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DOE Releases Preliminary List of NIETCs

5/11/2024

This week, the U.S. Department of Energy released its list of preliminary NIETCs.

You can read their list here.

There is also a larger map of each preliminary NIETC, and DOE's initial reasoning for including it on the list.

There are 10 potential corridors across the nation ranging in size up to 100 miles wide and 780 miles long.

I'm just going to concentrate on a couple for this blog.

The Mid-Atlantic corridor. This corridor follows the path of the MidAtlantic Resiliency Link (MARL) project that PJM ordered to be built to act as a giant extension cord from West Virginia coal-fired power plants to Northern Virginia's data centers. But this corridor isn't just for that project... it also includes corridors for the other two large 500kV transmission lines that ship power to the east.

It's a virtual spiderweb of coal-fired extension cords to No. Va. Each corridor line on this map is 2 miles wide. TWO MILES! That means that anything within that 2-mile corridor would be turned into a sacrifice zone for new transmission lines.

Another is the Midwest Plains corridor. This NIETC is 5 miles wide and 780 miles long and roughly follows the proposed path of Grain Belt Express.

Since the purpose of an NIETC is to bump permitting to a federal level if a state denies a project, or to "unlock" government financing of a transmission project in a corridor, your guess is as good as mine why GBE applied for this corridor. Do they expect that the Illinois Appeals Court will remand their Illinois permit back to the ICC for denial? Or is this designation necessary to get government financing for GBE? If it's the latter, maybe that explains why GBE's Environmental Impact Statement already in process for its government guaranteed loan seems to have stalled out. A NIETC also requires a full environmental impact statement, and the NIETC corridor is much wider than what GBE originally proposed. Perhaps it has to be re-done.

The last corridor I'm going to focus on is the Delta Plains. This corridor begins in the Oklahoma panhandle and proceeds east across the state and on into Arkansas, where it forks north and south. This corridor is 4-18 miles wide and 645 miles long. It roughly follows the routes for the dearly departed Clean Line Plains and Eastern project and the WindCatcher project. Although both of these projects were cancelled long ago, it seems that someone wants to bring the zombies back.

These three corridors alone will impact millions of landowners. When you add in the other 7 corridors the amount of people impacted by DOE's corridors is astounding!

DOE has opened a 45-day comment period on these corridors before it will further narrow them down and select some or all of them to proceed to its next phase of the process. That phase will open environmental impact reviews, provide public notice, and issue a draft designation report that you can comment on. Of course, by the time these corridors get that far, DOE will have already made its decision. It is imperative that we all get involved and comment now.

I will be publishing more guidance for impacted landowners to help them make timely and effective comment, so stay tuned!

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FERC To Announce New Transmission Rules May 13

4/21/2024

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The Federal Energy Regulatory Commission (FERC) has announced an open meeting where it will present its new rules for transmission planning AND its new rules for transmission permitting in a National Interest Electric Transmission Corridor (NIETC).

Both of these rulemakings have taken years to get to this point. As you may know, rulemakings are public participation proceedings where the agency proposes a new rule, accepts comments from the public, and then issues a final rule. The transmission planning rulemaking began in 2019 -- 5 years ago! Five years to get a new rule in place isn't uncommon... things move at a glacial pace at FERC. In addition, FERC's commissioners have come and gone over that time period, making FERC flip-flop on several different new rule proposals. The transmission permitting rulemaking hasn't been in the works for as long, but it is going to have a profound impact on landowners so unlucky as to be targeted for new transmission projects.

First, the transmission planning rulemaking. This is all the media has been talking about. Fans of doubling or tripling transmission lines to ostensibly connect remote wind and solar generators are chomping at the bit, convinced that it will finally make intermittent renewables viable. That proposed rule contains, among other provisions, a plan to prospectively build new transmission to remote "zones" where some unnamed authority believes new wind and solar can be built. This would shift the cost of transmission to connect renewables from the owner of the generator to ratepayers across the regions connected. As it has been for years, the owner of a new generator must pay the costs of connecting its new generator. These companies want to shift this cost burden to ratepayers. If a generator has to pay for its own connection, it makes economic choices about where to site new generation in order to build at the most economic sites. If we're paying, generators can build stuff anywhere, even if it doesn't make economic sense, and stick electric consumers with the bill.

Another thing the transmission planning rule is going to do is create some hypothetical list of "benefits" from new transmission in order to spread the cost allocation as wide as possible. Even if you don't "need" transmission for reliability or economic reasons, if the transmission owner makes up some hypothetical "benefits" for you, then you're going to be charged for it. The idea is to spread the trillions of dollars needed for new transmission as wide as possible in the hope that if everyone pays a little that nobody will notice how their money is being wasted building transmission that they don't need.

Finally, the transmission rule will require planning authorities, like PJM or MISO, to plan transmission on a rolling 20-year timeline. What are you going to need 20 years from now? You have no idea, and neither does the planner. By planning so far into the future, the idea is to drive generation choices through transmission planning, and not to plan the transmission system based on need. It will also attempt to roll state and federal "public policies" into transmission planning so that we all pay a share of other state energy policy choices. Is Maryland shutting down all its gas-fired generation? You're going to pay for new transmission to replace it, even though you don't live in Maryland and had no say in the creation of their energy policies.

The transmission planning rule will be prospective only and will not affect any transmission already included in regional plans. After this rule is issued, planners will have to submit what are known as compliance filings, which detail how the planner will adjust its rules to carry out the new transmission planning process FERC orders. In addition, I fully expect that this rule will be litigated for several more years, which is going to hold the whole thing up.

Now onto the Transmission Permitting rule, which is something that is going to impact anyone currently battling unwanted transmission, and anyone doing so in the future. As you probably know, the U.S. Department of Energy is poised to release its preliminary list of potential NIETCs at any time. That's a whole battle unto itself that I'm not going to cover here, but if a corridor is designated in your area, it means that one or more proposed transmission projects may be built in that corridor. A transmission project sited in a NIETC is subject to "backstop" permitting by FERC. If a state has no authority to permit transmission, or denies a permit to a project in a NIETC, then it can be bumped to FERC for permitting. FERC will require the transmission company to file an application and then will hold a full-blown permitting process very similar to the state process. If FERC permits the project, then FERC has authority to say where it goes and to grant the utility building it federal eminent domain authority to take property for it.

In FERC's rulemaking on transmission permitting, it proposed that a utility could begin the FERC process as soon as an application is filed at the state level. This would mean that there will be TWO simultaneous permitting processes going on at the same time. Two permitting cases, two interventions, two sets of lawyers, double your time and double your money. The drawback here is that the FERC process may not even be necessary if the state approves the project in its own permitting process. If a state approves, FERC doesn't have jurisdiction to get involved. FERC said that it needed to speed up this process by running its own permitting process at the same time as the state process. It's foolish and a waste of our time and money. Let's see what FERC does with this as it was widely panned by those who commented on this rulemaking.

Another horrible idea in FERC's proposal is an "Applicant Code of Conduct" to meet the statutory requirement for "...good faith efforts to engage with landowners and other stakeholders early in the applicable permitting process." FERC proposes a voluntary, generalized, unenforceable "Code" that does little to protect landowners. The "Code" is merely an idea of how a company should behave, not how it will behave. FERC does not plan to enforce it, or intervene when landowners report violations. The landowner should report violations to the company! Don't laugh... they're serious! FERC's proposed "Code" advises that the company should "avoid" coercive tactics, but it doesn't prohibit them. That does NOTHING to meet the statutory requirement. It's a big joke!

