ITC MVP Study 3

This week we have three days of DEIS meetings, that’s Draft Environmental Impact Statement for the uninitiated.  The schedule:

Tuesday, April 22, 2014
1:00 p.m. and 6:00 p.m.
Knights of Columbus Hall
920 East 10th Street
Fairmont, MN 56031
Wednesday, April 23, 2014
1:00 p.m. and 6:00 p.m.
National Guard Armory
108 County Road 51
Jackson, MN 56143
Blue Earth
Thursday, April 24, 2014
1:00 p.m. and 6:00 p.m.
Hamilton Hall
209 South Main Street
Blue Earth, MN 56013

This project is important because, well, look at the red line in the map above that represents this project.  It connects on the west to the Split Rock-Lakefield Jct. line from a decade ago, and then goes east, and drops down into Iowa, to become part of a web headed toward Chicago.  The red and green on that map constitute MISO designated MVP3, and to the east, the orange and blue are MVP 4, and further to the east, 1/2 of which is Badger Coulee, is MVP 5.  Important to note that there are 17 MVP projects, and all 17 must be built to offer the benefits touted, the modeling included all 17.  Not only that, but cost apportionment also included costs to states beyond just the percentage of the one project under review, i.e., there are claims of benefits of MVP 3, but those benefits require MVP 4 and MVP 5, and in fact, ALL the 17 MVP projects.  Costs to Minnesota ratepayers are “just” a portion of MVP 3, but there are also costs to Minnesota of MVP 4, MVP 5, and I think ALL of the 17 MVP projects.  So the benefits that are reliant on all the 17 projects being built must be balanced against the costs attributable to Minnesota for all 17 projects!  See, that wasn’t so hard, was it!

Here’s the DEIS from the Commerce ITC MN/IA DEIS page, it’s easier to cut and paste, though it’s a good idea to download because you never know when links will be changed or disappear:

Draft Environmental Impact Statement Text





Judge Susan Richard Nelson issued an order yesterday declaring Minnesota’s Next Generation Energy Act unconstitutional because it “constitutes impermissible extraterritorial legislation and is a per se violation of the dormant Commerce Clause.”

I finally found a copy of the decision, I was looking in all the wrong places.  Here’s the Order (thanks to the STrib for posting it):

April 18 2014 Order – Next Generation Energy Act Suit Minn. Stat. 216H.03

It’ll likely be appealed, but I wouldn’t bet on any success.  The impact of this decision will be what I’ve been expecting — dreadful — the doors are open for even more coal plants (note the discussion of surplus capacity in the decision) and with CapX mostly built, we’ve got the infrastructure for 50+ years of coal generated electricity exports across Minnesota to market, and 50+ years of mercury for our fish, and all those emissions for us to breathe.  Great, just great.



This is the Hollydale Project proposed route, the one that Xcel Energy couldn’t demonstrate need for if their Certificate of Need depended on it, and it did, and they didn’t.  Hence their petition to the Minnesota Public Utilities Commission for withdrawal of Applications for both their Certificate of Need (12-113) and their Routing Permit (11-152).  I love it when that happens…

This was a great victory to get Xcel to acknowledge that this project was in trouble, that they couldn’t demonstrate need, not that they admitted it outright, but close enough.  The down side is that they are persistent, and when they want something, they keep trying, sometimes the same thing, sometimes something different.  What will they do here?  Who knows, but I doubt they’ll disappear.

There was a surprise filing letter and proposed decision option sent by Paula Maccabee on behalf of WPNA at 8:37 a.m., less than an hour before the meeting began, and half an  hour after we’d already left for St. Paul, first I learned of it was when it was passed out at the meeting.

WPNA Decision Recommendations

Here are the changes that were requested:

D. Future Filing Requirements

2. Require the company to file a discussion on their public outreach efforts and an update on improvements made to the load serving capacity of the distribution system serving the area six months from the date of the order granting withdrawal and quarterly thereafter.

I don’t get it… why?  And no, that doesn’t work.  Where Xcel is saying they’ll be back, after developing a more palatable option through discussions with stakeholders, why eliminate the disclosure of its “public outreach efforts?   Thankfully, this was not adopted.

From Xcel’s filings, it’s clear that the Hollydale Project is “desired,” strongly desired, despite that it’s not “needed” in any criteria-based sense.  Xcel wants this project so badly that it has stated that if permitted to withdraw this application, it is coming back, and that:

The residents of Plymouth and Medina, as well as other key stakeholders, have expressed serious concerns about the potential impacts of this Project…

… that “it may take some time to collaborate with stakeholders on developing a new solution…”     

… and that it “intends to work with the community and stakeholders on developing a more widely supported electrical solution…”

Withdrawal Comments January 29, 2014

Xcel Reply Comments February 19, 2014

Those words get me more than a little concerned, particularly where at a meeting organized by Commerce at Plymouth City Hall, after we’d gone around the room in introductions, Sen. Bonhoff said, very pointedly to me, “Who are you?”  “Why are you here?”  “Who is the Barry Family?”  I got the idea that she though I shouldn’t be there, that it was to be a more private party, and I shouldn’t have been invited.  And yesterday, a woman present in support of WPNA asked the same questions.  Hmmmm… Oh well.  We’re parties to this party!

