When the Pictures Speak for Themselves...

Banned from Clean Line's Astro Turf

Today we learned that someone started a blatantly faux "support page" on Facebook called "Arkansans for Jobs & Low-Cost Energy". AFJLCE claims to be a group of conservatives who support lower taxes, more jobs and excellent education opportunities for Arkansas future generations...

...and we had some fun. 

I mean really, the whole thing was a gag fest, sorry, I mean advertisement for the same old garbage they've been spewing for months. It kinda kills me that they think Arkies are so stupid that they'll just fall for the "jobs/taxes" flute. Like our eyes just glaze over and we start drooling... "jooooooobs... taaaaaaaaaxes." Please. It's insulting.

Dave got deleted first. Probably because he tagged just about every constitutional officer and elected delegate he could think of. And, ah, RTO Insider.

Scott got banned. Nic got banned... I got banned, too.  But I took screenshots of my posts...

And then... I took some more...

You may recognize this next one because I commented on it... Deleted!!!

Factually inaccurate... $5 million to our schools...

I know, I know... You're all like, "What are these people freaking out about with the taxes thing?!"

Please allow me to explain, to the best of my knowledge. Clean Line can't own their facilities in Arkansas. Our statues won't allow for that, as the PSC ruled way back when. Instead of trying to fix those rules (now even more firmly set against interstate transmission as of the last legislative session, thanks to the ill will Clean Line generated among so many people here), Clean Line decided to try their luck with the feds assuming that the SWPA would own all the facilities in Arkansas. Here's the big, honkin' problem with that plan. The SWPA is a federal agency. Federal agencies in Arkansas are immune from taxation due to both federal and state law. So unless SWPA signs a waiver, or Clean Line pays out of it's own pocket (in spite of my request above, I was not presented with a legally binding document saying that those taxes would be paid), all of those promises to the schools are nothing but hot air.

Pants on fire, indeed.

Now, I could be wrong. Maybe there is a document. Maybe Clean Line has good intentions. Know what would help the general public to determine that? Public hearings on the 1222 review, an extension on the comment period so that these issues can be more carefully explored, and rule making for 1222 in general... Which is why our lawyer filed motions with the Department of Energy for all those things today.

**Update** Oh, look!! I still can't comment, but my posts are back... Magic ;) 

**Update 2** Whoops, gone again! They're here, they're gone. Here. Gone. Here... Gone. Along with the comments of almost every member of the opposition. Nice communication with the little people, my transmission constructing inclined friends. Well done. How about you just slap another couple hundred on promoting that page. That will fix everything.

"The Best Laid Schemes of Mice and Men..."

"...Go often askew,
And leave us nothing but grief and pain,
For promised joy!"

What does it mean when a inexperienced company posing as a "utility" takes to Change.org with a couple of petitions that address nothing (But feel real good to sign. Support wind, yay! Jobs, yay! "Ally", yay!... Wait, what? Is this "Ally" by any chance a Clean Line employee?) to try and salvage public opinion for a project? When, after snarkily dismissing the opposition's petition because it's signed by people from other states, it sneakily sends out an email to supporters from other states asking for them to sign in support?

Well, it might mean that their Updated Section 1222 Application can't stand on its own two feet. Or that all those promises for taxes might be just promises (See Appendix 4-A, pg 5&6: The Feds are fixin' to own themselves a brand new shiny line -along with some number of easements- in Arkansas... but not the capacity. Wait, what?) Or that the relationship between certain parties involved in this project (not even talkin' about you, Jimmy) might be a little too close for kosher. It might mean that they're preparing an awesome comment that, yet again, won't deal substantively with any of the serious issues that have been raised about this debacle, but will include a 600 (ba-hahaha!) voter survey of Arkansans showing we support P&E. (Landowners? What landowners? Oh, wait... You mean the Sierra Club Executive Committee member you have listed on your website as a "landowner" even though he isn't even on the route? That landowner?) Because if there's one thing we've learned as a country, it's that if you have a majority opinion based on half-truths and rhetoric that tramples on the rights of a smaller, underrepresented minority, the majority is clearly in the right. That always turns out well.

Listen, guys... You can't outsignature the opposition and expect it to change anything. At least not with the people you'll actually have to deal with if by some miracle this thing goes through without SWN cleaning your clock for virtually ignoring their interest in the Fayetteville Shale (Hint: even with the current natural gas slowdown they are money in the hand. You are money... maybe... someday... when the legal battles are over... possibly).

Who are the mice here? And who are the men?

I gotta go, but I'm just gonna leave this here. Who is ElephantRider? Welcome to the microcosm. Enjoy:

And... Feelin' free to send along, as instructed:

Taxes, and Jobs, and Tourism! And a Big Oopsie... Oh, My!

Big Piney from the Rushing Bridge at dawn

It was a simply glorious day in Arkansas yesterday. Warm, but not too hot. Sunny, but not too humid. A perfect day to celebrate not only our sci-fi geekdom, but the opening day of 2015’s National Travel and Tourism Week.  And to celebrate it in the Natural State: 

• Where last year we welcomed 26 million visitors and tourism expenditures brought in $6.7 billion. 
• Where tourism is so much a part of our state economy that our Governor proclaimed May 2nd to 10th "Arkansas Tourism Week".
• Where we receive more than $460 million in state and local taxes annually from the hospitality industry.
• Where that same industry supports approximately 110,400 jobs.
• Where following the governor’s instructions to appreciate and enjoy “the natural beauty of Arkansas” could take you on a ride along the Scenic Highway 7, “the state's first state-designated scenic byway”, “arguably one of the most scenic drives in America”.
• Where you could rent a raft from some great folks (btw, if you want a little insight into the anger this project has caused, ask these folks how and when they found out about the project, and how close the preferred route came to their home and business. Ask them what Clean Line's reps said about why) and go on a scenic float down Big Piney Creek, “which ranks among the best float streams in the state”.

Surely anyone planning a major infrastructure project in the state would be cognizant of the importance of tourism and the locations of  the areas that rely on it most directly, right? Especially a corporation so concerned with "outreach" and "stakeholders". Even if they had missed the occasional landowner, surely they would have developed a deep and effective working relationship with that state’s agencies that deal with… oh, parks and tourism? Apparently not.

Big Piney at sunset from the bluff on 4E

To the Oklahoma Attorney General: A heartfelt thanks from many, many landowners...

This needs to be posted for all to see. Thank you for hearing us, and for lending the considerable weight of your voice to ours...

How many more reasons do you need, Secretary Moniz? It is now PAST TIME!

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?

First Impressions...

We're all kind of in a post-Draft EIS comment period stupor, but we did read the Quadrennial Energy Review and, I have to say, we liked a lot of what we read. State involvement, effective public engagement, agency collaboration, and keeping the transmission footprint as small as possible (using underground and existing easements) were all listed as critical to the timely and responsible development of new infrastructure. And long distance transmission for renewables to load centers did not seem to be the "be all and end all" Clean Line claims it is. In fact, the review went so far as to say the need for that kind of transmission is lessening due to the increasing availability of local renewables thanks to rapidly improving tech.

I'd love to write more and add some pictures, but I gotta get the kids to school... And can I just say, it feels like we've been let out of jail. I know this whole fight is long from over, but for the last year we've all been completely consumed by Clean Line. I can't tell you what this fight has cost us. It's been exhausting... emotionally, financially... And while there have been amazing moments between neighbors... friendships built and connections made that will have made us a stronger community. A stronger Arkansas... I can't help lamenting, and being furiously angry, over what we've lost.