The new transmission permitting rule will become operational once it is issued. Many readers will be subject to this government-sponsored landowner abuse immediately. This is one you should not ignore!

Over the years, I have worked with a large group of transmission opponents from across the country to file extensive comments on both of these rulemakings on behalf of impacted landowners. In particular, you should read our comments about the transmission permitting rule to familiarize yourself with what's about to happen to landowners.

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Please plan to (virtually) attend FERC's May 13 Open Meeting where they will release these two new rules and make comment and explanation. The meeting is "listen only". There is no opportunity to make comment or interact with the Commissioners. This is an informational presentation, not a participatory event. FERC's meeting begins at 11:00 a.m. and is expected to last about an hour. You can watch it live on YouTube using a link that will appear on FERC's website the week before. Later on that day (or the next day, remember FERC works at a snail's pace) the text of the rules will be released and then discussed over and over by lawyers and the media. If you're impacted by a new transmission proposal, you can't miss this presentation!

You don't need to sign up in advance... simply click the link to view when the meeting starts. You can find that link and minimal information about this special meeting at FERC's website.

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Washington Post Says The Quiet Part Outloud

4/20/2024

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Our power appetite is bigger than our power supply. The "renewable transition" isn't working. We are losing large baseload power generators and not replacing them and we're adding too much load. Our electric system is not sustainable. It's a simple math equation.

Back in January I was contacted by a reporter from the Washington Post who had been writing about the proliferation of data centers in Northern Virginia and wanted to investigate how Virginia's out-of-control building was impacting people in surrounding states. Virginia's data center problem is no longer just Virginia's problem. It has now spread to the entire 14 state PJM Interconnection region.

Here's his story that began back in January.

For us, the story began last summer when we found out about PJM's transmission plan for multiple new high-voltage transmission lines to import more power to data center alley. We followed it through PJM's planning process and though we protested and asked for other solutions, PJM approved three new 500kV transmission lines and a whole bunch of smaller segments and substations. During PJM's TEAC meetings, I remarked several times that the new transmission was feeding from existing legacy coal plants in West Virginia and was actually increasing emissions and in no way helping the "renewable transition." Every time I mentioned it, PJM was quick to claim that the new electric supply would come from "all resources, including renewables." PJM seemed rather sensitive about the reality of its plan and vehemently denied it. Deny this article, PJM. It's all there in living color.

Virginia has renewable energy laws that prohibit the building of new fossil fuel generation (gas, coal). But yet Virginia is building an incredible amount of new data centers that use outrageous amounts of power that is simply not available on the current system. Virginia's renewable energy plan is a virtue signaling lie. Instead of building the electric generation it needs, Virginia intends to IMPORT electricity from surrounding states, even coal-fired power from West Virginia. ESPECIALLY coal-fired power from West Virginia. How is Virginia's "renewable energy" law cleaning up the environment? It's not. It's making the situation worse.

After Tony started working on this story for the Washington Post, FirstEnergy made an announcement that bolstered what I had been saying... PJM's transmission plan is increasing the production of coal-fired electricity in West Virginia. FirstEnergy announced it was abandoning its goal to decrease its carbon emissions by 2030 by throttling back its Ft. Martin and Harrison coal-fired power plants near Morgantown. FirstEnergy said it was necessary to abandon that goal because those resources were necessary to provide reliability in PJM. In other words, FirstEnergy will throttle up its electricity production at those plants in order to provide supply to PJM's new transmission line that begins at the nearby 502 Junction substation and ends at No. Va.'s data center alley in Loudoun County. Ft. Martin and Harrison directly connect to 502 Junction via dedicated 500kV transmission lines. Also connecting directly to 502 Junction is the Longview coal-fired power plant in Morgantown and AEP's Mitchell coal-fired power plant in West Virginia's northern panhandle. It's more than 5,000 MW of hot and dirty coal-fired electricity and if the line is constructed it's heading right for Northern Virginia, along with some smog and air pollution. Data Centers are filthy! And PJM is a filthy liar.

Along the way to No. Va., PJM's new coal-by-wire extension cord will expand existing transmission rights-of-way closer to homes, schools, parks and businesses. Expanding existing easements makes it impossible for the utility to avoid sensitive things like they could if they were siting a new corridor. Anyone living along the existing corridor, like the Gee family, is going to be steamrolled right over.

The "using existing rights-of-way" propaganda is another huge PJM lie I brought up over and over during TEAC meetings. It's a new easement all the way because it cannot be constructed within the existing corridor.

And guess what? Along with new pollution and new land acquisition using eminent domain, West Virginians will PAY for this destruction/construction in higher electric bills, along with every other ratepayer in the PJM region.

And we get NOTHING for our trouble. Virginia gets new tax revenue building things they can't power while crowing about how "clean" Virginia is, and the rest of us get the impacts and the bill. We're NOT your sacrifice zone.

Washington Post reporter Tony Olivo did a fantastic job investigating and reporting on this story. He spent a day with us here in Jefferson County and drove from one end of the county to the other meeting people, and Washington Post photographer Sal got lots of photos and drone footage along the way. Then these two guys drove all the way out to 502 Junction and Morgantown to do the same there. They spent an enormous amount of time on this story and it shows.

One of my favorite images in the story is the new solar "farm" near Charles Town taken from the drone. It shows how the company building it scraped off all the vegetation and top soil and left nothing but bare earth and erosion that is killing the Shenandoah River. Clean energy ain't so clean, is it?

And let's talk about that "clean energy", shall we? Wind and solar cannot create the amount of electricity needed for new data centers, even if they cover Virginia with turbines and panels from end to end. The data centers need a plentiful and reliable supply they can only get from fossil fuels. A few solar panels on the roof of the data center won't do a thing to cure this problem. It may only keep the lights on in the restroom... during the day. Renewables cannot power our energy intensive society. We're not replacing the generation we're shutting down in the name of carbon reduction, and there's no chance that we can ever catch up at this point. Data centers are too big a drain and Virginia can't stop building them.

If you have any doubts, check out the Generation Fuel Mix pie chart on PJM's website at any time. Renewables provide only a tiny slice of PJM's power supply and it will never change as long as we keep increasing power load with new data centers.

Bravo to Washington Post for exposing Virginia's dirty data center reality!

And let's get to work, Jefferson County. We've got a power line to stop!

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What's an NIETC and what can I do?

4/7/2024

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The U.S. Department of Energy (DOE) is due to release its preliminary list of National Interest Electric Transmission Corridors (NIETC) that it is considering any day now. In order to understand what an NIETC is and how you can participate in the process of designation, let's take a look back at the history of NIETCs.

In the Energy Policy Act of 2005, Congress passed legislation to give the DOE authority to study electric transmission congestion and designate NIETCs that would give the Federal Energy Regulatory Commission (FERC) jurisdiction to site and permit an electric transmission line in the event that a state either did not have the authority to approve a transmission line or failed to act on an application for a transmission line for one year. This became known as "Backstop Permitting." States traditionally have authority and jurisdiction to regulate the siting and permitting of new transmission lines within their borders. This hasn't changed, but now there was a backstop measure to prevent a state from holding up a needed transmission project.

