Wednesday, July 10, 2013

Commentary about Grain Belt Express, RICL, and Clean Line Energy


After reading ComEd’s expert witness testimonies and the testimonies  of the ICC staff here’s my opinion on some of the current affairs of Clean Line Energy.   I think ComEd raises some valid points about who is going to pay for the reliability issues created by the addition of the Rock Island Clean Line (RICL).   Yes, I imagine RICL is hoping ComEd would help them out and pay for the improvements.   These costs could be allocated to the consumer through ComEd and there is no chance ratepayers will pay for the upgrades and necessary improvements to handle the 3,500 mwh project through RICL.   RICL has already asked PJM and FERC for some cost allocation on this project, and Clean Line Energy was rejected at both levels.   Like ComEd either directly states or implies, if construction begins on RICL and there are cost overruns, Clean Line would likely ask for cost allocations.   In essence, Clean Line very likely could ask FERC for a consumer bailout.
While it is probably not the place of the Illinois Commerce Commission (ICC) to decide which part of this RICL project Clean Line should pay for and which part ComEd is responsible to build to help out RICL, ComEd raises some valid concerns that have not yet been addressed or decided by MISO, PJM, or FERC.   I think ComEd is correct in asking the ICC to hold off until these concerns have been ironed out.   The last thing we want is for RICL to proceed and then complain they don’t have access because somebody else needs to build another powerline for them at the expense of the ratepayers.
While FERC approval for Grain Belt Express should be an easy cut & paste from the RICL filing, Clean Line Energy has not filed with the fed’s asking for approval.    It is not by accident Grain Belt Express has not filed for FERC approval and has not filed with the ICC for state approval.   Next, combine this situation of many undecided RICL issues with Grain Belt Express.   It appears to me Clean Line is traveling in virgin land with RICL and learning were the landmines are located.   Whether RICL succeeds or fails to obtain state approval, my guess is Clean Line will take what they have learned and pursue cost allocation for Grain Belt Express.
Clean Line knows they are not a part of any Regional Transmission Organization’s (RTO’s) long term planning and this is a problem to obtain cost allocation.   I suspect Clean Line is working behind the scenes trying to get Grain Belt Express to be a part of PJM’s long term plans.     Whether the RICL project succeeds or fails, I fully expect Clean Line will likely claim the costs of additional upgrades to assure reliability are too great and further costs for similar upgrades will make the GBE project unfeasible as a Merchant Transmission Line.   I expect Clean Line Energy to argue the only way the Grain Belt Express project to be feasible is if PJM or FERC grant them cost allocation.  
Of course with the consumers aware Clean Line Energy has not filed with FERC, this will be another hurdle for the company.   In FERC’s recent decision on those consumers fighting MISO’s CapX2020 projects, the consumers were told they should have gone through proper channels and argued their position with the RTO first and it’s now too late to appeal to FERC.   Clean Line Energy should most assuredly know consumers plan to fight FERC approval for Grain Belt Express Clean Line.   We will also be advocating against cost allocation for Grain Belt Express at the RTO’s, whether it is PJM, MISO, or SPP.
It’s not that we’re opposed to the RICL project coming through our farms.   This is not a NIMBY issue.  We are opposed to Clean Line Energy coming into Illinois.   We oppose the way Clean Line Energy was granted Public Utility Status by the Kansas Commerce Commission without even declaring a route.  

So...when is GBE going to seek FERC approval?   

Why should states or even counties, for that matter, vote to approve a project where the company hasn't even asked FERC for approval?

Grain Belt Express does not have one customer signed up.  It can't without FERC approval.  There is absolutely no proof this project is economically feasible (as a Merchant Transmission Line).  There is no economically proof wind power plus the cost of transmission at current prices is a feasible business model.  Is the supply really there at current market prices?  

There are no customers lined up to supply the wind energy for this project.  NONE.  Yes, Clean Line Energy will surely claim their potential wind energy customer base is confidential information or a trade secret but the question needs to be answered at some point.  

Where are the potential suppliers for this alleged Merchant Transmission Line?

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