Invenergy has come up with a cockamamie plan to build a DC-AC converter station in Monroe County, and then build a brand new 40-mile AC transmission line through Audrain and Callaway Counties to connect Grain Belt Express at McCredie. The project will also continue through Monroe County on its way toward Illinois, and eventually a connection with the Mid-Atlantic electric grid.

This is about the dumbest plan ever. GBE says it will pursue all required regulatory approvals for these "changes." These aren't "changes," this is a whole new project with a whole new route affecting a whole new area. GBE is trying to whip everyone along to comply with its "changes" before they think too hard about it. Public meetings for affected landowners and communities are in 2 weeks. Supposedly all landowners have been notified, but nobody seems to have actually been notified yet. GBE claims it will file this "change" at the PSC on August 1 and whip the Commissioners to approve it without thinking much.

What the..... This is insane! I could make a month of blogs out of what's wrong with this plan and all the requirements Invenergy seems to have skipped along the way. But, for now... HEADS UP, Missouri!

Invenergy has been so successful at buying and castrating state officials in Missouri that it's gone completely rogue. Are the steers finally going to step up and protect their people from the rich, urban liberals who are going to make a bundle plundering Missouri?

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How To Avoid Opposition To New Transmission Lines

7/3/2022

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I read a couple articles this week that demonstrate exactly how crucial host landowners and communities are to building the "clean energy" utopia. They can't do it without us, folks!

They say that recognizing your flaws is the first step in solving your problem, but I'm not so sure these folks get it yet. The solution is simple... don't cause impacts to land use and community values. If you don't cause impacts, nobody cares all that much, certainly not enough to invest years of valuable time, and years of personal savings, fighting transmission proposals. It's just that simple!!!

This vapid article on CNBC is not accurate. Here's just one snippet of its inaccuracy:

On June 16, FERC issued issued a first step — technically called a “notice of proposed rulemaking” — that it aims to amend laws making it easier to connect sources of electricity to the grid.

FERC doesn't make laws, nor amend them. It's an executive/administrative body. It carries out the laws enacted by Congress. Only a legislative body makes laws. Just how dumb is this reporter anyhow? FERC writes regulations, aka "rules, for how the laws Congress makes shall be carried out. The laws governing connection to the electric grid haven't changed. It's just that FERC wants to reimagine them to make them do something not written in statute. And maybe that's all you need to now about FERC's rulemaking... and this reporter's knowledge of the facts.

Another fallacy...

The most productive geographical regions for wind and solar are generally far away from urban centers where the energy is needed.

The article includes a map of wind energy potential in the U.S. The most productive places for wind are offshore, which is conveniently located near the most populated cities in the U.S. It doesn't even make sense. The reality is that the politically powerful people who live in those cities don't want wind energy infrastructure junking up their own back yard... the ultimate NIMBYs! They want to put it in rural America, far from their own home, so they can reap all the benefits without any of the impacts. The cities want to close all the "dirty" electric generators in their own back yard so that they can have a cleaner environment. They are poised to spend trillions doing so. If that's how they want to spend their money, have at it. But when someone from rural America objects to having new industrial energy facilities to serve the cities sited in their own community, they get villainized as hating "clean energy." They get accused of working for the Koch brothers, every armchair environmentalist's ultimate fossil fuel satan. And when rural communities ask to have new transmission connecting new generators to cities buried on existing rights of way, they get told that's "too expensive" or simply impossible.

There’s also the possibility of putting transmission lines underground, which, “is much more economic today than it used to be,” Gramlich said. But it’s still expensive, as much as ten-fold the cost, depending on the terrain you are trying to go through, according to Robb of NERC. In some cases, for example, putting a transmission line means blasting through granite. So, while “that’s a viable thing to do, it’s a very expensive thing to do,” according to Robb.

It's really not that expensive, especially when it is sited in existing rail or highway rights of way. Maybe double the cost, not ten times the cost. Buried HVDC only needs a narrow, shallow trench 5 feet deep. These guys need to break out of Thomas Edison's basement and read up on new technology... or better yet ask an engineer and quit trying to pretend they are experts.

So, the cost of cleaning up cities is not "too expensive" but the cost of avoiding impacts in rural communities is "too expensive." This is nothing more than a value judgement -- the cities are "worth it" but the rural areas are not.