The legislation tasked FERC with developing rules for its backstop permitting process and FERC did so. FERC interpreted the statute to mean if a state denied an application for a transmission project then it bumped permitting to FERC. But that's not what the statute said! Piedmont Environmental Council and several states appealed FERC's rulemaking in the Fourth Circuit Court of Appeals. The Court found that state denial did not activate backstop permitting in PEC v. FERC. This allowed states to deny a permit to build transmission and end the matter.

Meanwhile, DOE had performed its congestion study and designated two huge corridors, one in the southwest, and one along the east coast stretching from New York to Virginia. The designation of those corridors was also appealed in the Ninth Circuit and the Court vacated the corridors due to DOE's failure to consult with states and its failure to perform an environmental assessment on the huge corridors it had designated. That decision is California Wilderness Coalition v. DOE.

These two court decisions made DOE's NIETC program effectively worthless and the entire thing was put on a shelf and forgotten about. But, in 2021, Congress passed the Infrastructure Investment and Jobs Act that contained a section that is meant to cure the problems with NIETCs, reviving the program. In addition to broadening the reasons for designating a corridor, the new statute allows FERC to site and permit a transmission project in an NIETC that is denied by a state. The law tells states -- either approve it or FERC will do it for you. It does not take the place of state permitting, the states still have authority to site and permit, as long as they don't say "no." Transmission projects cannot go directly to FERC without first applying at the state and going through the state permitting process.

DOE has been busy trying to revive its NIETC program ever since. In May of 2023, DOE issued a Notice of Intent and Request for Information proposing a new procedure for designating transmission corridors. DOE proposed that it accept applications from transmission builders to designate a NIETC that corresponded with transmission they wanted to build. That's not what the statute says... it says

Not less frequently than once every 3 years, the Secretary, after considering alternatives and recommendations from interested parties (including an opportunity for comment from affected States and Indian Tribes), shall issue a report, based on the study under paragraph (1) or other information relating to electric transmission capacity constraints and congestion, which may designate as a national interest electric transmission corridor any geographic area ...

It says DOE must study and designate corridors, not farm it out for suggestions from for-profit transmission builders to come up projects that provide profits. The DOE is supposed to be studying and designating corridors that accomplish the criteria in the study and benefit consumers. There can be a huge difference between a project proposed simply for profit and one that is actually needed by consumers. Designating corridors is supposed to be a government tool to incentivize the building of the right kind of beneficial projects. If DOE thinks (all by itself) that a project is needed, then it designates a corridor that will attract transmission builders to propose a new project in the corridor. Instead, DOE is, as I mentioned in my comments to the DOE, allowing the inmates to run the asylum. And I wasn't the only one, DOE received more than 100 comments on its proposal for designating NIETCs. Many commenters also thought allowing transmission builders to apply for NIETCs was a bad idea. Some thought DOE should perform a legal rulemaking to set parameters for its new program.

Meanwhile, DOE had been working on a National Transmission Needs Study required by the statute as the first step to designating NIETCs. That study was published in October 2023. The study found transmission congestion everywhere, meaning that NIETCs were needed everywhere. Many comments were also submitted panning that study. Mine are posted here.

In December 2023, DOE released a "Guidance" document on NIETCs, in lieu of the requested Rulemaking. The Guidance says that it changed DOE's approach to allowing transmission builders to apply for NIETC corridors. Instead, DOE opened a 60-day window for any person to submit a request for a corridor. Supposedly this cured the DOE's problem with allowing transmission builders to control the process. But it really doesn't. Who else would submit a request for a corridor but a transmission builder? It's a legal sleight of hand that is due a day of reckoning.

Many blog readers got involved in NIETC at this point and attended DOE's webinar explaining its process in early January. DOE was not really forthcoming about all the process that came before that webinar, but hopefully this blog will help you to understand that this didn't just drop out of the sky, but had been in process for more than a year.

DOE's 60-day window for submission of "information and recommendations" for corridors ended on February 2. Many thought this was the one and only comment period for NIETCs, but it was actually designed for transmission builders to submit requests for DOE to study corridors to correspond with the projects they want to build. After DOE's window closed, it began to take a preliminary look at the corridor recommendations it has received and promised to release a list of corridors it was considering within 60 days (which would be April 2). DOE hasn't released anything yet, we are still waiting.

However, NextEra notified Piedmont Environmental Council that it had applied for a corridor in Western Loudoun for its MARL project. I'm pretty sure that is not the extent of NextEra's corridor proposal... the corridor will cover the entire MARL transmission line, from 502 Junction substation in Pennsylvania to Data Center Alley. It makes no sense to request a corridor for only part of a transmission project. However, we will have to wait and see what DOE's list looks like before we proceed with our own response.

Our own response? Oh yes, anyone can make comment on DOE's list for 45-days after it is released due to the way DOE expanded who may submit "recommendations." I urge you to read DOE's Guidance, that separates the designation process into four phases. Phase 1 began in December, when anyone (like NextEra) could submit recommendations for corridors. Phase 2 begins when DOE releases its list of preliminary corridors to be studied. In the 45-day Phase 2 window, any person may submit information and recommendations. DOE is asking for specific information about each preliminary corridor. It seems to be intended for transmission builders who submitted recommendations for corridors in Phase 1 to supplement their applications, err... "recommendations." It does not seem to be intended for people concerned about the designation of an NIETC to submit their own information and recommendations, but we're going to crash this party and give DOE an earful about corridors that concern us. More information about how to participate will be forthcoming after I see DOE's list. After the 45-day Phase 2 process, DOE will decide which corridors will proceed to Phase 3. Phase 3 opens the federal environmental study process required by NEPA. DOE will also evaluate historical resources and endangered species. During Phase 3, DOE will create a draft designation report and open it to public comment. Phase 3 requires "robust" public engagement and notification. This is where DOE wants you to join its NIETC party and make comment, and comes very late in the process, after DOE has already made up its mind in the draft designation report. When all the studies and comment periods are complete, DOE will move onto Phase 4. Phase 4 publishes a completed environmental study and DOE's Record of Decision and final Designation Report. That's the end of the process.

However, a designation may be appealed, first through a Request for Rehearing at DOE, and afterwards through a formal appeal in the D.C. Circuit Court of Appeals (or other circuit where the transmission builder is headquartered).

Is it worth engaging in the NIETC process? Absolutely! Unfortunately it is just one more thing to deal with and will play out during the state permitting process for MARL. If you do nothing on NIETC, you risk all your hard work opposing MARL at your state utility commission being for naught. If your work in the state process causes the state to deny a permit, NIETC can bump it to FERC and start the permitting process all over again.

And speaking of FERC, it also needs to update its process for permitting transmission projects in a designated NIETC. Back in 2005, FERC engaged in a rulemaking for a permitting process. That rulemaking has to be updated for the new process. FERC opened a rulemaking proceeding for siting and permitting transmission in a NIETC back in 2022. The comment window closed way back in May of 2023. However, FERC has not yet issued an order or taken any further action. FERC cannot accept any applications for NIETC projects until it completes its rulemaking. A group of nationwide transmission opponents submitted timely comments on FERC's rulemaking. You can read their initial comments here, and their reply comments here. This group was the only one to speak up for impacted landowners at FERC. You can read other comments on the docket and monitor its progress by going to FERC's eLibrary and searching for Docket No. RM22-7.

