Grain Belt Express Seeks to Push Costs onto Kansas and Missouri

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.