There are a few more hearings for Xcel Energy’s rate case coming up:

RemainingHearings

Who cares about this rate case?  Center for American Experiment does, but it’s a pretty myopic view, claiming that “Renewable Mandate Drives New Increase in Utility Bills.”  Wish they’d read the testimony.  Anyway, you all should care because this is a transmission driven rate case (see 2A2_MYRP_Chuck Burdick Testimony p. 28-30; 2C2_Xmsn_Benson)     Greasing the skids was a consensus agreement reached by Xcel Energy  on many issues, including Xcel’s proposal for a “Multi-Year Rate” plan prior to legislation being introduced to give Xcel what it wanted:

Exhibit 1B – e21_Initiative_Phase_I_Report_2014 – Xcel Filing PUC Docket 14-1055

Note this snippet, where they’re whining that their grid is only 55% utilized:

(N) Identify and develop opportunities to reduce customer costs by improving overall grid efficiency.  In Minnesota, the total electric system utilization is approximately 55 percent (average demand divided by peak demand), thus providing an opportunity to reduce system costs by better utilizing existing system assets (e.g., generation, wires, etc.). (e21_Initiative_Phase_I_Report, p. 11).

Well, DOH, we know that CapX 2020 wasn’t needed, we know the purpose was evident in the map starting at the Dakota coal fields, and putting it on our land wasn’t enough (for those who think it’s “for wind” no, it’s not, what a crock, you should have heard the testimony, seen the exhibits, the record demonstrates it isn’t, www.nocapx2020.info), now they want a whole new scheme for us to pay for their infrastructure to sell coal eastward?

CapXFor some reason, this docket disappeared… wonder who all on this consensus e21_Initiative_Phase_I_Report made that happen!?!

e21ParticipantsOr maybe the e21 Project Team?

e21ProjectTeamDoes anyone else care that Matt Schuerger, most recent Dayton appointee to the Public Utilities Commission, was instrumental in working the e21 scam?  Shouldn’t he have to recuse himself from any consideration of Xcel Energy’s e21 Initiative rate case?

And look at Bill Grant’s role in e21.  He’s now Deputy Commissioner at Commerce in charge of energy issues, and was for 20+ years head of Midwest Izaak Walton League (working over then employee Beth Solholt and IWLA employee, now PUC Commissioner, Nancy Lange).  Given Nancy Lange’s role in e21, she should also recuse herself.

And then there’s Mikey Bull’s role, as he recounts, and look who all is involved:

The e21 Initiative started as little more than a glimmer in my eye a couple of years ago, when I was a Manager of Policy and Strategy for Xcel Energy.  I’d just come back from a meeting at the Edison Electric Institute about the impact of various dynamics – low load growth, increasing infrastructure investments, deeper penetrations of distributed resources – on the current utility business model. In general, rates were going to rise under the current model far faster as a result of those forces, and utility revenues become more uncertain.

Those dynamics were later chronicled in the Disruptive Challenges report issued by the Edison Electric Institute in January 2013. I realized that it was important for Xcel to try and get out ahead of the curve.

So I reached out from Xcel to Rolf Nordstrom at the Great Plains Institute and Nancy Lange then at CEE (now a Minnesota PUC commissioner), to start putting the e21 project together. Rolf and I worked to put a strong core project team together – CEE, Great Plains, Xcel Energy, Minnesota Power, George Washington University Law School and consultant Matt Schuerger. We then compiled a terrific group of stakeholders who together represent much of what constitutes the public interest – low income customer advocates, small and large business representatives, utilities, environmental organization, cities and other public entities, and regulators. Beginning last February, this group of 25-30 stakeholders met monthly for day-long sessions that were wonderfully facilitated by Rolf and Jennifer Christenson, his colleague at GPI, toiling together deep in the weeds of utility regulation.
It was an honor to work with all of them, as we coalesced around the set of consensus recommendations detailed in the report.

Here’s the full recap:

e21_MikeBull_Center for Energy and Environment

wallstreetbull2

The legislation, SF1735, well, check the links below, and you can see how that went down.  I was there, seeing is believing.  First it was introduced, but despite the full room of SILENT “usual suspects” who had acquiesced to e21, and only a couple of us objecting to the bill, Sen. John Marty pulled it from consideration, initially on the Senate Energy and Environment Committee same days as legislative extension of the Getty and Black Oak wind contracts (the project couldn’t do it before the PUC so they go to the legislature), stuck in a placeholder “e21 Lite” and then put it in later as part of the Energy Ominous Bill, SF 1431:

These issues were raised, e21 marches onward, and here we are, in a rate case.

 

 

RateCase_MankatoHearing

Last night there was a hearing in Mankato on the Xcel Energy rate case (Docket E002/GR-15-826).  Public participation in Public Utilities Commission dockets is supposed to be a happenin’ thang…   But there were no witnesses to question yesterday at the public hearing, and the Xcel representative who was there could not answer questions.  Worse, there was no commitment to have witnesses available to the public at the public hearings, and only advice that the public could attend the evidentiary hearing.  ATTEND?!?  When might we be able to question witnesses?

