Graphic3

Dairyland Power Cooperative’s transmission through Onalaska and La Crosse is something to see…

Dairyland Power Cooperative and USDA’s Rural Utilities Service has released the “Q-1D South” Environmental Assessment, open for Comment until July 1, 2016:

Q1-South_Environmental Assessment (BIG FILE)

And from Dairyland’s site:

Briggs Road to La Crosse Tap (Q-1D South) – Environmental Assessment

Comments are due July 1, 2016 — send to:

USDA’s Dennis Rankin:  dennis.rankin@wdc.usda.gov

(I’d also cc DPC’s Chuck Thompson:  cat@dairynet.com)

By U.S. Mail:

Dennis Rankin

Environmental Protection Specialist

USDA Rural Utilities Service

1400 Independence Avenue S.W.

Mailstop 1571, Room 2242

Washington, DC  20250-1571

What’s to comment on?  I see two issues that should be sufficient to stop this project in its tracks — the debt load of Dairyland Power Cooperative and the physical setting of the project which too near and right over people’s homes.

Debt load — Dairyland Power Cooperative’s debt is excessive and should prohibit taking on more debt:

Dairyland Power Cooperative’s Annual Meeting was last week.  One purpose of an organization’s Annual Meeting is to discuss its financial status and approve plans going forward.

Dairyland depends on federal USDA/RUS loans to pay for its transmission expansion, such as the Q-1 transmission upgrades, including Marshland-Briggs Road and now the stretch from Briggs Road to North La Crosse south of I-90. Another USDA/RUS loan paid for Dairyland’s share of the CapX La Crosse line now blighting the bluffs. Dairyland will also be part owner of the MISO Hickory Creek to Cardinal line from Iowa to Madison. That’s a lot of transmission and loans.

Dairyland recognized this financial risk and lopsided debt/equity position, and in 2012 sought help from FERC_(DPC_Request4DeclaratoryOrder), requesting a hypothetical capital structure of 35 percent equity and 65 percent debt when its actual capital structure was 16.5 percent equity and 83.5 percent debt, and FERC did grant this relief in an Order for DPC for CapX 2020 (see FERC Docket, go HERE and plug in docket EL13-19-000).  That Order, and the 83.5/16.5% debt/equity ratio was prior to the present Q-1 D South project and the MISO MVP Hickory Creek to Cardinal transmission line.  Dairyland requested a “hypothetical” (bogus) debt/equity ratio to preserve its credit rating and enable low cost loans. The true debt level makes DPC a higher risk.

Are Dairyland members aware of the 83.5%/16.5 % debt/equity ratio and reliance on loans for major transmission projects? What’s the debt level where new projects are included? This new transmission enables increased power marketing and sales, a private purpose. Is this highly leveraged position for new transmission in the best interests of Cooperative members?

Physical setting of the project — it’s just too close!

The map way above is what the transmission system in the area looks like theoretically, according to the Wisconsin Public Service Commission, but here’s what Dairyland’s Q-1 South line looks like on the ground:

Ulman_St[1]

Really… Here’s what it looks like from a satellite with the lines drawn in, on the far south:

End of the Line

Here’s what it looks like further north — look at all those homes:

Sheet Map 3

And here’s what the Wisconsin PSC Code says about clearances in PSCW 114.234:

(2) Transmission lines over dwelling units. [Follows NESC 234C1b, p. 119] (Addition) Add the following paragraph c:
c. Transmission lines over dwelling units.
No utility may construct conductors of supply lines designed to operate at voltages in excess of 35 kV over any portion of a dwelling unit. This provision also applies to line conductors in their wind-displaced position as defined in Rule 234A2.
Note: It is the intent under s. SPS 316.225(6) that the public not construct any portion of a dwelling unit under such lines.
Note: The term “dwelling unit” has the meaning given in ch. SPS 316, which adopts by reference the definitions in NEC-2008.
Note: See s. SPS 316.225(6) Clearance Over Buildings and Other Structures, which refers to ch. PSC 114 regarding clearance of conductors over 600 volts and the prohibition of dwellings under or near overhead lines.
So look what Dairyland says about these clearance problems, first on page 3-3 of the Q1-South_Environmental Assessment in its discussion of alternatives, specifically joining with Xcel Energy, which has a similar line right through the community over homes and through yards on the other side of the highway:
p23
Though there’s no case law about this, Dairyland states, “This provision likely applies to Xcel as a public utility but not DPC as a cooperative.”  That’s pretty presumptive, with no basis for the presumption, DPC!  And they wiggle around again, claiming the code doesn’t apply to them 10 pages later:
[33_1p33_2
Do you buy that argument???  First, they don’t even cite the correct PSCW section, using “PSCW 114.234(a)(4)” rather than PSCW 114.234(a)(2).  Note they state that “public utilities may seek waivers of any rule expanding upon NESC requirements…”  But if they’re saying the code doesn’t apply to them, why would this apply to them and they can seek a waiver?  Under their argument that the PSC Code doesn’t apply to them because they’re a cooperative, then if that applied, then this would not apply to them either.  Or is it the opposite, that the Code does apply to them, they cannot rebuild the line under  and have to apply for a waiver to the PSC?  Which is it, Dairyland?  Oh, but wait, I thought part of why you’re doing it the way you are, applying to local governments, in this short segmented version of your Q-1 line, was that you don’t want to have to go to the PSC, that you’re trying to get around it…
Segments
Segmenting, particularly segmenting to avoid environmental review, is not OK, Dairyland…
Remember, comments are due July 1, 2016 — send to:

