It’s the most wonderful time of the year!!! It’s the Annual Power Plant Siting Act Hearing, where we get to tell an Administrative Law Judge how we think our state’s system for Power Plant Siting works and doesn’t work. In these days of extreme regulatory capture, it’s hard not to just barf at the thought. But here we go again.

The map above was turned in at the 2006 PPSA Annual Hearing. It is an OLD transmission map, from 2005, long before Critical Energy Infrastructure Information (CEII) became an issue, so don’t even think of claiming this is CEII info! The highlighted lines are rough approximations of the transmission lines proposed for CapX 2020 (PUC Docket CN-06-1115). The green squares are cute little coal plants, existing or planned, with megawatts ID’d. Every picture tells a story.

My comments, Round 1 highlights — full packet below:

When they’re talking about planned & proposed transmission what are they talking about? It’s a big, long list.

Here’s the Commerce handout:

Compare the list provided by Commerce, page 4, and note which ones are missing — that is which that have been assigned a PUC docket number, but aren’t in the list: 1( Brookings-Lyon Co. & Helena-Hampton (CN-23-200 & TL-08-1474); Wilmarth-North Rochester-Tremval a/k/a Mankato-Mississippi (CN-22-532 & TL-23-388); Big Stone So.-Alexandria-Big Oaks (CN-22-538 & TL-233-454). Here’s their list:

Here’s a rough map of what’s been and is proposed, from the 2001 SW MN 345kV line, to CapX 2020, to MISO MVP Portfolio, to the current MISO “Tranche 1” in Minnesota:

HOW MUCH TRANSMISSION CAN WE POSSIBLY NEED?

HOW MUCH TRANSMISSION SHOULD WE PAY FOR?

Here’s the Commission’s 4 color glossy powerpoint (and yes, Comment period ends January 12, 2024).

And here are my INITIAL Comments:

THIS is the most important part — CapX 2020 transmission was predicated on a 2.49% annual peak demand increase, which we knew then was bullshit, and utilities said, “Oh, that’s just a blip.” Right… we new better, and we have the proof it’s not a “blip.” The peak demand numbers in the chart and graph are taken from Xcel’s SEC 10K filings. Xcel in 2009 claimed 9,632.6 for 2009, though SEC filings said 8,615. NOTE: Demand is essentially FLAT over time:

So why are they wanting all this transmission, transmission that we pay for, that landowners forfeit land for easements, WHY?

Let’s focus on this and ruminate a bit…

Just filed, the ALJ’s report to the Public Utilities Commission from the Power Plant Siting Act Annual Hearing.

Here’s the presentation from the hearing:

And I’ve not kept up with the annual report filings, so here they all are:

2000 Summary of Proceedings

2000 Report EQB

2001 Summary of Proceedings

2001 Report EQB

2002 Summary of Proceedings

2002 Report to EQB

2003 Summary of Proceedings

2003 Report to EQB

2004 Summary of Proceedings

2004 Report to EQB

2005 Report to PUC

2006 Report to PUC – Docket 06-1733

2007 Report to PUC – Docket 07-1579

2008 Report to PUC – Docket 08-1426

2009 Report to PUC – Docket 09-1351

2010 Report to PUC – Docket 10-222

2011 Report to PUC – Docket 11-324

2012 Report to PUC – Docket 12-360

2013 Report to PUC – Docket 13-965

2014 Summary Report– Docket 14-887

2015 Summary Report – Docket 15-785

2016 Summary Report – Docket 16-18

2017 Summary Report – Docket 17-18

2018 Summary Report – Docket 18-18

2019 Summary Report_Docket 19-18

20202-160679-01 Summary Report – Docket 20-18

SPREAD THE WORD:

6:00 P.M.

MONDAY, DECEMBER 5, 2022

At the PUC’s annual Power Plant Siting Act (PPSA) hearing on the 9th, it was impossible to get into the webex meeting, so ultimately I signed in via the phone, and as far as I could tell, I was the only one present. I did note for the record that it was impossible to get in, and afterward, the next day(?), I called Bret Eknes to complain, and he did admit there were problems and that it would be rescheduled. GOOD!

Today the notice came out:

CLICK ON THE NOTICE FOR LINK AND DETAILS OF HOW TO CONNECT.

Once more with feeling:

BE THERE OR BE SQUARE!

BE THERE OR BE SQUARE!

9:30 a.m. Wednesday November 9, 2022

3rd Floor Large Meeting Room

Public Utilities Commission

121 – 7th Place East, St. Paul

Just got notice of the Minnesota Public Utilities Commission‘s Power Plant Siting Act annual hearing:

This happens every year, and it’s important to spread the word around. One change that is very good is that the Commission is doing a good job of serving notice of the hearing — there are ~ 128 pages of recipients of this notice! GOOD! Love the interwebs, makes it so easy to let people know what’s happening.

The “Power Plant” aspect is very broad, this includes not just “power plants,” but transmission lines, wind projects, and solar too. This is the opportunity to tell the Public Utilities Commission, and the state generally, what works and what doesn’t work about the procedures for siting electric utility infrastructure, ideally based on your experience.

One positive aspect of COVID is that hearings are now held in “hybrid” format, both in person and online via Webex:

It is best if using Webex (http://mn.gov/puc/about-us/calendar/ and click on “November 9, 2022” to get to “webcast”) to have video on your computer and to use the phone for audio, whether listening or making comments — that’s the best way to avoid feedback (using headphones helps too). The webcast link usually goes live 10 minutes or so before the hearing starts.

What to comment about? If you’ve had experience with a Public Utilities Commission siting docket, if there were issues that made it difficult to participate, things needing clarification, rules and/or procedures that need changing, this is a way to bring it to the Commission’s attention. Over the 27 years that I’ve been dealing with utility siting issues, oh, the horror stories I can and do tell. The system needs work, and siting infrastructure is a constantly evolving process, sometimes very good changes are made, and sometimes, no matter how much we petition (formally and informally), challenge, cajole, demand, they just won’t take responsibility, won’t do their jobs, and won’t even promulgate necessary rules.

A main point of holding this hearing, as above, is hearing from “the public.”

In addition to the public participation issues exposed in this report (about which not much, not enough, has been done), a few things that I’ll be bringing up, orally or in writing:

• The Office of Legislative Auditor investigated the Public Utilities Commission‘s practices, and this report had recommendations, most of which have not been addressed:

OLA-Report_PUC Public Participation 2020

• The Public Utilities Commission has not, in the decades I’ve been participating in the PPSA Annual Hearing, EVER brought up the PPSA for discussion and ACTION on issues raised.

• Wind siting “guidelines” were adopted via Commerce-EERA without public notice or opportunity for input: Large Wind Application Guide.2

• Notice has not been provided to landowners on transmission line routes where “alternate” routes are proposed, and sometimes landowners have not discovered their land may be affected until the public hearing, very late in the process.

• Power Plant Siting Act rule revisions, due after the 2005 Power Plant Siting Act legislative changes, have not been promulgated, despite a years long process, NINE YEARS, many committee meetings, and a lot of work by a lot of people. The Public Utilities Commission just dropped it… no action… sigh… Minn. R. ch 7849 & 7850 Rulemaking? DEAD!

• Despite 2 rulemaking petitions to the Public Utilities Commission, there are no wind siting rules! The Commission refuses to promulgate wind siting rules, instead using Small Wind Standards:

There’s no end to the issues to raise.

In addition to the public hearing, comments may be submitted in writing:

Get to it! Register your experience with the Public Utilities Commission, and let them know what needs work.