Clean Line Energy Partners, LLC, becomes South's newest Regional Transmission Organization! (Not really.)

2.2.2 Clean Line Has Developed the Project Using Analyses and Steps That Are Consistent with RTO Planning

SPP’s and MISO’s planning processes for their internal system purposes occur through a series of connected studies and analyses to identify the need, to design a proposed addition, and to ensure these additions meet specific reliability, economic and policy concerns. In designing and implementing the Project, Clean Line has undertaken a similar and consistent series of studies that have shaped the Project into its present form. Similar to SPP’s and MISO’s transmission planning, Clean Line has developed the Project through the following studies and steps: (1) establishing the likely location of wind generation; (2) assessing known areas of congestion; (3) assessing utility demand for wind power; (4) determining the necessary physical infrastructure to meet that demand; (5) considering economic development implications; (6) conducting power flow analyses; and (7) production cost modeling to quantify cost savings to consumers. The Project meets the criteria for consistency in planning under Section 1222(b) through its use of steps and analyses to plan and develop the Project that are consistent with the SPP and MISO planning process.

1. Establishing the Likely Location of Additional Wind Generation 

MISO and SPP plan their respective transmission systems around forecasted locations of wind generation based on wind analysis, the interconnection queue and input from stakeholders. For example, in the process of designing and evaluating the Priority Projects, SPP Staff designed a portfolio of seven gigawatts (“GW”) of new wind projects in six locations around the region. Likewise, MISO’s selection of sites for coordinated wind and transmission expansion dates back to the Regional Generation Outlet Study, performed in 2008 and 2009. The selection of renewable energy zones for further transmission development included wind analysis, site suitability and distance to existing infrastructure. The highest ranking sites were selected to be included in the MISO transmission expansion plan and set the beginning points of many of the MVP Projects.

As noted in Section 2.5.1 of the Draft EIS and supporting technical materials, Clean Line conducted a similar analysis to define the zones from which the Project is likely to connect wind generation. The process incorporated wind development activity and responses to a Request for Information, wind mapping, evaluating distances from the Hitchland substation area, and environmental and land use consideration. The process used by Clean Line to identify the locations of additional wind generation was therefore consistent with the processes used by SPP and MISO. The identification of the most likely locations for wind development was a key step in planning and developing the Project. 

2. Assessing Known Areas of Congestion

In developing their portfolios of transmission lines to connect wind generation to load, both SPP and MISO examine existing congestion due to wind generation. This analysis provides information about where transmission lines could generate economic savings due to reduced congestion costs. For example, SPP’s Board of Directors has noted growing congestion on its system and tasked its staff to “reduce grid congestion” and “better integrate SPP’s west and east regions.” MISO likewise has identified transmission constrained zones which affect the ability to fully utilize wind and designed upgrades to relieve the constraints.

Similarly to SPP and MISO, Clean Line evaluated existing congestion patterns when designing the Project. Early in the Project’s development, Clean Line observed that existing wind generation in the Oklahoma Panhandle region was already experiencing very low prices due to transmission congestion. In its 2009 National Electric Transmission Congestion the DOE identified the Oklahoma Panhandle region as a Conditional Constraint Area (“CCA”). The region is a Type I CCA, meaning wind generation can be developed with existing technology. In that report, the DOE notes that Kansas and Oklahoma have strong wind generation potential that could significantly improve the economic vitality of the states’ rural counties, enhance reliability and potentially reduce consumer electricity costs.59 By creating a direct, HVDC link to the Mid-South and Southeast, the Project assures that the connected generators will not experience congestion and avoid existing transmission constraints.

(You know, in the process Jimmy Glotfelty helped advocate for in the office he created and directed that's the same office that's overseeing this process now back in 2003?)

This one:

(Yeah, that process. The one that was laid out to help identify the "constraints" that led to the "constraints" that resulted in the eventual RFP from the Department of Energy.)

Or, here, after he left DoE in 2005 and became VP of ICF International where he:

(Maybe worked on recommendations about "constraints"?)

3. Assessing Utility Demand Based on Public Policy and Other Factors 

In planning their respective transmission systems, both SPP and MISO conduct a review of regional renewable energy portfolio standards and goals to determine the amount of renewable energy needed. For example, SPP distributed a survey to state representatives in its Cost Allocation Working Group about each state’s mandated or desired level of wind generation. Based on these responses, SPP established a target in 2020 of approximately 11 GW of total wind generation. MISO likewise surveyed each member utility’s renewable portfolio standard requirements in 2021 and 2026 in order to determine how much incremental renewable generation the transmission plan needed to enable. These assessments allow MISO and SPP to build transmission to meet the needs of their member utilities for low-cost clean energy. 

In planning for the Project, Clean Line conducted a similar review based on numerous meetings with utilities and state policies, which is summarized in Section 2.1.3. As discussed there, Clean Line reviewed and identified the need and demand for renewable energy within the Mid-South and Southeast. In determining the size of the Project, Clean Line took into account the large potential demand for low-cost wind power delivered by the Project, and dimensioned the Project so that it could meet a substantial portion of the identified demand. 

4. Determining Physical Infrastructure 

In their transmission expansion plans, SPP and MISO weigh the distances involved and evaluate the economics of different voltages and numbers of circuits. Transmission lines with higher voltages and more circuits can carry more power, but are also more expensive. SPP faced this tradeoff in implementing two of the Priority Projects. SPP had studied the use of 765 kV lines to move larger amounts of power within the SPP region than would be possible with 345 kV lines.62 However, a 345 kV-only portfolio produced better regional cost-benefit metrics and therefore was approved by SPP’s Board of Directors.

