SPP Map 2013

As if they don’t exist?  Yes, and that’s because they don’t.  That’s because they’re transmission projects in their own minds, and not in reality.

What?  SPP, the Southwest Power Pool, dissing Clean Line?  See for yourself!  It’s as simple as doing a simple search of the SPP planning reports.

We know, Clean Line is all about Clean Line, but there’s a significant disconnect between what Clean Line is saying about SPP, claiming “approval” of its projects and incorporation of those projects into SPP’s plans, and the reality of what shows up in those plans.  Or more correctly, what DOESN’T show up in those plans:

CLEAN LINE IS ABSENT!

PLAINS & EASTERN CLEAN LINE IS ABSENT!

GRAIN BELT EXPRESS CLEAN LINE IS ABSENT!

Whadda ya mean?  Well, on November 19, 2012, Plains & Eastern Clean Line sent out this press release:

SPP Transmission Working Group approves Plains & Eastern Clean Line reliability studies

This press release was EVERYWHERE, with Clean Line jubilant, jumping up and down, so excited and so elated, and stated that:

The Southwest Power Pool’s (SPP) Transmission Working Group today unanimously passed a motion accepting that the Plains & Eastern Clean Line reliability studies completed to date have met the coordinated planning requirements.

And went on to say (emphasis added) that:

Clean Line is also pleased to announce that it recently submitted the Plains & Eastern Clean Line and Grain Belt Express Clean Line projects, both +/- 600 kV high voltage direct current transmission projects capable of transmitting 3,500 MW from the SPP footprint to external-to-SPP sinks, in each of the ITP20 Futures 1 through 4. The objective of ITP20 is to develop an EHV backbone (345 kV and above) transmission plan for a 20-year horizon. The assessment will identify a robust transmission plan that is capable of reliably and economically providing deliverability of energy to the SPP market while enabling policy initiatives. The current ITP20 process is the second Integrated Transmission Planning Year 20 Assessment (ITP20). The assessment is conducted in accordance with the SPP Open Access Transmission Tariff (OATT) Attachment O, and the approved ITP Manual. The assessment begins in January 2012 and is scheduled to be finalized in July 2013.

Here’s that 2013 ITP 20:

2013 ITP20 Report – Southwest Power Pool

Now check out the map of their ITP20 projects in this report — do you see either the Plains & Eastern or Grain Belt mentioned above on this map:

SPP 2013 ITP20 Consolidated Portfolio 1Nope, neither do I.  I did a search of the narrative, and “Clean Line” isn’t even mentioned once!

And there are no ITP20s after that 2013 one above, either HERE on the ITP Assessments page or HERE on the ITP20 Documents page!

Oh, OK, so what about the SPP Planning and SPP’s STEP (not unlike the MTEP and RTEP!):

2015_STEP_Report

Do a search — nada… so I tried a search on “transmission” and blew up the computer.  So the search function works and in this report also, there’s no mention of Clean Line whatsoever, be it Plains & Eastern Clean Line or Grain Belt Clean Line or just plain ol’ Clean Line.

And there’s nothing here either:

2014 ITPNT Report

It’s only in the 2015 ITP10 SCOPE that there’s any mention of “Clean Line” and it’s only the Plains & Eastern Clean Line, not both, AND it’s only for sensitivity analysis.  This is not being included as a project, contemplated or promoted.

2015 ITP10 Scope Final MOPC

And in the resulting 2015 ITP10?  A mention in the list of sensitivities, and then three mentions on p. 103:

Final_2015_ITP10_Report_BOD_Approved_012715

And in the SPP 2015 Final Near Term Assessment, not a mention:

Final_2015_ITPNT_Assessment_BOD_Approved

When it comes to the scope of their next ITP10, Clean Line disappears, not even one mention, nada, again, not even an honorable mention as a “sensitivity” in the scope:

2016_ITPNT_Scope

Meanwhile, Illinois is holding “public hearings” that are very limited for what a large project this is, and very odd, considering that there are pending Motions for Reconsideration in this docket (Grain Belt Express Docket #15-0277 online at ICC’s e-docket system at www.icc.illinois.gov).

Public hearings tonight and tomorrow in Illinois:

ILL Hearings

I’d hope that Illinois, Missouri, Texas, Oklahoma, Arkansas and Tennessee pay attention to this lack of incorporation of any Clean Line project into SPP Planning!

Oh, and of course, the DOE should be paying attention!  Hey Office of Electric Deliverability and Energy Reliability, are you paying attention?