As you can tell from the length of this blog post, NIETCs have been quietly in the works for a long time and there are a lot of moving parts. I know it's a lot to understand all at once, that's why I will be publishing some guidelines for landowners who want to kick NIETCs to the curb just as soon as DOE releases its Phase 2 list.

Stay tuned!

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DOE Pretends to Plan New Transmission

3/16/2024

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Our Big Green government is wasting our tax dollars on an effort to "plan" new transmission, although is has absolutely no authority to do so. The latest waste of money is entitled "Interregional Renewable Energy Zones" and is a partisan effort to create these "zones" in rural America and "suggest" new HVDC transmission to connect the "zones" to "load centers." Boiled down, it's an ineffective "plan" to turn rural areas into industrial scale power plants covered with wind turbines and solar panels and then ship all that green juice to the elite bastions of urban arrogance. Why? It's simple... they don't want any ugly, invasive power infrastructure sited in their own backyard, but they still want to pretend they are "clean and green" by turning us all into their personal energy serfs.

Nice try, but rural areas aren't that stupid. DOE has absolutely no authority whatsoever to plan renewable energy "zones" or new transmission lines. It seemed they thought they did last year, until they were challenged and came up empty handed. No authority. Not happening.

But they're not giving up. They continue to waste our money on idiotic "reports" that do absolutely nothing. This time, they claim that their work is "helpful" to states who may want to use this nonsense to plan for their own energy needs. Sorry... the states don't need your help anymore that the transmission planning authorities do. Nobody needs help from a bunch of babies that are too stupid and partisan to accept reality.

This study is a preliminary analysis to help state decision makers determine whether to pursue more detailed analyses of IREZ corridors that are relevant to them. This report could not fully account for all the case-specific details that would affect the configuration of a transmission project. Nevertheless, if a corridor examined in this study has a high benefit-to-cost ratio based only on energy cost savings, a follow-on study focusing on that corridor might expand the economic analysis to include local factors that we were not able to address here. A guiding premise behind the IREZ analysis is that states will ultimately take the lead in deciding whether to pursue IREZ development.

But that has approximately ZERO chance of happening. Even if one or two states used this dreck to ask their regional planning authorities to plan for zones and transmission, there are too many "fly over" states that are never going to agree to it.

What states are those? Take a look at the grandiose "plan." (larger image available at the "report" link)

The green dots are "zones" to be covered with wind turdbines and solar panels. The red dots are the places that want to pretend they are only using renewable energy. The lines are new HVDC transmission projects.

This study develops a model using renewable energy zones to address the new challenges of interregional transmission planning. An interregional renewable energy zone (IREZ) is an area comprising a very high concentration of very low-cost developable renewable energy potential. An IREZ hub is a collection point on the bulk power system to which renewable energy plants built in the IREZ can connect easily. The hub anchors an IREZ corridor that consists of a dedicated high-voltage transmission path from the IREZ hub to a major load center.

What were you smoking when you drew that?

We have identified and quantified several high-value IREZ corridors that affected states might consider for interregional transmission planning. Our analysis suggests that these corridors can be valuable tools for reducing carbon emissions in a manner that uses known technologies, has relatively small net impact on customers’ electricity bills, improves resource adequacy, and provides the grid with an additional measure of resilience against major disruptions related to climate change and other causes.

Affected states won't be "considering" that. It is quite insane and wasteful.

And let's talk about that "using known technologies" thing. The only "technology" NREL considered here was wind and solar. That's it. News flash! We absolutely, positively, undeniably cannot reliably power the United States with only wind and solar. Putting their intermittency and unreliability aside, they are just too expensive at this scale. There's nothing in this report that adds up the cost of all those renewables in the "zones" and the cost of all the new transmission. I don't think they can count that high. Here's an idea! Why don't you take all the money you were hoping to spend on this wasteful plan and use it to build clean, renewable nuclear generation at all the red dot load centers? None of this transmission would be necessary, and that's a huge savings. I'm sure it would be cheaper, but DOE didn't compare any other resource plans to this biased brain fart.

And, before I end, let's examine one of the huge errors DOE made purporting "benefits" for the states:

Benefits could include assumptions about local tax receipts and indirect economic development effects in the IREZ state, payments to landowners for the acquisition of right-of-way (ROW) along the transmission path, net savings in energy costs for customers at the receiving end of the corridor, and enhanced resilience against extreme weather events.

Sorry, but payments to landowners for land taken from them against their will is NOT a benefit. It is COMPENSATION for something taken from them. The idea of compensation is that the landowner remains whole after the taking, although you can't grow crops on piles of dirty money. It is not a windfall similar to winning the lottery. The landowner is supposed to use that money to purchase additional land, or to make up for the inability to use that land in the future. That is not a "benefit" by any stretch of the imagination.

DOE did a pretty poor job of trying to dredge up some reason why flyover states should willingly sacrifice themselves for the urban elite. It also completely overlooks that the "zones" may not want to be covered in wind turbines and solar panels and may outright refuse to sign leases or permit these projects to be built.

What a complete and utter waste of taxpayer money.

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Grain Belt's Not So Big News

2/23/2024

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Someone sent me this article earlier this week. It tries to pretend that Grain Belt Express has made some sort of regulatory or procedural progress... like it got things *approved*. But the reality is that the only things GBE recently got was a well-deserved kick in the behind from the Federal Energy Regulatory Commission and a big nothing from the U.S. Department of Energy. Big deal. Must have been a slow news day... or just one ripe for propaganda and fake news.

Let's go to the DOE thing first.

That's right... zero plus zero is still zero. GBE is still a big, fat zero. FAST-41 is supposed to be a government run program that "speeds up" the environmental review for selected projects. Except, the government getting involved has never sped up anything! Government slows everything because of its pendulous rules and process. GBE's Environmental Impact Statement has already been underway for more than a year, and it's already at least 6 months behind schedule. And there's no end in sight. How would anyone even know if FAST-41 speeds up the GBE EIS, since it's already behind the non-FAST schedule? This is just a waste of time and tax dollars, let's move on to FERC.

The article says

Grain Belt Express is also making procedural headway at the Federal Energy Regulatory Commission.

Say what? Did this silly reporter even READ the FERC Order he's reporting on? I'm thinking no, because no sane person would have read that Order and decided it was favorable to GBE. What GBE got from FERC was nothing but a scolding.

We've known for quite a while that GBE was going to connect to MISO and AECI in Callaway County at the existing McCreedie subtation and also at a new substation it is sharing with Ranger Power's immense solar farm. The new substation is called Burns. Burns will be owned and built by incumbent utility Ameren (however I hear that Ranger Power bought the land and scraped all the topsoil off it before handing it over to Ameren). Ameren has been ordered to build this substation and connect both Ranger Power and GBE by regional grid operator MISO. Ameren cannot refuse to build it. In addition, MISO's studies determined that there needs to be two new 345kV high-voltage transmission lines from the new Burns substation to the existing Montgomery substation (in Montgomery Co.) in order for GBE to connect. The existing line cannot carry enough power and new ones must be built. Ameren has also been ordered to build these new transmission lines, although GBE must pay for them.