This Hollydale Project was an odd project, in ways that weren’t fully addressed in the proceeding:

  • First is the inherent legal definition of transmission – this project, as proposed, would change this line from a relatively unregulated 69 kV line to a highly regulated “High Voltage Transmission Line” as defined in statute.
  • The project as proposed represents a significant physical and electrical change, from an inactive 69 kV line to a high capacity HTVL that is an operating part of the grid.
  • This project would require a change in ownership – Xcel is requesting to buy the easement, gain the powers that ownership of easement interests represents, and planned to use the easement to build a line of a very different character than what was built under the original easement.
  • This project would change the purpose of the line through Plymouth and Medina, from a purpose of rare emergency backup for the local distribution system, to a high capacity grid support for the 345 kV system.

Now the application has been withdrawn.  Xcel says it’s going to work collaboratively to come up with a “new solution.”  Let’s see what happens next!

Xcel’s request for withdrawal of its Hollydale Transmission Project Certificate of Need and Route Permit Application is before the Minnesota Public Utilities Commission tomorrow.  We’re 4th on the agenda.  Come on down, or watch it live!

Live Webcast

Public Utilities Commission Meeting
PUC Large Meeting Room
121 7th Place East, Suite 350
St. Paul, MN


And look how a decision came down in Chino, California!  There was a transmission line through the community for a long, long time, and it was “inactive” for a long, long time.  Then one day, the utility started taking down the towers that weren’t being used, and stuck new bigger ones in their place.  Thankfully, the story didn’t end there — they had to take the poles down and underground that transmission line:

Chino Hills wins battle against So Cal Edison


Here’s the Chino Hills group’s website:

Hope for the Hills


No, unfortunately it is NOT about the beer.  The Grain Belt Express Transmission Line is moving forward, now in Missouri.  Yesterday they filed their “application” and I’ve never seen anything so light on substance.  But there’s more… A big pile o’ testimony was filed yesterday, and today there’s the first prehearing order, setting an intervention deadline of April 25, 2014.


Missouri Public Service Commission Code of State Regulations

Missouri CSR – Chapter 2 – Practice and Procedure

Missouri CSR – Chapter 3 – Filing and Reporting Requirements

Missouri CSR – Chapter 4 – Code of Conduct (i.e., ex parte!)

To keep up with the docket CLICK HERE and plug in “EA-2014-0207″ and you’ll get all the filings — here’s what’s been filed thus far:

Item No.

Date Filed

Title of Filing

Filed on Behalf Of

14 3/27/2014 Order Directing Notice, Setting Intervention Deadline, and Directing Filing of Staff Recommendation Commission-(All)
13 3/26/2014 Direct Testimony of Robert M. Zavadil Grain Belt Express Clean Line, LLC-(Electric)
12 3/26/2014 Direct Testimony of Michael P. Skelly Grain Belt Express Clean Line, LLC-(Electric)
11 3/26/2014 Direct Testimony of Gary Moland Grain Belt Express Clean Line, LLC-(Electric)
10 3/26/2014 Direct Testimony of Dr. David G. Loomis Grain Belt Express Clean Line, LLC-(Electric)
9 3/26/2014 Direct Testimony of Mark O. Lawlor Grain Belt Express Clean Line, LLC-(Electric)
8 3/26/2014 Direct Testimony of Timothy B. Gaul Grain Belt Express Clean Line, LLC-(Electric)
7 3/26/2014 Direct Testimony of Dr. Anthony Wayne Galli Grain Belt Express Clean Line, LLC-(Electric)
6 3/26/2014 Direct Testimony of David Berry Grain Belt Express Clean Line, LLC-(Electric)
5 3/26/2014 Application of Grain Belt Express Clean Line LLC for a Certificate of Convenience and Necessity Grain Belt Express Clean Line, LLC-(Electric)
4 2/25/2014 Order Granting Leave To Withdraw As Counsel Commission-(All)
3 2/25/2014 Notice of Withdrawal Grain Belt Express Clean Line, LLC-(Electric)
2 2/25/2014 Entry of Appearance Grain Belt Express Clean Line, LLC-(Electric)
1 1/13/2014 Grain Belt Express Clean Line LLC Notice of Intended Case Filing Grain Belt Express Clean Line, LLC-(Electric)