Legalectric

Here we go, the Initial Comments on the Iron Range-St. Louis County-Arrowhead transmission project:

Fresh Energy says:

Now that Fresh Energy’s Michael Noble and Allen Gleckner are stumping for Google, I wonder if they’d say that under oath!?!?!

What money can buy… June 21st, 2026

Will add Comments from others if/when they’re filed.

Reports are disappearing, like the WRAO report, and the WIREs Phase II and Appendices below, so here they are for posterity! These Meta boxes are really irritating, I deleted from the upload, but they reappear. To get rid of them, click the grey thing in the upper left:

Lindsey says, “Hold my beer…”

Lindsey Graham, longtime GOP senator and Trump ally, dies at 71 after sudden illness

Here it is, the latest “transmission needs study” from the DOE:

The 60-day Public Comment and Consultation Period closes on September 7, 2026.

Send comments on the Needs Study to NeedsStudy.Comments@hq.doe.gov.

Yesterday’s Public Utilities Commission meeting was a cluster. At issue were Objections to the Commission’s Environmental Report Scoping Decision:

Alternatives analysis is crucial, because system alternatives may only get into the record in a Certificate of Need proceeding, and not routing. Turned out that yesterday’s debate was about alternatives, and a requirement that an alternative have support of “sufficient information” and that meets Applicants’ “stated need” at the Environmental review stage? How does that work?

FYI, “stated need” is used 4 times in this Scoping Decision, four times: three times on p. 6, and twice on that page referring to alternatives, “whether alternatives meet stated need” and regarding generation, whether it would “meet, reduce, defer stated transmission need.”

The Objections:

And those Staff Briefing Papers — here ya go – and what’s weird, I don’t recall an email of this, and I’m not the only one:

HERE’S THE LINK TO THE MEETING, AGENDA #2 STARTS ABOUT 7 MINUTES IN!

Oh my… here’s the main issue, adding this to the scope from Applicants’ last minute filing:

Issues? Oh yeah… there are issues… this is so perverse (Characterized by or resulting from willful opposition or resistance to what is right, expected, or reasonable.)

• “unsupported by sufficient information” — explain how “sufficient information” gets in the record at this stage, the Environmental Report stage?? That doesn’t happen until “informing the record” in the contested case.
• “would not meet the stated need for the project” – STATED need? The Applicants’ STATED need is the threshold? That assumes that what they’re saying is the need IS the need. How does the record reflect need at the Environmental Report stage? It’s not been proven, the applicant has the burden of proof, yet simply STATING a need is sufficient to assume as a threshold for an alternative?

On objecting to this language, specifically these two phrases, because that’s limiting alternatives in the ER right NOW, with their order, Commissioner Tuma says, “You’ll have the opportunity to make those points in front of the ALJ, they have the burden of proof…” “You’ll get your chance in the Contested Case” at least twice.

As if I don’t know procedure, don’t know that we’re intervenors, don’t know that we’re dealing now, July 9, with the SCOPE of the ENVIRONMENTAL REPORT at this meeting, the Scope which will determine what alternatives will be considered, if and how, that the Environmental Report is due out September 23, and that the public and evidentiary hearings are in November, and the environmental review, limited as it is in a Certificate of Need proceeding, is based on the Order of the Commission TODAY!

And where did that language come from? It’s a cut and paste of the Applicants’ filing the day before, but the Applicants “only” wanted a change of “may” to “must” as taken from the source, the Staff Briefing Papers.

The rest of that language, other than the change of “may” to “must,” the origin of the “unsupported by sufficient information” and “stated need for the project? in Order Point 2? Looks like it’s EIP Staff.

It’s quite simple. “Opportunity” in the Contested Case is too late if alternatives are eliminated by the Scoping Decision, even before the Environmental Report! The Commission isn’t about to approve anything that’s not been through even the nominal “Environmental Report” in a Certificate of Need docket.