GBE's interconnection to MISO was subject to a Transmission Connection Agreement between the parties. The TCA is a pretty standard thing that relies in large part on MISO's filed tariff with FERC. TCAs can be negotiated somewhat and once they are complete, they are filed with FERC for approval. Except GBE could not agree with MISO on a number of issues so MISO filed the TCA with FERC unexecuted (unsigned). FERC approved that unsigned TCA. GBE had asked FERC to make several changes to the TCA and force MISO to do certain things, and for FERC to make Ameren hurry up and build the new transmission lines that GBE needs to make its connection at Burns. FERC declined to make any of GBE's suggested changes and told GBE it was not necessary to tell Ameren to hurry up. GBE got NOTHING it asked for here. GBE was legally smacked upside the head. FERC has sided with its regional transmission organization, MISO, on all issues. This really isn't novel or different. FERC always sides with its pet RTOs. GBE is just stupid if it thinks it can challenge MISO and get a different result. Maybe now Polsky will get a clue about why they "don't hear from them" on all the complaints Invenergy has filed against MISO?

Although the TCA was approved by FERC, it doesn't do anything to make GBE's connection happen faster. It's still scheduled for, maybe, 2030. GBE had asked FERC to force MISO to connect some smaller portion of capacity in 2027. Not happening.

Why is this such an issue for GBE? Here's a quote from the Order:

Grain Belt asserts that, with respect to the reasons for delaying the In-Service Date of the GBX Line, Ameren Missouri did not mention that its affiliate, Ameren Transmission Company of Illinois, was awarded a number of transmission facilities under MISO’s Long-Range Transmission Planning process, which it is constructing with planned In-Service Dates of 2028 and 2030.

That's right, folks! MISO ordered Ameren to build new transmission lines to be in service in 2028 and 2030 for the purpose of importing wind and solar energy from Iowa to Missouri and Illinois. These regionally planned lines are cost allocated to all ratepayers in MISO. This means that the cost to use them is going to be considerably LESS than the bloated $7B merchant transmission Grain Belt Express. In fact, ratepayers are going to be paying for the new Ameren lines, even if they choose to use GBE instead. Let's see... renewable energy on new lines you pay for OR renewable energy on the GBE, which costs a lot more, and then you STILL have to pay for the Ameren lines anyhow. Doesn't take an energy trader to figure out that problem.

The Ameren lines will be cheaper. Therefore, GBE is in a big hurry to try to get its bloated behemoth online before Ameren gets those lines built. Looks like that's not going to be possible.

GBE is stripped bare... it's too expensive and obsolete. Who would want to be a customer? And, speaking of customers, GBE still does not have negotiated rate authority to try to find any. No matter though... GBE can't connect its project until at least 2030, when there will be better options for renewable energy transmission service in MISO.

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Damned if you do, damned if you don't

1/27/2024

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That was the sentiment expressed by one Missouri farmer about signing an easement for Grain Belt Express under threat of condemnation and taking of an easement across his land by Chicago-based energy conglomerate Invenergy. The same sentiment also applies to cooperating with biased liberal media journalists from back East. You can cheerfully cooperate and welcome these people to your home and business and hope that they are guided by professionalism and decency to tell your story accurately, or you can refuse to talk to them and be labeled as a selfish, renewable-hating deplorable in abstentia.

The people of rural Missouri are some of the most welcoming, thoughtful, and brave folks that I have ever met. Even when their gut told them that a reporter from The New Yorker was probably going to do a hit piece, they warmly welcomed him and cooperated anyway. They didn't deserve this.

Here's the filter through which the reporter viewed his entire Midwestern experience:

In a notice of intent to prepare an environmental-impact statement for the Grain Belt Express, the Energy Department notes that the project could create “local safety risks associated with electromagnetic fields, power surges, risk of increased lightning strikes, and line-induced fires.”

Of course, the risks associated with climate change are much more serious.

This was the reporter's preconceived notion going into this article. Nothing anyone said or did, or anything he saw, felt, or experienced, was allowed to interfere with this pre-determined outcome.

What do you mean, "of course"? That's the reporter's bias. The two main characters he visited for this story obviously did not agree. It's all about perspective... safety risks from GBE are guaranteed and immediate for the people who will have to live and work around it for the rest of their lives. Climate change is a political theory espoused by people like the reporter, who don't have to live and work around a dangerous invader every day. GBE won't be outside his kitchen window every morning, and he won't have to drive huge farm machinery around giant impediments on his land numerous times every year. GBE will not be personally affecting him so he is content to belittle its impacts on others in favor of his own armchair scientist theories. The risk to Missouri farmers is REAL. The risk to the reporter is a watered down possibility. Get off your high horse, buddy, assuming you've ever even been on a horse, of course.

The article drones on about how wind and solar energy has not been successfully deployed, and that it will require enormous sacrifice to ever work as a dependable source of electricity. Instead of contemplating, perhaps, whether wind and solar is not a realistic future energy source because it isn't progressing, the reporter doubles down on a bad idea by believing transmission lines like Grain Belt Express can be the turning point to success. It can't. Wind and solar are not the answer for our energy future. It's too expensive, too invasive, and unreliable. It's actually making our entire electric system incredibly fragile. We need to abandon this bad idea in favor of new technology that can produce the energy we need where we need it when we need it. I haven't heard any talk that we need enormous amounts of new transmission for new-age nuclear generators. Wind and solar is an experiment that didn't work, but it made a lot of investors very rich and they don't want to let go of their golden goose, even if it is for the betterment of society.

The reporter's portrayal of Loren Sprouse and Marilyn O'Bannon as "holdouts" against a "better grid" is unfair. Both Loren and Marilyn have selflessly devoted themselves to careful and deliberate examination of the issue and spent their personal time and money standing up for the rights of farmers. They did the right thing.

The reporter fails to mention that Loren is a knowledgeable electrical engineer and preferred to portray him as an uneducated rural farmer. When Loren worries about GBE's interference with GPS, he's basing it on REAL studies and, more importantly, real experience using GPS systems to farm. As if Loren's educated concerns can be alleviated altogether because the reporter managed to find a Canadian study that said there was no problem. Neither the reporter or the Canadian study author will be in the cab with Loren when his GPS system is scrambled or temporarily disabled.

When Loren says that GBE could have been designed better, he's expressing an educated opinion. Numerous other HVDC transmission lines have been proposed and built underground on existing road/rail rights-of-way. Choosing to reject that and instead swallow a great, big mouthful of Invenergy's excuses for not burying its line demonstrates the reporter's bias and ignorance. Grain Belt Express was planned more than a decade ago based on a bad idea for cheap, overhead lines across private property. GBE has poured millions of dollars down the drain trying to force its cheap, overhead project on private landowners over the last 15 years. At any time it could have stopped and investigated whether there was a better way to do things. But it did not. Perhaps if GBE had stopped throwing good money after bad 10 years ago, it could have used all the money it wasted on lawyers, lawsuits, environmental studies, experts, land acquisition, and buying advocacy to bury its line on existing rights-of-way instead. Perhaps if it had, GBE would be built and in operation right now.

