FERCenese and FRICL

“If it looks like a duck, and quacks like a duck, we have at least to consider the possibility that we have a small aquatic bird of the family anatidae on our hands.”  --Douglas Adams

I don’t know what it is.  Maybe living under powerlines all your life affects the brain.  Maybe the brain is slowly destroyed from working inside the D.C. Beltway, but who writes like Jimmy Glotfelty of Clean Line Energy did in 2009?

Whichever approach is taken, the Commission should ensure that the manner in which these projects are incorporated takes due account of the differences between merchant and participant-funded transmission projects, on the one hand, and transmission upgrades that are included in the rates paid by captive transmission customers, on the other hand. Where an independent developer of a merchant or participant-funded transmission project is willing to assume the financial risks of the project, the planning process does not need to consider whether transmission customers are being asked to pay for transmission facilities that may not be necessary in the relevant planning horizon. Instead, the planning process should focus on ensuring that the project can be safely, securely, and reliably interconnected with the transmission system. The planning process should also recognize that flows over a transmission project that uses HVDC technology to facilitate long-distance transmission of renewable energy are physically separate from the AC transmission systems to which it interconnects. Such projects should not be studied as though they are AC projects that necessarily have far more variable effects on existing AC transmission facilities.

I read and reread that paragraph from Clean Line until it started to hurt.  Perhaps dissecting it word by word would help.  Nope.   Maybe this paragraph needs dissecting each sentence to the  subject, verb, predicate, and all that.  Seriously, who writes like this?  D.C. lawyers perhaps.  Plain English is much nicer to read than FERCenese.  I finally had to phone a friend.  Keryn was a help interpretating  Jimmy’s FERCenese.    Maybe someday, I’ll be able to read FERCenese better, but I don’t think I’ll ever be able to write in this sub-dialect of the English language

What we think Jimmy Glotfelty is saying in October 2009 before Order 1000 and under Order 890 is that RICL and its sisters are not "needed" in a traditional sense.  It also makes much of the fact that their HVDC projects do not connect into the AC system like other AC lines do so therefore, any study undertaken by a RTO should be nothing more than minimal.  He wants to be included in regional planning, but doesn't want to be held to the same standards that everyone else is.  

This was written in 2009 before FERC Order No. 1000 was handed down from the mountain top.  Clean Line was making an argument that current regulations shouldn’t apply to them because they are “Merchant Transmission Line”, and as such, relevance and need should not matter.   Clean Line projects should not be considered in the relevant planning horizons. Only safety, security, and reliability should be considered when reviewing a merchant line because merchant line accepts the risk and rewards.

Today we have Clean Line saying that their HVDC projects will provide regional reliability benefits as a way of having a portion of RICL construction costs allocated to captive ratepayers. Clean Line is protesting PJM because they are not included in the Regional Transmission Expansion Plan.    So in 2009 RICL doesn’t want to be considered a part of a regional transmission plan because it is a Merchant Transmission Line.  It was probably easier to gain FERC approval if relevance and benefit was not considered to closely.   Today Clean Line thinks it deserves to be a part of a regional transmission plan because it wants cost allocation from captive customers.  

http://elibrary.ferc.gov/idmws/common/OpenNat.asp?fileID=13128021

This could put Clean Line in a precarious position as the Illinois Commerce Commission is attempting to determine the company’s relevance and benefit.  When Clean Line tells FERC in 2009 relevance is irrelevant, how do you come back and tell the ICC the Rock Island Clean Line is both relevant and beneficial to the state?  I guess when you change the rules as you go anything is possible.

To put in plainer English without the FERenese, Clean Line is being a childish playground bully who constantly wants the rules to the game changed in their favor.   They wanted less oversite as a Merchant Transmission Line.  Now they are crying to FERC that PJM is not treating the same as Ameren and Mid American Energy.  This is absurdly ridiculous or maybe another Douglas Adam’s quote applies to Jimmy Glotfelty’s logic

. 

He was a dreamer, a thinker, a speculative philosopher... or, as his wife would have it, an idiot.

Back in 2009 someone did have the basic foresite to call the current situation correctly.  The Organization of MISO States (OMS) explained the importance of state regulators and their ability to handle these problems and challenges on the state level. 

http://www.misostates.org/files/FERC/2009/OMSResponsesOrder89023NOv2009.pdf

The OMS cautions, however, that in its efforts to facilitate transmission investment, the Commission should not abandon principles that have served the industry well for decades.  Given the high stakes for the nation in effective energy policy, the Commission must ensure that the processes being developed for regional and inter-regional transmission planning and the practices for transmission cost allocation provide for the nation’s future energy needs, while

recognizing individual states’ interests in ensuring the reliable service to retail customers at reasonable rates.

If the ongoing regional and inter-regional grassroots efforts to develop policy solutions are able to produce broad consensus, or at least a common understanding regarding solutions, such solutions would create a strong foundation of industry certainty that would likely have more permanence than federally imposed solutions.

Well said OMS!  Let issues be worked out by the states and not the federal government.  The states look at all the concerns better and keep focused on economically priced energy rather than taking the “We’re from the federal government and we’re here to “help” by taking over with centralized playing” approach.   While the current proposal by OMS scares me, they predicted the problems a poorly written Order No. 1000 would create.

Then again, maybe FERC Order No. 1000 wasn’t written out of arrogance and a desire for federal power.  Maybe there was some good intention.  Maybe one more Douglas Adams quote applies to Order No. 1000 and its creators.

"He attacked everything in life with a mix of extraordinary genius and naive incompetence, and it was often difficult to tell which was which."