What do any of these people (including the reporter) know about what motivates transmission opposition? Only Sandy Howard knows, and the reporter conveniently wrote little about why Howard has devoted many years of her life to stopping NECEC. Instead, the reporter focuses on the competing energy companies who poured money into stopping NECEC for their own reasons. The reporter tries to make you believe that transmission opponents are just figureheads doing the bidding of fossil fuel companies who want to stop new transmission. That's not true at all. In fact, in my 15 years doing this, I have not seen any energy interests get involved in a transmission battle, except that one. One instance does not make a trend. These people need to quit making excuses and stop underestimating grassroots opposition.

If they want to end opposition, they need to find out what's causing it, and there's no better way than to engage with transmission opponents. However, these self-congratulating chuckle heads prefer to insulate themselves and simply make crap up. Such as this lovely theater at a recent industry nerdfest:

Overcoming NIMBYism on TransmissionLast August, the Niskanen Center and the Clean Air Task Force released a report that called for adoption of the “5 P framework” to overcome opposition to clean energy infrastructure. The construct builds on the transmission concept of “planning, permitting and paying.”

“We propose adding ‘participation’ as a fourth ‘P’ and then ‘process’ as [the fifth]. Because one of the challenges of transmission [is that] every single project is unique, because every state in every region is different,” said Liza Reed, Niskanen’s electricity transmission research manager for climate policy. “The reason that we raise participation up to an equal level with the other Ps … is that groups are really siloed in each of those policies right now. There is stakeholder engagement in planning. There is stakeholder engagement in permitting. There is stakeholder engagement in paying. But different stakeholders get brought in at different points, and that’s when groups start getting frustrated. And I think when folks hear the word ‘participation,’ they think angry town halls and lawsuits. But the whole point of bringing participation into a consistent process is to avoid that.”
Lawrence Berkeley National Laboratory’s Joseph Rand offered an observation from his analyses on the siting and community impacts of large-scale wind and solar.
“What the wind energy developers have learned over time is that we need to move away from a process that people call ‘decide, announce, defend,’ [to one] called ‘consult, consider, modify, proceed,’ so that you’re meaningfully engaging local stakeholders in that process and being open to actually modifying your proposal,” said Rand, senior scientific engineering associate for the lab’s Electricity Markets and Policy Group.

...said the people who have never opposed transmission or been involved with any group that has. In fact, these people LOVE transmission. If they have a "plan" to end transmission opposition, it's probably not a very good one. They don't understand the problem they're trying to solve. These are the people who are trying to use transmission opponents as figureheads on their battering ram. Niskanen needs to quit trying to pretend it represents transmission opposition groups. It has nothing to do with any group. Niskanen can take its 5 P's and turn them into one U. Underground. Simplicity is key, not years of ineffective policy-jockeying and "participation" that does not actually include any of the affected landowners and communities. Shut up already, Niskanen. You don't speak for us. We're perfectly capable of speaking for ourselves. You're just incapable of listening.

And if you thought their ideas were bad, how about these from the CNBC article?

To spur grid expansion, the federal government should consider a tax credit for large scale transmission investment in current budget reconciliation policy discussions and the FERC proposed rule for expansion, he said.

But yet in the same article, another guy says, "It’s not because there aren’t investors ready to fund it." So it's not a problem of lack of investment -- but let's give billions of our tax dollars to transmission investors? Why? Because they want to fill their pockets? That's the only answer to this contradiction. Investment tax credits for transmission are nothing but a give away. They won't actually help transmission get built. They will just help a handful of people to get rich trying.

And then there's this:

Congress needs to act to give a federal agency, either the Department of Energy or the Federal Energy Regulatory Commission (FERC), authority to site transmission lines. “They could pass a statute that’s about one page long,” Pierce told CNBC in a phone conversation at the end of May. “This is not hard to accomplish if you’ve got the political will.”
Pierce knows that there will be opposition to such a federal authority, to which he says: Too bad.
“You cannot allow the citizens of a single state to block actions that are imperative for the welfare of the citizens that the whole country much less can you can you afford to allow the citizens of one little town or one landowner to,” Pierce said. “It’s just frustrating."

Perhaps Pierce should ponder how frustrating it is for a farmer to have a portion of his business confiscated to build transmission lines from which he would receive no benefit when that transmission line could just as easily be sited on an existing road or rail right of way. I'm pretty sure Pierce's "frustration" would pale in comparison. Giving more power to the federal government has NEVER solved a political uprising, instead it exacerbates it. Having federal authority to site gas pipelines certainly hasn't stopped grassroots opposition to them. Too bad for Pierce... it's never going to happen. The federal government only has power where states don't. And states have power over electric transmission siting and permitting.