Sent this Data Practices Act Request this morning to round up the Information Requests and Responses regarding transmission, transmission riders, MISO and FERC:

Data Practices Act Request

Xcel Energy wants to shift its transmission rate recovery from CWIP and AFUDC to general rates, but there was no one there to talk about it.  These are the MVP projects at issue, in Schedule 26A, below, which are worked into MISO tariff and FERC blessed:

MVP ProjectsAnd here’s the projects in Schedule 26, below, but hmmmm, no project costs shown (click for larger view):

Sched 26I entered these exhibits:

Exhibit 1A – XcelCover_e21_Request for Planning Meeting and Dialogue – PUC Docket 14-1055

Exhibit 1B – e21_Initiative_Phase_I_Report_2014 – Xcel Filing PUC Docket 14-1055

Exhibit 2_MISO Schedule 26A Indicative Annual Charges_02262014

Exhibit 3 – FERC EL-14-12-002_ALJ Order – ROE on MISO Transmission

Next meeting I’ll have some more:

e21_MikeBull_Center for Energy and Environment

MISO Schedule 26 Indicative Annual Charges

1Q_Earnings Release Presentation_5-9-2016_1500085150

Investor Presentation – NYC-Boston_3-1-2=16_1001207698

Investor Presentation – NYInvestorMtgs_5-10-2016_1500085349

2015 10K – Xcel Energy

2015 10K – NSP

Back to last night’s hearing…

Check the rules about public participation:

1400.6200 INTERVENTION IN PROCEEDINGS AS PARTY.

Subp. 5.  Participation by public.

The judge may, in the absence of a petition to intervene, nevertheless hear the testimony and receive exhibits from any person at the hearing, or allow a person to note that person’s appearance, or allow a person to question witnesses, but no person shall become, or be deemed to have become, a party by reason of such participation. Persons offering testimony or exhibits may be questioned by parties to the proceeding.

Another, the PUC practice rules:

And yet another:

And this one (though they’ll say it isn’t applicable because a rate case isn’t part o the Power Plant Siting Act):

What about the mediation next week?  How is the public interest represented?
PublicHearingSchedule

Graphic3
Time for a nap.  Just filed Comments on the USDA RUS’s Environmental Assessment for Dairyland’s Q-1 D South transmission line.  Here’s the EA:

Q1-South_Environmental Assessment

And here are the Comments I filed on behalf of No CapX 2020:

No CapX 2020 EA Comment_July 1, 2016

zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz

Oh, and the interesting thing is that just this morning, I got a copy of the “Briggs Road-La Crosse Tap 161 kV Rebuild Study”  Thank you, Chuck Thompson!

 

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

SystemIntact

Remember Xcel Energy’s Hollydale Transmission Project that was derailed when it was clear it wasn’t needed, and so Xcel Energy withdrew the application with regular compliance reports on status of the project, and a promise of a need study so long ago???

Yeah, I’ve been forgetting too, it’s been so long.  Here’s Xcel Energy’s page on what’s now called the “Plymouth Project.”

But, here it is!!  Finally, it has arrived, the Hollydale System Assessment Report from Xcel Energy that we’ve all been waiting for:

Plymouth_and_Medina_Electrical_System_Assessment-Final_Complete

Pay particular attention to the map above of the “study area,” and note that it is the Interstate 494/694 ring and Hwy 55 to the east and north where the problems are, and the problems are yellow and orange, and not red.  The problems are not in the area of the Hollydale substation and not to the west, towards Medina.

When do we start seeing problems?  Looks like it’s in 2036, 20 years from now, double the usual 10 year transmission planning outlook (hint, that means it STILL is not needed) — and note, again, the problems are to the east and north, along the highways:

2036SystemIntact

I’ve got to scour this report, but I do not think that they’ve considered select placement of distributed generation, i.e., solar panels on all the big boxes in the areas above in red!  Or residential solar on those in yellow.  What’s so difficult about that?

Here’s their choice:

FavoriteAlternativeCOn the plus side, there’s new substations planned in the red territory.  On the minus side, they still want to utilize the Hollydale substation.  On the plus side, they plan to expand transmission using 34.5 feeders, which is what I promoted as a solution.  On the minus side, they plan to keep the 69 kV line through Plymouth, with an eye on utilizing it in the future.  On the PLUS side, they claim that there’s no impact on the Hollydale – Medina section of the 69 kV line, claim that there’s no change from present use and non-use, and for my clients in Medina, that’s a good thing.  On the MINUS side, they don’t propose to tear that “unused” 69 kV line down.  On the MINUS side, they don’t propose to put all the transmission and distribution underground.  And remember, just yesterday, when there was a large distribution outage due to wind out in the western suburbs?

So now, it’s time to read this report!