Instead, it's barely limping along a road so lengthy it cannot see the end. GBE doesn't have county assents in Missouri, its Illinois permit is being appealed, it has not announced enough customers to pay for the line (and in fact doesn't even have permission to negotiate with customers), it has not secured its financing, it doesn't have all the land it needs, its interconnection has been delayed 3 years, and it's now facing competition from new transmission planned to be built by regional grid operator MISO.

Marilyn O'Bannon is one of the nicest, most thoughtful ladies I've ever met. But she's not a pushover. This brave lady didn't just complain when GBE showed up in Missouri, she stood up and fought for everyone. She was instrumental in forming a landowner group, fully participating at every opportunity, and she pushed herself to leave no stone unturned in her quest for justice. She went on to become a popular county commissioner, taking on a leadership role when people needed her most.

It doesn't matter what she was wearing, or what she was driving, or what various characters in the story ate for that matter. The part about the Escalade was touching... but he forgot to mention that Marilyn intended to take him around the farm in a pick up, the vehicle of choice for just such an adventure. However, when they got outside, they found all the pick ups were in use around the farm doing actual farm work. She could have sent him packing, or cancelled the tour. But instead, she took her 6-year old Escalade, used to go to town, not putter around the farm. And for that, she gets slyly attacked, like she has no right to own or drive such a car while opposing GBE's invasion of her farm. What is she allowed to drive to become a sympathetic character in this story? A totally inappropriate (and much more expensive) electric coupe? The reporter, who may or many not even own a car of his own, had no idea why a farmer may have more than one vehicle, each for a different purpose.

I found the focus on Marilyn's outfit downright creepy. Five-pointed stars on her shirt? What does that even mean? Who cares? The trucker's hat on the counter... was he sad it wasn't on her head to complete his irrational attack on her character? I'd bet that reporter would covet just such a cap if a filthy rich corporation came to take his land, or his family's land, for its own profit. Nobody knows what eminent domain feels like until it happens to them. It's a devastating punch to the gut, not a slogan used to make ad hominem attacks on people unlucky enough to experience it.

The quotes attributed to Marilyn regarding climate change are manufactured, she claims. Marilyn shared that she was recently contacted by a New Yorker "fact checker" to make sure the quotes in the story were correct. Although she said they were not, it didn't matter. They stayed in the story. That's all we need to know to dismiss this article as a pre-planned hit piece.

At the end of the day though, nobody in rural Missouri reads The New Yorker. It doesn't matter to them or their battle how they are perceived by eastern city dwellers. What does matter is that Marilyn, Loren, and others graciously hosted a stranger and told their story honestly. That the reporter couldn't accept it because it didn't fit with his pre-determined agenda is all on him. Do unto others as you would have them do unto you. It's a good way to live.

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How Transmission Lines are Routed

12/18/2023

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New transmission lines are routed by utilities using an extensive process. The actual proposed route is unlikely to resemble preliminary maps created by PJM Interconnection, or Piedmont Environmental Council. PEC simply laid PJM's generalized maps over an interactive map with actual detail. These maps may have shown transmission lines cutting through homes, historic districts, and other valuable assets. That's unlikely to happen when actual proposed routes are released by the utilities building the MidAtlantic Resiliency Link (MARL).

So, how DO utilities develop proposed routes? Here's a look at how they developed the proposed routes for the proposed, but never built, PATH transmission project 15 years ago. Utilities still use the same process today.

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Certain lands and structures are avoided. Here's a list:

The Routing Team developed specific routing criteria in identifying, evaluating, and selecting routes, attempting to minimize:

Route length, circuity, cost, and special design requirements.

The removal or substantial interference with the use of existing residences.

The removal of existing barns, garages, commercial buildings, and other nonresidential structures.

Substantial interference with the use and operation of existing schools, existing and recognized places of worship, existing cemeteries, and existing facilities used for cultural and historical, and recreational purposes.

Substantial interference with economic activities.

Crossing of designated public resource lands such as national and state forests and parks, large camps and other recreation lands, designated battlefields or other designated historic resources and sites, and wildlife management areas.

Crossing large lakes and large wetland complexes, critical habitat, and other scarce, distinct natural resources.

Substantial visual impact on residential areas and public resources.

While trying to avoid those things, the utility must also take these safety and engineering considerations into account:

Avoid double-circuiting or crossing existing 765 kV lines.

Do not parallel existing 765 kV lines for more than 1 mile in any particular location.

Minimize the crossing of 345 kV and 500 kV transmission lines.

Minimize paralleling corridors with more than one existing 345 kV or 500 kV circuit.

Maintain 200 feet of centerline-to-centerline separation when paralleling existing 345 kV, 500 kV, and 765 kV transmission lines.

Maintain 150 feet of centerline-to-centerline separation when paralleling 138 kV or lower voltage transmission lines.

Minimize angles greater than 65 degrees and sloping soils more than 30 degrees (20 degrees at angle points).

Do not triple-circuit lines of 345 kV or greater voltage.

Of course, it's impossible to avoid everything in the first list. The second list consists of engineering and safety standards and cannot be changed. Therefore, while the utility may attempt to avoid your home, it may not be able to avoid your property. Instead of going over top of your home and making it uninhabitable, they may go 200 ft. from your back door. Might as well have taken your entire home, right? I urge you to read this report carefully so you can get a feel for the things that can change transmission line routes so that you are well-armed when MARL holds public meetings in your area to present its initial proposed routes and get your feedback.

Something interesting in this report is the claim that "paralleling" existing transmission lines is somehow preferred... as if the people who live with them won't notice another gigantic transmission line across their property, or simply won't care. Think about it... if you are unlucky enough to have a transmission line routed through your backyard, would you welcome another one? Of course not! A new idea has been formulated since the PATH project called "energy justice." Energy justice means that we cannot keep forcing more and more energy infrastructure on the same people. These unlucky people have already "taken one for the team" by hosting a transmission line (or power plant) nearby. Isn't it someone else's turn? Inherent in this status quo is that objectionable infrastructure projects historically end up in the backyards of populations at a disadvantage. They are not as able as other more fortunate places to fight back and win. Therefore, the disadvantaged communities get the infrastructure thrust upon them time after time. This is not only unfair, it is morally reprehensible. We ALL deserve to live safely and happily on our own property. Nobody is a "throw away" to be ground down under the boot heel of "progress."

Another problem with paralleling is that homes and communities have been built up around old transmission lines that have been in place for decades. In some places, the development is so thick that paralleling causes the taking of improvements made just outside the right of way, whether it is a shed, barn, fence, pool, swing set for the kiddos. It also can include land the homeowner is using for a well and/or septic system. None of these ordinary residential land uses are compatible with transmission easements and will have to be removed. If a home's water and sewage disposal is made unusable, that can make the home uninhabitable. Paralleling is an idea that needs to die.

Also interesting in this report are the routes where the utility proposed tearing down an existing transmission line and rebuilding it on new structures that include both the old circuit and the new one. The unfortunate part of that situation is that the easement must always be expanded to house the bigger structures. This is exactly what FirstEnergy is planning to do with its portion of the MARL -- tear down an existing 138kV line on wooden poles less than 100 ft. tall that is situated on a 75 ft. wide easement, and replace it with a 500kV/138kV 200 ft. tall double circuit on big, new lattice steel towers. The existing easement must be expanded to accommodate this new line.

