National Transmission Needs Study Declares Itself Useless

Wait... was it just 10 minutes ago that I said giving the children running the U.S. Department of Energy a pot of money to undermine our current transmission regulatory system was a dumb idea?  Here's another example!

This week the DOE released its National Transmission Needs Study.  As expected, it supposes that we will need many new transmission projects everywhere in the future.  

But what good is it?  After a lot of pushback on its draft study  contention that DOE has any authority whatsoever to plan the transmission system, the announcement says this:

The Needs Study is not intended to displace existing transmission planning processes and is not intended to identify specific transmission solutions to address identified needs, but it does identify key national needs that can inform investments and planning decisions.  ​

Right.  It's useless for planning purposes.  Mainly because experienced planning organizations are NOT going to take advice from a bunch of politically-motivated babies who don't know how to plan lunch, much less a transmission system.  But, bless their little hearts, the DOE babies still think they're influencing their superiors.

Let's look to the actual study.

The findings of this Needs Study are intended to inform regional and interregional planning, as well as help guide the Department in the execution of its transmission-related authorities. The Department understands the factors that drive industry transmission planning today and the entities and institutions that perform such planning. This Needs Study is not meant to displace these planning processes or the reliability standards they address. Rather, the Department believes it will be an important addition to overall industry and government planning efforts to reduce transmission congetion and capacity constraints that adversely affect consumers. 

In other words, all of the stuff in here is useless.  So why did all this taxpayer money get wasted?  It only has comedic value at this point.  

Appendix B contains a Comment Synthesis and Resolution.  

This is the only part worth reading because the rest of it is collective fantasy.  Reality intruded in the comments and watching DOE try to sidestep it is much more entertaining than the report itself.  Imagine how hard I laughed to find my own name mentioned 36 times in the Comments section.  Yes, I submitted comments.  I had fun writing them.  Apparently someone at DOE had fun reading them.  And then some idiot tried to "resolve" them.  I'm not going to list all the brainless responses to my comments, just the ones that made me laugh the most.

A few individuals express opposition to the basis of the Study and what they view as political or parochial goals of the Study. One individual, Keryn Newman, criticizes the discrepancy between needs identified in the 2020 Congestion Study and the draft Study, stating that in 2020, DOE did not find a need to designate transmission corridors. In contrast, this report finds significant transmission need “in an area so vast that if the DOE were to designate corridors to solve it, the entire continental U.S. would be one gigantic ‘corridor.’” Newman concludes that this discrepancy can only be attributed to the fact that the studies “are not based on data and science, but on political goals. 

DOE's "resolution" to my comment?  There wasn't one to this particular comment.  And so it begins...

Keryn Newman criticizes the Study’s conclusion that large-scale transmission build-out is cost-effective. Newman cites the Study’s “vague claims of ‘economies of scale,’” arguing they are never justified and allow DOE to avoid a comprehensive analysis of the cost of transmission. 

Again... not resolved.  Perhaps the comment quoter had big intentions for some of these legitimate comments to be resolved, but the resolver preferred to make crap up and watch cat videos on Facebook.

Keryn Newman argues that the Needs Study does not include adequate consultation with landowners, whom Newman identifies as those who will most experience the devastating impacts of transmission development. Newman argues that the Study identifies landowner concerns as a barrier to transmission deployment but does not bother to consult these “barriers” or to devise solutions to mitigate their concerns. For this very reason, Newman also objects to the FERC Report on Barriers and Opportunities for High Voltage Transmission, which is cited in the Needs Study. Additionally, Newman argues that landowner interests should be represented on DOE’s Technical Review Committee. ​

Finally... we're getting somewhere!  DOE's resolution to this issue is:

Department Response
In response to comments from parties requesting additional, targeted stakeholder and Tribal outreach and continued stakeholder engagement, the Department has made additional efforts to engage with entities beyond the Department’s consultation with states, Tribes, and regional entities pursuant to Section 216(a) of the FPA, as amended (16 U.S.C. §824p(a)(1)). The Department has continued to accept meeting requests from commenting and interested parties to discuss draft Study findings.
Further, the Department has created regional and national fact sheets to be appended to the final Study and released concurrently to help make Study findings more accessible. The Department hopes the final Needs Study will be used as an educational tool to engage communities in discussion about grid needs. Departmental communications on final Study findings are a tool to solicit additional feedback from stakeholders on what future iterations of the Needs Study should entail.
The Department agrees with commenters that landowner, community, stakeholder, and Tribal engagement is imperative. The Department added Section V.e. Siting and Land Use Considerations (pages 95–108) to the final Study on subjects of unique interest to the communities. This section contains discussion of best practices for developers in engaging with landowners and other affected parties. 

Would any landowner who has had a meeting with DOE please raise your hand?  DOE is lying about having meetings with landowners, or any contact whatsoever.  As well DOE does not intend to CONSULT with landowners... it wants to dictate to landowners about how they should feel, what they should want, and thinks it needs to "educate" landowners to gladly participate in their goose-stepping march to government control.  This is the kind of nonsense dreamed up by privileged babies who have never had to live life in the real world.  The DOE's "Best Practices" did not come from discussions with actual landowners.  They came from a bunch of urban dimwits who think meat comes from Walmart, a place where they would never set dainty foot!  This is completely useless.  What landowners want is a seat at the table, not a bunch of know-nothings speaking for them.  DOE actually thinks if they read a number of studies done by fellow urban dimwits that pretend to speak for landowners that automatically makes them experts on what landowners want.  It would have been a lot less time consuming and a lot more accurate to actually consult with landowners.  What is it about us that *scares* these babies so much?

Keryn Newman objects to the Needs Study’s statement that “large amounts of low-cost generation potential exist in the middle of the country and accessing this generation through increased transmission is cost-effective for neighboring regions.” Newman argues this approach is only low-cost due to taxpayer-funded subsidies and lower-cost lands and that “turning rural America into an energy serfdom to provide power to far-away cities” benefits urban communities that do not want to build infrastructure in their own backyard. Newman also argues that the statement exhibits “cultural and political elitism.” Furthermore, Newman argues that the Study dismisses legitimate landowner concerns as “NIMBYism” and barriers to transmission development without attempting to address them. Accordingly, Newman concludes that the Study lacks awareness and empathy. 

The use of quotation marks slays me.  The response does not.

The Department stresses that addressing landowner concerns is critical to ensuring just and equitable outcomes in transmission deployment. The Needs Study makes no reference to “NIMBYism” and the Department has taken care to ensure that landowner concerns are not presented as a barrier to transmission deployment in the final Study. 

Well, that demonstrates lack of awareness and empathy.  Bravo!

Here's what DOE's "study" concluded about transmission on farmland.

Transmission can share much of its rights-of-way with other activities, such as agricultural fields or recreational paths, and are considered a “mixed use” activity. 

This also demonstrates a complete lack of sense and an absolute disconnect with farmers.  This is WHY DOE needs to consult with landowners.

This is how your hard-earned money is being wasted in Washington, DC.