Legalectric

Map from Comparative Environmental Assessment(click for larger version)

Heads up — there will be a public hearing about this line some time in the future, I’d expect before year end, but who knows…  Will find out and post here, and until then, here’s the “target” schedule (click for larger view):

In the meantime, the Draft Comparative Environmental Analysis has been released for the MERC natural gas pipeline around the south and west side of Rochester, yes, a CEA, the environmental review document tossed out in the Sandpiper Appellate Decision OPA150016-091415.

How did I miss this?  I see I’m not on the service list — anyone who comments should be.  And I know I went to the meeting and handed in comments, and eFiled as well:RRRRRRRRRR. I have two major concerns.  First, hiding the RPU gas plant that this will service; second, that if this pipeline goes in, how close will it be to existing development and will the local governments permit development over and next to this gas pipeline, as has been done in Kasson and Byron, to name a few.  This is a serious problem and they’d better consider it.

Documents I’d entered in support of Comments at the Scoping meeting back in February:

Sandpiper Appellate Decision-CEA_20165-120948-01 (filed multiple times, ???)

RPU_2012 Infrastructure Update_2012  20164-120802-01

RPU chooses Boldt to build new $62 million power plant 20164-120796-01

Safe separation distances from natural gas transmission pipelines_20164-120797-01

A model for sizing high consequence areas with natural gas pipelines_20164-120800-01

Anyway, looking at the public comments regarding the CEA, PUBLIC COMMENTS HERE, I see that yes, they’re planning on routing this through an area that’s going to be a subdivision, now in the permitting process.  The developers have raised concerns.  ???  There should be awareness that platting over a pipeline is a major liability exposure for the permit granting jurisdiciton and whoever builds next to a pipeline, what with such broad burn zones.  Once more with feeling:

• Model for Sizing High Consequence Areas Associated With Natural Gas Pipelines
• Safe Separation Distances From Natural Gas Pipelines

This MERC pipeline is to support the natural gas plant on the west side of town, and as I’d noted before in an earlier post, with some links to primary documents:

First they brought it up at Rochester Public Utilities Board meetings over the summer [2015]:

PUB- Resolution 4315 – Resolution: West Side Energy Station

Westside Energy Station Epc – Bids in Minnesota

And finally, last week, RPU made it’s plans to add new natural gas generation VERY public:

A New Generating Station for Rochester

Back in that CapX 2020 Certificate of Need proceeding (PUC Docket 06-1115) it was an issue because the “need” used to justify CapX 2020 transmission to Rochester was so very small that it could be met with this RPU planned natural gas plant.  Here’s what I wrote in the 2008 No CapX 2020 Initial Brief:

Most importantly, the need is overstated. In addition to modeling performed with all local generation off line, infrastructure planned was not considered. For example, in Rochester, there are FOUR 161kV lines planned that were not taken into consideration, and which could well serve Rochester’s needs. In addition, RPU, the Rochester utility, has planned for new generation at the West Side substation (Ex. 100, lower left corner), where two of those four lines will be connection to serve Rochester. Ex. 157, Report on the Electric Utility Baseline Strategy for 2005-2030 Electric Infrastructure, June 2005, Summary p. S-21-S-22. Specifically, this report recommends actions that have been taken by RPU, resulting in the Westside Substation and transmission from it to serve the city:

Consider taking options on approximately 100 acres of land within the RPU service territory near a high pressure gas line and transmission facilities under RPU control for installation of future combustion turbine capacity.

…Around 2014, assuming that new generation is required in accordance with the long range plan and that generation has not been installed in connection with the transmission issue, begin the process for installation of approximately 50-100MW of natural gas-fired generation for an inservice date of 2018. The generation should be low capital cost with as low an operating cost as is consistent with expected operating capacity factors.  Id.

Local load as a reason for CapX is not supported by the evidence. The need, even if assumed, can be met in other ways, and these small amounts, if assumed in its entirety, cannot justify a project of this size.