MISO also studies the appropriate voltage and circuit level to use in in its transmission expansion. In its 2006 transmission expansion plan, MISO initially examined a series of 765 kV transmission lines to improve access to low-cost and high-capacity factor wind generation.64 However, in its 2011 planning process, MISO concluded that a preferable option was a build out primarily of double circuit 345 kV lines, with some single circuit 345 kV additions and one 765 kV line segment in Indiana.

In developing the Project, Clean Line also analyzed the appropriate technology and voltage for the desired power levels. An initial economic analysis indicated that HVDC was clearly more economic than AC lines of any voltage in light of the power levels and distances involved.66 A review of recently completed projects identified that DC voltages in the 500-600 kV level were most appropriate. Finally, a more detailed analysis of capital costs and electric losses concluded that 600 kV was the most appropriate voltage when considering power transfer levels, losses, and capital costs. Clean Line’s studies, like SPP’s and MISO’s, assured that the Project was consistent with the need to use the appropriate technology and voltage to economically achieve the goals of transmission expansion.

5. Considering Economic Development Implications

Both SPP and MISO seek to ensure that their transmission expansions result in economic development benefits for the region. In fact, both SPP and MISO have employed Brattle Group estimates to assess the economic impact of their proposed transmission expansions. The Brattle Group studies perform an economic impact assessment using IMPLAN and NREL’s JEDI model.68 

Clean Line performed a similar study, which was attached as Appendix 2 to its July 2010 Proposal to DOE. In addition, the Socioeconomics and Environmental Justice Technical Report that Clean Line submitted to DOE as part of the NEPA process extensively analyzes the employment impacts of the Project, which are further discussed in in Section 3.3.

6. Conducting Power Flow Analyses

In their transmission plans, SPP and MISO examine specific power flow cases to identify violations of reliability criteria that would require either additional transmission expansion or modifications of the proposed upgrades. For example, SPP’s Transmission Working Group prepared a series of power flow analyses on the Priority Projects to determine whether this expansion either required additional reliability projects to meet the required NERC and regional standards, or whether the Priority Project actually eliminated other reliability projects that, absent the Priority Projects, were needed to meet the standards. MISO also performed steady state power flow analyses of the MVP projects to see if any NERC or regional reliability standards were affected.

The Project has been the subject of comparable power flow analyses through its interconnection studies with SPP, MISO and TVA. As discussed below in Section 2.2.3, the interconnection studies monitored any violations of reliability planning standards and prescribed upgrades to remedy any violations. The reliability standards used in MISO and SPP transmission planning studies are consistent with and identical to those used in the interconnection studies performed by these entities regarding the Project.

7. Production Cost Modeling

SPP and MISO both use a production cost modeling software, PROMOD, to examine how proposed projects will affect the dispatch of their system. Specifically, the RTOs examine whether the points of injection of new wind power, together with the studied transmission expansion, result in any meaningful amount of curtailment of anticipated power flows. They also examine the extent to which the new transmission projects generate production cost savings for SPP and MISO member utilities.

Clean Line also conducted a similar analysis using PROMOD. An earlier version of this analysis was conducted with GE’s Multi-area Production Simulation (“MAPS”) and was included in the July 2010 Proposal to DOE. Clean Line’s production cost modeling shows that the Project results in minimal curtailment for the connected generators and substantial production cost savings. This is the same purpose for which SPP and MISO use production cost modeling in their transmission expansion plans. In Clean Line’s updated analysis, attached as Appendix 2-G to this Part 2 Application, curtailment for the connected wind generation was reduced to a single hour of the year, in contrast to over 15% curtailment (an economically unfeasible level) for the same amount of wind generation if the Project is not built. The analysis also shows annual production cost savings of $540 million because of the Project. These savings arise because the Project’s low-cost wind generation reduces the cost of the fuel purchases by utilities necessary to serve their load.

Well, there you have it, folks! Given the fact that Clean Line used a "similar and consistent series of studies" as MISO and SPP, they should be given the same weight as an ACTUAL Regional Transmission Organization in their qualification for Section 1222, given that Section 1222 mandates:

(B) is necessary to accommodate an actual or projected increase in demand for electric transmission capacity; (2) is consistent with— (A) transmission needs identified, in a transmission expansion plan or otherwise, by the appropriate Transmission Organization (as defined in the Federal PowerAct) if any, or approved regional reliability organization;

An RTO must:

(j) Required characteristics for a Regional Transmission Organization. A Regional Transmission Organization must satisfy the following characteristics when it commences operation:(1) Independence. The Regional Transmission Organization must be independent of any market participant. The Regional Transmission Organization must include, as part of its demonstration of independence, a demonstration that it meets the following:(i) The Regional Transmission Organization, its employees, and any non-stakeholder directors must not have financial interests in any market participant.(ii) The Regional Transmission Organization must have a decision making process that is independent of control by any market participant or class of participants.

(iii) The Regional Transmission Organization must have exclusive and independent authority under section 205 of the Federal Power Act (16 U.S.C. 824d), to propose rates, terms and conditions of transmission service provided over the facilities it operates. 

Take Clean Line's word for it, guys. They did the studies, too. Their transmission line is needed because they say so! They're really just doing MISO and SPP a favor, here. All of this is really too silly for words. Why are we here, again?