Again... why do this when the real solution is so much simpler? Several contemporary examples prove that siting transmission underwater or on existing rail or road rights of way does not attract opposition. SOO Green Renewable Rail. Champlain Hudson Power Express. Lake Erie Connector. New England Clean Power Link. Vermont Green Line. Clean Path New York. Need I go on? These are the transmission projects that are sailing through siting and permitting because they don't require new rights of way and they don't impact host landowners or communities.

We've been beating this drum for several years now by sharing this idea any place we can. Maybe some of these morons are starting to catch on, but prefer to pretend it was their own idea?

Also, Gramlich sees a potential path forward in upgrading existing transmission lines. There, you don’t have the siting battles. “Reconstructing or replacing the old lines with new lines is a is a major opportunity,” he told CNBC. “There’s very little public opposition to transmission over existing corridors.

Ding! Ding! Ding! Ya think? However, this is from the same guy who thinks we need transmission investment tax credits. But, whatever. The basic kernel of an idea has managed to squeeze its way into Rob's brain after running into his wall of resistance to new ideas. Opposition doesn't form if you don't cause impacts.

Quit wasting time, energy, and money on stupid, ineffective ideas to quell opposition. The only way to avoid opposition is to bury new transmission on existing rights of way.

Now get crackin'. Time's a wasting.

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Clean Line Is Less Popular Than Gonorrhea -- And Other Not-So-Funny Jokes

6/28/2022

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According to this article, Arkansas PSC Chairman Ted Thomas said that he'd rather have gonorrhea than the Plains and Eastern Clean Line. Hardee-harr-harr.

Thomas said the failed 700-mile HVDC Clean Line transmission project from Oklahoma to Arkansas, which the U.S. Department of Energy agreed to support, “had higher negatives than gonorrhea.”

According to the same article, U.S. Department of Energy transmission facilitator Michelle Manary also thought making funny jokes about Plains & Eastern at some boring transmission "summit" was smart.

“We have battle scars from that,” joked Michelle L. Manary, acting deputy assistant secretary for DOE’s Energy Resilience Division.

Hardee-harr-harr, Michelle. You're a bigger comedian than Ted.

Poor widdle Michelle has battle scars from fighting all those nasty landowners and their lawyers and elected representatives. I'm so sad for her.

News flash for Michelle! The other side also has battle scars after being treated like dirt under Michelle's big government boot. They also have drained bank accounts, lost sleep, no free time, postponed plans for their properties, and a long period of their life filled with uncertainty and frustration.

And it all happened because the federal government acted politically to put its thumb on the scale for Clean Line. In the end, it was all just a gigantic waste of time and money.

Once bitten, twice shy, Michelle? What's she going to do with her new authority to act politically to put a thumb on the scale for merchant transmission?

To avoid that problem in the future, Manary said DOE will focus not on transmission corridors but on specific projects.

“It’s much easier to study a specific project,” she said. “And I think it’s easier also for the states and utilities to comment on it and coordinate and facilitate with it because they know what we’re talking about — not just a broad swath of land.”

But wasn't Plains & Eastern a specific transmission project? One less popular than gonorrhea? One that scarred everyone? I guess Michelle's scars aren't so bad after all.

Hardee-harr-harr. You two are about as funny as stepping in dog poo.

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Randolph County Commissioners Spill Truth About GBE

6/23/2022

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Here's a very well-written article about GBE's recent antics in Randolph County, Missouri. Leave it to the local media to actually tell a little truth!

The first truth is that the amendments to Missouri eminent domain law made by the legislature this session aren't applicable to Grain Belt Express. The legislature did NOTHING to protect these landowners. It just tossed them under the bus to slow it down a bit for the rest of the traffic.

Missouri House Bill 2005 has been heralded as a win for farmers facing eminent domain from transmission line companies, but it won’t protect Randolph County farmers from the Grain Belt Express, Randolph County Commissioners said Monday.

But Commissioners John Truesdell, John Hobbs and John Tracy said the bill won’t affect eminent domain proceedings brought by Invenergy Transmission for its Grain Belt Express, a new long-distance transmission line in the works for the past 10 years.

The new law will not help farmers keep their land. “Grain Belt is not affected by this,” said Hobbs. “I, myself, say it’s hogwash. It’s not protecting the farmers on Grain Belt. It’s protecting the farmers for anything after Grain Belt.”

And maybe not even as good as Grain Belt... since GBE's permit requires the company to give condemned easements back to the landowners after 5 years in the event it does not have financing, while the new "protective" legislation allows 7 years. Yeah, protect those landowners with new legislation!

The second truth is that merchant transmission owner Invenergy does not have enough customers for this project. No customers, no revenue, no financing, no project. (More on this in my next blog, you won't believe what's turned up!)