 

Here are a few comments filed, very articulate and specific reasons why the Department of Energy shouldn’t “participate” in this Section 1222 transmission project:

From BLOCK Plains & Eastern here are a few links (thanks for sending them, hard to get anything up here in the woods):

Please skip to page 264 of the PDF to read our BLOCK Plains & Eastern Clean Line: Arkansas and Oklahoma official comment:

http://www.energy.gov/…/Comment%20from%20BLOCK%20Plains%20%…

We would also like to acknowledge and thank Downwind, LLC, for formally supporting our efforts to date. They are an organization of landowners in eastern Arkansas (represented by Jordan Wimpy of Gill Ragon Owen, PA, Little Rock) that has formed in opposition to the Plains and Eastern project:

http://www.energy.gov/…/Comment%20from%20Downwind%2C%20LLC%…

Jordan Wimpy’s FANTASTIC comment on behalf of Downwind, LLC:

http://www.energy.gov/…/Comment%20from%20Downwind%2C%20LLC%…

Oklahoma Attorney General E. Scott Pruitt for his Office’s comment. The potential protection to landowners in Oklahoma, Arkansas, and Tennessee that your comment might help afford cannot be overstated:

http://www.energy.gov/…/f24/Comment%20from%20OAG%2007-13-15…

Southwest Power Resources Association lays out the MANY problems RE: liability in this project, and their comment should be read by all with an interest:

http://www.energy.gov/…/Comment%20from%20Scott%20Williams%2…

Comment from the Colorado River Energy Distributors Association (The equivalent to SPRA for the Western Area Power Association) supporting SPRA’s objections to the Project:

http://www.energy.gov/…/Comment%20from%20Leslie%20James%20o…

Will tidy this up when there’s better access.  Internet is NOT to be taken for granted, nor is cell phone access, here on the Canadian Border!  It’s the “Not-so-Great Northern Transmission Line road show.  The same DOE office is handling the GNTL project as the Plains & Eastern Clean Line, different staff, but pretty close.  The transition from D.C. to Roseau and Baudette must be a rough one!  But there’s good coffee and treats, thanks for breakfast!

20150715_094015_resized

Map

Quick — email angela.colamaria@hq.doe.gov and ask that they hold public hearings, just like they did for the environmental review!

Today is the deadline for Comments on the “Section 1222″ review, time to tell the DOE what you think of this (&($%&(#@*%&()# project!

BLOCK_Comment_Motion_FINAL

BLOCK_Comment_Attachments_A-J

Are we having fun now?

And good news today too — we’re getting some “US TOO!” support on our previously filed Petitions and Motion.  YES!  That helps!

ferclogo

After a day in the bowels of FERC’s docket system as RM15-22-000, FERC rejected the BLOCK Plains & Eastern Clean Line Petition for Rulemaking.  It’s a binary thing, has to be either one or the other, so now it’s in the DOE’s hands.

FERC REJECTION_RM15-22-000  20150625-3025(30664807)

So, DOE, what cha gonna do?  You’ve been thinking about it, but it’s been 10 years since Section 1222 was passed.

DOE_PetitionRulemaking_Attachments_FINAL

And the grand finale of the Administrative Procedure Act, Section 553:

(e) Each agency shall give an interested person the right to petition for the issuance, amendment, or repeal of a rule.

.cheeringsection

YEAAAAAA!

When filing BLOCK Plains & Eastern Clean Line: Arkansas and Oklahoma’s Petition for Rulemaking, because it doesn’t have a docket number, it’s not an existing docket, it must be filed, and then FERC staff decides whether to accept it, the next step in deciding what to do with it.  Our Petition for Rulemaking has been accepted!  Now they will have to decide what they’ll do with it!

Here’s the FERC Notice:

Acceptance for Filing ——————— The FERC Office of the Secretary has accepted the following electronic submission for filing (Acceptance for filing does not constitute approval of any application or self-certifying notice):

Accession No.: 201506165371

Docket(s) No.: RM15-22-000

Filed By: BLOCK Plains & Eastern Clean Line: Arkansas and Oklahoma -Signed By: Carol Overland F

Filing Type: Utility Accounting Request(??)

Filing Desc: Petition for Rulemaking of Regulations for Filing Applications and Review of Transmission Line Projects under Section 1222 of the Energy Policy Act of 2005 of BLOCK Plains & Eastern Clean Line under RM15-22.

Submission Date/Time: 6/16/2015 2:25:40 PM

Filed Date: 6/16/2015 2:25:40 PM

Your submission is now part of the record for the above Docket(s) and available in FERC’s eLibrary system at: http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20150616-5371

If you would like to receive e-mail notification when additional documents are added to the above docket(s), you can eSubscribe by docket at: https://ferconline.ferc.gov/eSubscription.aspx

Here are the filings (each was advised of the other Petition for Rulemaking so everyone knows):

FERC_Petition for Rulemaking_Attachments_FINAL

DOE_Petition for Rulemaking_Attachments_FINAL

Note we also filed a Petition for Rulemaking with the DOE’s Office of General Counsel.  Let them argue between themselves and figure out just who is going to do it and when and get it MOVING FORWARD!  Rulemaking is long overdue, and FYI, DOE, you have no business making any decision, doing any review, without rules.