USDA’s Dennis Rankin:  dennis.rankin@wdc.usda.gov

(I’d also cc DPC’s Chuck Thompson:  cat@dairynet.com)

By U.S. Mail:

Dennis Rankin

Environmental Protection Specialist

USDA Rural Utilities Service

1400 Independence Avenue S.W.

Mailstop 1571, Room 2242

Washington, DC  20250-1571

gavel

WOW… can you believe??  It’s not just me, it’s not just denial of Intervention of No CapX 2020.  See 20162-118122-01_Denial2_Overland-NoCapX Intervention.

Intervention as a party in this Rate Case is only open to those who sold out to Xcel Energy and it’s “business plan” agenda of e21.

This is the most recent Order in the Xcel Energy Rate Case:

Order Denying Intervention – SunShare & ILSR

Here are their Intervention Petitions:

ILSR_Intervention_20164-120145-01

SunShare_Intervention_20164-120144-01

To see the full Rate Case docket, go to the PUC’s Search Documents page, and search for Docket 15-826.

And the Order… Dig this, parroting Xcel’s objections:

Order1

And this, even worse, as if the interests of the “Clean Energy Organizations” who bought into, stumped for, and sat quietly during the legislative hearings about Xcel Energy‘s e21 Initiative are the same as the interests of SunShare and Institute for Local Self-Reliance – ILSR:

Order2

This is SO offensive.  There is no consideration that the perspectives are different, only statements that the issues, the concerns, are the same.

The late, great Myer Shark, rate case Intervenor extraordinaire, would spin in his grave at the limitations of participation in this rate case.

Myer Shark, Lawyer Who Fought Utility, Is Dead at 94

In the Matter of the Complaint by Myer Shark, et al …

USSupreme-Court

Here’s an interesting case (oh, how I hate that word “interesting”).  It’s about whether a state can offer “incentives” over and above FERC wholesale electric rates that would incentivize construction of new in-state generation.  US SCt says NO!  The states can only regulate retail rates.

Hughes v Talen Energy Marketing_14-614 April 19, 2016

This is a case regarding Maryland “incentives” and PJM, but it’s applicable to our good friends at MISO too.

So do tell, what does this mean for FERC set rates of recovery and cost allocation for all this transmission to enable the wholesale market?  What happens when FERC rates stick their nose under the tent in state rate proceedings, i.e., Schedule 26A covering return and cost allocation for these big transmission projects we know and love?  From what I can see of Schedule 26A, they’re allocating a “retail share” and, well, what business does FERC, via MISO (in this area), have with retail rates?

Transmission Rate Information

Schedule 26A – Indicative Rate Charges MISO (last updated 3/31/2016)

Look at all the ways we’re charged for transmission:

Transmission Pricing – MISO

 

cheeringsection2

 

ows_145818241516183-AP Photo SethPeriman

AP Photo – Seth Periman

There’s a good editorial in the STrib today about Donald Drumpf’s abject incompetence and nailing journalists for not reporting it, not holding him accountable, not exposing it, and the bottom line:

But the media in general haven’t really made enough of it. Journalists are quick to accuse him of bullying and bigotry (and rightly so), but he’s rarely called grossly incompetent for his basic factual understanding of the world, or even called out on his inability to speak coherently.

Here’s the full OpEd:

The scariest thing about Trump is his incoherent gibberish.

This headline puts it well, and “incoherent gibberish” is exactly the sort of thing we often heard from Sarah Palin.  It is just bunches of words, often code words a la Wallace’s hate speech, puked out and strung together, and it does not make any sense.  Read it.  Worse, read it out loud!

What does it mean when there’s such strong support for someone who cannot even speak sufficiently well to communicate a coherent thought?  What does this say about his thought process if this is what comes out?  And what does it say about media, where reporters do not raise their eyebrows, screw up their snouts, and say, “WHAT?”  “What did you say?”  “What do you mean?”  “What you said makes no sense, what are you trying to say?”  “What on earth are you talking about?”

Here’s the transcript of his meeting with the Washington Post editorial board, something that I want to preserve in case they disappear it, it’s that _________ (scary?  mind boggling?  bizarre?  inexplicable?).

A transcript of Donald Trump’s meeting with The Washington Post editorial board – The Washington Post

I’m confident that he will not be elected President, one way or another, but that he is regarded as a contender, and that he is commanding so much of our country’s collective time, OH MY DOG!

Trump&Clintons