But Randolph County Commissioners say the company isn’t following normal procedure and has not contracted with local energy companies to provide energy at lower costs.

“You have to drop something of value in Missouri before you can do eminent domain,” Truesdell said. But the commissioners say they have yet to hear of any local utility company that has contracted with Grain Belt to move their product.

“I haven’t heard from the county coop that we’re going to get any energy,” Hobbs said.

There also aren't any local jobs or other benefits.

Ivenergy says Grain Belt Express will play a major role in economic recovery and growth in the Midwest by delivering thousands of jobs, billions of dollars in energy savings, and tens of millions of dollars for local communities and landowners.

Randolph County Commissioners say they haven’t seen any contracts or data that make them believe that.

The Commissioners also share about Invenergy beginning construction work without proof of financing, something its PSC permit prohibits.

The company also has to have a financial plan, which it doesn’t have, said Truesdell. “We have a lot of red flags in Randolph County.”
Though the company doesn’t have permission from Randolph County, it has started construction off Highway 3, Truesdell said. “It’s how they do business.”
Randolph County filed a moratorium to stop work until Grain Belt complies with all regulations, said Truesdell.
“They went in and did some dirt work,” said Hobbs. The landowners signed a contract with the company.

Invenergy is literally trying to bulldoze its way through Missouri, even though it cannot construct anything in Kansas or Illinois. What's the point? Who builds a transmission line that doesn't connect with anything on either end?

Maybe it's this kind of company...

“They didn’t act like any other utility company we’ve ever dealt with,” said Truesdell in May. The company struggles with communication; one hand doesn’t know what the other is doing, he said.
A little over two years ago, Grain Belt was supposed to come visit with the commissioners, said Truesdell. It never did. The company has to have approval from the county to begin construction, which it doesn’t have, he said.

It's all a very precarious house of cards.

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Grain Belt Express Seeks to Push Costs onto Kansas and Missouri

6/8/2022

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Remember the good old days when Clean Line Energy Partners promised the state regulatory commissions that it would not recover its costs from Kansans and Missourians? CLEP thought it was a negotiated rate merchant transmission project where only its voluntary, contracted customers would pay for the project.

Those days are over. New owner Invenergy has been begging the Federal Energy Regulatory Commission to create a new revenue stream for GBE from captive regional electric ratepayers. This means that electric customers that will receive no benefit from GBE would end up paying for a portion of it.

Why? Apparently Invenergy "needs" this additional revenue because it doesn't have anywhere near enough customers for GBE to support the financing of the project. Invenergy wants FERC to create new "products" that GBE can supply, such as "standby" emergency service to supply energy in an emergency. By "standby" they mean they need to be paid to stand by in case of emergency and promise to commandeer capacity from their paying customers to serve some future "emergency" that may or may not occur. GBE proposes:

...large, merchant interregional HVDC transmission lines that, although in non-emergencies are contractually dedicated to the interregional delivery of a pool of renewable resources to more distant loads, can nonetheless also be made available should explicitly designated contingencies arise such that the power from these different capacity sources can then be available to help mitigate the designated contingency -- even where such delivery could require the power to flow in the opposite direction from that called for in the usual schedules. For example, the GBX Line could have in place arrangements in advance that would allow any of the regional transmission systems to override its dispatch for a period of time so that the GBX Line could be dedicated to addressing contingencies when they arise. It will be important that these arrangements allow such transmission systems to relax the interconnection and/or
injection limits that may have been authorized for normal operations. For example, if the
prevailing dispatch would deliver Midwestern power to Eastern markets, there must be
arrangements in place to ensure that when necessary to schedule power in the opposite
direction, such Midwestern transmission system is not constrained from receiving such power based on interconnection or injection limits that might be in place during non-
contingencies.

In other words, GBE wants to sell capacity attached to a string so that it can pull back when it wants to.

Indeed, assuming the GBX Line was subscribed to its full capacity (approximately 4,000 MW), had only a fourth of its subscribers agreed in advance to be curtailed if required for certain emergencies, an additional 1,000 MW would have been available to the system operator to alleviate the shortages in local capacity resulting from the storm.

Gosh, I wonder who would reap the rewards of emergency use? Would it be the contracted customers, or would it be Invenergy? What customer would sign up to use this line with the knowledge that it can be shut off at any point in time? Grain Belt Express cannot be relied upon to meet customer energy needs. What happens if two "emergencies" (or just one wide-spread one) occur at the same time? Who has priority over capacity? Which emergency is more severe? Which one pays the most to Invenergy? Yup, this is all just crazy talk.