How much? Well, that seems to be mired in layers of murk. When NextEra originally proposed the MARL, it said it could do this amazing rebuild with only 30 additional feet of right of way. 30 added to the existing 75 equals 105 feet. No way they are putting this double-circuit monstrosity in 105 feet, right next to a parallel existing 500kV line. It doesn't even meet safety code. So, NextEra was either ignorant of the width of the existing ROW, or simply making things up in order to make its project more likely to be selected by PJM. However, PJM decided to give that rebuild section to incumbent line owner FirstEnergy to rebuild its own line to include MARL. FirstEnergy has not yet announced how much it would need to expand the existing ROW. We're in the dark on the rebuild section. However, when routing PATH 15 years ago, FirstEnergy had this to say about expanding that 138kV ROW:

In these cases, the existing transmission corridor already runs through theses areas, and in order to keep the height of the structures lower, the Applicant would work with the holders of these easements to modify them in order to acquire approximately 105 feet of additional ROW.

PATH proposed expanding the existing 138kV easement in Northern Loudoun by 105 feet. 105 plus the existing 75 feet comes to nearly 200 ft. 200 feet is the standard easement required for a 500kV line like MARL. I guess we can expect that FirstEnergy is going to ask landowners for another 105 feet of easement for the 36-mile section stretching from Frederick County, VA to the point in Loudoun where the line turns south towards Waterford. This includes the section in Jefferson County, WV. If you live along this stretch, you may want to measure an additional 105 ft. from the edge of the existing ROW to see how much of your property is going to be gobbled up by expanded ROW, and how much closer it is going to be to your home.

It is our job to educate ourselves if we're going to be successful in stopping the MARL. Taking a look at how utilities actually route transmission lines is the next logical step.

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GBE Project Delayed Another 3 Years

12/12/2023

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Grain Belt Express is complaining again. Last week it filed a complaint with the Federal Energy Regulatory Commission against MISO, the Midcontinent Independent System Operator. This makes the second complaint Invenergy filed against MISO regarding GBE. The first complaint GBE filed is still languishing more than a year later. This one will probably suffer a worse fate.

The problem is that MISO recently notified GBE that it was changing the date for connecting GBE to the MISO transmission system from December 1, 2027 to December 1, 2030 based on MISO's determination that some of the Network Upgrades that are required by MISO for Grain Belt's interconnection may not be ready by 2027. GBE says it will have its project built in 2028 and wants MISO to allow it to connect some smaller portion of its capacity that does not rely on the Network Upgrades at that time.

MISO's rules do not allow for this kind of "limited operation," therefore MISO cannot grant it without changing its rules. In order to change its rules, MISO must complete its stakeholder process, which can take years to talk about the rule changes, vote on the rule changes, get the rule changes approved by FERC, before they can become effective. That's probably going to take longer than 2030 because MISO has a lot on its plate.

GBE tries to tell FERC that other system operators permit limited operation, therefore MISO should, too. Too bad GBE never raised this issue and asked for this rule when the rules for merchant transmission were being made. It is what it is... GBE cannot connect to MISO until 2030. That's 7 years from now.

But what about those "Network Upgrades" that got delayed and required pushing GBE's interconnection out until 2030? What are those upgrades? According to GBE's complaint:

The Ameren upgrades involve two new 345 kV Montgomery-Burns transmission lines for which GBX will pay $126.5 million. The total cost of all upgrades that GBX is funding under the TCA is $217 million. In addition to permitting the two new Ameren transmission lines, Ameren mentioned some concerns about scheduling outages in connection with these lines and coordinating with AECI, which is an Affected System.

Well, what do you know... two MORE 345kV transmission lines caused by GBE and that GBE needs to have built in order to connect its project. First there was the GBE itself, then there was the 40-mile Tiger connector and now TWO 345kV lines connecting the new Burns substation in Callaway County to the existing Montgomery substation to the east. Where is the Montgomery substation?

These 2 new 345kV transmission lines are the financial responsibility of GBE, but will be built by Ameren in its service territory. Therefore, Ameren has to get them permitted by the PSC. More landowners are going to be affected with new transmission only made necessary because of GBE. But will these new landowners be entitled to 150% of fair market value? What problems are going to crop up during permitting of these new lines? Is it going to take them as long to get permitted as all the other GBE lines? No wonder the connection date has been pushed out until 2030.

Grain Belt Express -- spreading the misery to thousands of landowners across Missouri for at least 20 years. Will GBE even be relevant by then?

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PJM's Constructability Farce

12/1/2023

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Constructability? Is that a word? My internet spelling police hates it, but constructability is defined as:

Constructability (or buildability) is a concept that denotes ease of construction. It can be central to project management techniques to review construction processes from start to finish during pre-construction phase. Buildability assessment is employed to identify obstacles before a project is actually built to reduce or prevent errors, delays, and cost overruns.

PJM loves its constructability analyses to select a project from a pool of many options. PJM pretends it's all so scientific and dependable. But, is it really?

Here's PJM's Constructability and Financial Analysis Report. I didn't expect it to be anywhere near correct or accurate, and I wasn't disappointed. It's completely illogical to the point of demonstrating bias. Why is it that PJM has selected some of the most risky projects to recommend for approval by its Board of Managers? Here's what I mean (see page 115 of the report for larger image):

Out of this "west" group, PJM has selected the riskiest project, Proposal 853. 853 has two "high" risks, two "medium-high" risks, and two "medium" risks. It's the riskiest one in the table. So, maybe it's about costs? Proposal 853 costs $1,195,240. It's still more than the cost of Proposal 904 at $1,122,400. It can't be based on price. Just what DID motivate PJM to select 853 instead of 904 or one of the other projects on the table?

What is proposal 904? It's the building of a new 765kV transmission line through a section of central Virginia. 904 connects the data centers to a huge inventory of fossil fuel generators in the Ohio River Valley using AEP's 765kV transmission network. Significantly, proposal 904 keeps all the transmission necessary to serve Virginia's new data center build in Virginia. The other proposals inflict the burden of serving Virginia's data centers on other surrounding states. Keep that in mind as we examine these two competing proposals as PJM did in its Constructability report.

Project 853

Overall, the ROW risk for the new West cluster transmission line components in this proposal is medium-high to high, as the proposed new transmission lines are routed parallel to an existing ROW for majority of their alignment.

Environmental Risk Analysis
46a – 502 Junction to Black Oak OH 500 kV Line
Route crosses West Virginia and MD Department of Natural Resource (DNR)-recognized public lands and is also within a short distance of residential areas.
4CA – Black Oak to Woodside OH 500 kV Line
Route crosses through the Appalachian Mountains and intersects with VA Natural Heritage easements.
10C1A – Woodside to Gant (Segment 1) OH 500 kV Line
The proposed route for this line segment goes through several national scenic and historic trails (Harpers Ferry National Historical Park and the Appalachian Scenic Trail), and intersects public lands and conservation easements. This may require permission from the National Park Service (NPS) and require an Environmental Assessment (EA) pursuant to the National Environmental Policy Act (NEPA) to analyze the impacts to the environment and park resource, which could be a lengthy process. This route is also within a short distance of residential and commercial areas.
10C3 – Woodside to Gant (Segment 2) OH 500 kV Line
The proposed route for this greenfield line segment goes through highly developed residential and commercial developments, as well as state and local conservation easements. This route also crosses the Washington & Old Dominion (W&OD Trail), a regional park in northern Virginia. There is significant risk of public opposition to the proposed route, which may lead to rerouting this segment along the existing corridor from Doubs to Goose Creek.