GBE also tells FERC that it needs these things:

Grain Belt Express requests that the Commission initiate a study to value the reliability benefits that interregional merchant transmission lines will provide and develop a template of the types of tariff-based arrangements that the Commission would accept. The Commission should direct regional markets to: (1) establish products or services to capture those reliability and resilience benefits; (2) develop specific methodologies to place a value on these services; (3) confirm that transmission systems will be allowed to relax interconnection and/or injection limits for deliveries from interregional merchant transmission lines during system emergency conditions; (4) direct system planners to account for and adequately value interregional merchant transmission in planning efforts; and (5) when accounting for interregional merchant transmission in planning, properly allocate network upgrades required to integrate and interconnect interregional HVDC lines, consistent with beneficiary pays cost allocation principles.

Translation:
1) Pay GBE for "reliability and resilience" benefits that it provides but that the paying ratepayers don't actually need (because if they were needed, the regional planners would order the upgrades and the costs would be paid by everyone in the region). GBE proposes that all ratepayers in up to three planning regions (SPP, MISO and PJM) that span 2/3 of the continental U.S. pay these charges although they aren't GBE customers and don't get any benefit from the project.
2) Find a way to create a regional rate scheme for GBE.
3) Allow GBE to take over control of the grid when there's an emergency in order to inject more power. Safety limits be damned.
4) Include GBE in regional transmission plans, even though the regional planning authority doesn't find a need for the project. If they can shoehorn it in the plan, next they'll claim regional ratepayers have to pay for it, too.
5) Don't make GBE pay to interconnect its project to the transmission system. Instead, make captive regional electric consumers foot the bill for GBE's connections. When a new generator or merchant transmission line wants to connect to the existing grid, studies must be done to ensure that the new connection won't overload the grid and cause outages. Any upgrades necessary to the grid to support the new connection become the financial responsibility of the interconnection customer (GBE). GBE wants to upset that now and make captive customers pay those upgrades, claiming they somehow get some "benefit" although they are not customers of the project.

The long and short of it is that GBE is trying to get captive electric consumers in Kansas and Missouri to pay for a portion of its merchant transmission project that will benefit voluntary customers in other states or regions. All promises to state utility commissions that GBE won't charge its project to in-state consumers are now void. But why should the consumers of Kansas and Missouri pay for an electric transmission line that does nothing but burden them?

But wait... there's more! In a different recent FERC comment, Invenergy shares the latest news on GBE:

"Many regions lack clear and consistent rules for the interconnection of transmission lines.
For instance, MISO currently allocates all transmission interconnection upgrade costs entirely to the customer, but may allocate a portion of those same upgrades to load if they were identified within the generator interconnection process, and some regions (i.e., SPP) have no applicable rules that govern injection from such lines. Grain Belt Express has experienced this first hand in developing an approximately 800-mile, 4,000 MW high voltage direct current transmission line that will interconnect in and carry power to and from the SPP, MISO and PJM regions. But its development is complicated by the lack of any consistent rules governing its interconnections in the different regions. And further complicating the process, MISO has refused to include Grain Belt Express’ interconnection positions as assumptions in the base case models and studies for its long-range transmission planning initiative (“LRTP”), which is intended to identify and address issues looking 10-20 years into the future. This refusal to account for the expected injections and withdrawals of an advanced-stage merchant transmission project not only complicates Grain Belt Express’ own development, it means that MISO’s LRTP results may themselves be flawed and inefficient.”

So while GBE is moseying around Kansas, Missouri and Illinois telling people it is "wrapping up" its pre-construction activities and needs to condemn and take private property in a big ol' hurry so it can get started, the truth is that Invenergy can't connect its project. Its development is "complicated" by interconnection requirements. It is literally a road to nowhere right now.

Have a good long look, everyone, at the stuff that Invenergy hoped you wouldn't see.

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Well, Well, Look What Crawled Out of the Woodwork

Grain Belt Express: Secrets Revealed!

Hiding Information in Plain Sight

Missouri PSC Hits The Brakes On Invenergy's Rush To Site and Permit 40 Miles of New Transmission

Invenergy Manufactures News

Invenergy Releases Paper Tiger on Audrain and Callaway Counties Missouri

How To Avoid Opposition To New Transmission Lines

Clean Line Is Less Popular Than Gonorrhea -- And Other Not-So-Funny Jokes

Randolph County Commissioners Spill Truth About GBE

Grain Belt Express Seeks to Push Costs onto Kansas and Missouri

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