Overall, for Proposal 853, medium-high constructability risks are assessed for the proposed line routes due to anticipated lengthy regulatory process, potential public opposition, construction difficulty, environmental constraints and property acquisition, which may have significant impacts on the cost and schedule for the proposed project.

Transmission Line Risk Analysis
Significant engineering and construction challenges are anticipated for the proposed lines to construct a total of 167 miles of new transmission through four states and will require parallel crews and construction where possible to mitigate schedule challenges that will be introduced by the anticipated lengthy permitting and land acquisition process.
For the rebuild portions of the proposed line routes, there are challenges with existing overhead transmission infrastructure components needing to be removed/salvaged before construction of proposed brownfield lines can commence, and potential design and ROW limitations for reuse of existing infrastructure/assets.
Other medium risks for this project involve the existing facility outages that will be necessary for the project, particularly for the line rebuild and substation upgrades.

Schedule Review
The proposed in-service date of June 2027 is very aggressive for the proposed scope of the project considering the significant permitting and land acquisition challenges associated with the proposed 500 kV greenfield line routes through four states. Overall, the schedule risk is considered medium-high.

Project 904

Environmental Risk Analysis
Joshua Falls-Yeat 765 kV OH Line
The proposed line route has the potential to impact environmental and cultural resources including: the Southern Albemarle Rural Historic District, a FEMA High-Risk Flood Zone, wetlands and several waters subject to USACE Section 10 permitting, the most significant being the James River. The route also intersects local conservation easements and appears to co-locate with pipeline ROWs.
Warrenton-Wheeler 230 kV OH Line
The line crosses woodland, residential and agricultural parcels in Fauquier and Prince William counties in Virginia. The route intersects local conservation easements and potentially impacts environmental resources such as Auburn Battlefield Historic District, flood plains and wetlands.
There are medium constructability risks assessed for the proposed line routes due to anticipated lengthy land acquisition process, potential public opposition and environmental constraints, which will have impacts on the cost and schedule for the proposed project.
Transmission Line Risk Analysis
Transource has an optimistic schedule for several aspects of this component and would require a near perfect execution to maintain the proposed in-service date. Given the scale of the component, a 135 mile 765 kV line with everything from permitting to land acquisition to construction poses a risk for delay, the most critical being land acquisition.
For the 230 kV developments, Yeat-Clover Hill and Warrenton-Wheeler, these facilities will utilize BOLD (Breakthrough Overhead Line Design), which is a structure family developed by AEP. The design features a monopole structure with two arched crossarms to hold two circuits in a delta configuration. Benefits of BOLD include increased line capacity with lower-profile structures. However, utilizing this structure family poses risks to the schedule, specifically procurement of the arched crossarms, construction and maintenance of a non-typical design.

Schedule Review
This proposal includes 765 kV substation and transmission line construction, as well as utilization of BOLD (Breakthrough Overhead Line Design) technology for the greenfield 230 kV lines. The sum of all components is a very aggressive undertaking to be completed within the proposed schedule. The primary risks for this proposal are related to the magnitude of the scope of work, procurement and construction of 765 kV equipment and BOLD structures, state permitting and land acquisition for both the 765 kV and 230 kV developments. These all pose a medium-high risk to the December 2029 in-service date proposed by Transource.

Project 853 has medium-high constructability risks, while 904 has medium constructability risks. Gee, no help there either. 904 is cheaper and less risky, but PJM still selected 853.

And then there's this tidbit... did you catch it the first time you read it?

There is significant risk of public opposition to the proposed route, which may lead to rerouting this segment along the existing corridor from Doubs to Goose Creek.

PJM KNOWS this project isn't going to happen the way it was proposed and recommended for approval. PJM is already anticipating so much opposition to the new greenfield segment in Loudoun County that it will have to abandon this plan and move the proposed new 500kV transmission line over to an existing corridor between Doubs and Goose Creek. What is that corridor?

The 853 project in Loudoun is represented by that green line. The Doubs corridor is represented by that roughly parallel yellow line to the east. Sounds like a solution, you think? Think again! PJM has also recommending work on the Doubs-Goose Creek corridor to add another 500kV line to its existing 500kV and 230kV lines. In order to squeeze another 500kV line in there, PJM proposes to rebuild the existing 230kV line as a double circuit 230/500 kV line, and then add a second 500kV line. Moving the 853 project over to the Doubs corridor would add a THIRD 500kV line to that existing corridor. Would that be a double circuit 500/500 kV, in addition to a 230/500 kV double circuit? Or would there be one 230/500 kV double circuit, and two separate 500 kV lines? Either way, it will require significant expansion of the current easement through a heavily developed area of Frederick and Montgomery Counties (Maryland) and construct an unimaginable amount of power in that corridor (three 500kV circuits + one 230kV circuit). Chances of success on this idea rate right up there with the survival of a snowball in Hell. Which area is capable of forming bigger opposition? Loudoun County or Frederick/Montgomery Counties? Personally, I think it's a tie. Either one is going to kill this project dead. Remember, it's not about fighting each other to push the project off onto someone else, it's about stopping the bad project altogether. Nobody wants this anywhere!

So, what did we learn from PJM's constructability analysis? Not much. PJM did not examine the gray areas of opposition that I did. PJM pretty much ignored the possibility of opposition derailing their plans. Dismissed!

But, we're not going away. In fact, we're only going to get stronger. I predict that this project will NEVER get built. Maybe PJM should go back to the drawing board and take another look at project 904? Why did they dismiss that project anyhow? PJM never actually says. In fact, after reading all of PJM's excuses, err I mean analyses, I came away more convinced than ever that this whole thing is a farce. Some of the excuses for not selecting a project were so ridiculous, such as -- we didn't select this project because we selected a different project. That's not a REASON for making a project selection. I also got the idea that PJM is absolutely terrified of rich people opposition in certain areas of Northern Virginia. PJM has bowed down to the wealthy and privileged due to their bad experience trying to route the TrAIL project through those areas. PJM thinks it's a better idea to route its projects through disadvantaged areas that can't fight back (or so they think). That kind of thinking is outrageous in this day and age of environmental and energy justice reform. Add in the fact that PJM's new transmission lines are nothing but extension cords importing dirty, delicious, coal-fired electricity out of West Virginia and Pennsylvania and you've got a project idea that is dead on arrival when asking for federal help.

Stupid, stupid, stupid, on top of dumb, dumb, dumb, PJM! It's obvious PJM has another agenda at work here and it's not providing needed electric service at the lowest cost. Let's hope the PJM Board of Managers examines this farce carefully before making its decision on December 11.

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DOE Releases Preliminary List of NIETCs

FERC To Announce New Transmission Rules May 13

Washington Post Says The Quiet Part Outloud

What's an NIETC and what can I do?

DOE Pretends to Plan New Transmission

Grain Belt's Not So Big News

Damned if you do, damned if you don't

How Transmission Lines are Routed

GBE Project Delayed Another 3 Years

PJM's Constructability Farce

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