Legalectric

Oh, wait, not that MISO… we should be so lucky. It’s THIS one:

And speaking of which, here’s what the LMP market is doing today — it’s usually blue, so this is nothing unusual, other than the yellow and purple rubbing shoulders at the border:

Anyway, the Certificate of Need for the Mankato-Mississippi River transmission project, a/k/a Wilmarth-North Rochester-Tremval, PUC Docket CN-22-532, is flying through permitting using the “informal” process,” which means there’s no hearing on need, just “comments.” Great… so given that, it’s comment time again — we just had to file Reply comments last Thursday:

Here are all the comments filed thus far — MISO wasn’t too happy with the Prehns & NoCapX Initial Comment, you might want to check it out, plus MISO’s Reply Comment and Prehn & NoCapX Reply Comment:

INITIAL COMMENTS

REPLY COMMENTS

From the Mankato-Mississippi River Transmission Project page… WHAT A LOAD:

Now’s the time to report “Anti-Christian” activity — you know what to do:

Report to Anti-ChristianBiasReporting@va.gov

Remember how Trump pushed a “Muslim ban,” campaigning on it starting in 2015, and Executive Orders starting immediately after inauguration in 2017?

The flip side appeared right away in Trump II: Eradicating Anti-Christian Bias EO 14202 – February 6, 2025

It’s like that false yet malignant “War on Christmas,” much more dangerous, and spreading, essentially flying in the face of separation of church and state. What is “Anti-Christian bias” anyway, and where and when are these named offenses occuring?

I guess at Dept. of Veterans Affairs, hence this email that went out?!?

Report to Anti-ChristianBiasReporting@va.gov

Those in transmission will testify that for a LONG time I’ve been saying “MISO IS NOT THE DECIDER!” And yes, I’m shouting, because the Minnesota Public Utilities Commission is abdicating their role and allowing utilities to use “MISO approval” as a demonstration of need for a transmission project.

As we say in transmission, “It’s all connected.”

Yesterday, I received word of a FERC decision and more importantly, a “Statement” of the Chair’s Concurrence about system operators and “regional plans” versus state authority:

HERE ‘TIS IF YOU DON’T FEEL LIKE SCROLLING DOWN

The decision dismissed PJM’s request for a waiver of a deadline to address costs, and FERC rejected argument for more time:

The Chair’s Concurrence is the crucial and most interesting part — which FERC did not address in dismissing the Petition. The Concurrence weighs in on filings claiming that inclusion of a project in a regional transmission plan pre-empts a state’s permitting process and power:

Granted a claim of pre-emption is a step beyond a utility offering inclusion in a regional transmission plan and a state Commission rolling over to a utilities wish…

As I’ve said repeatedly, a utilities desire is NOT need!

So let’s get local. Here’s an example of misuse of MISO “approval,” keeping in mind that MISO is a marketing organization of utilities and transmission owners. The notion of MISO “approval” is a leading characterization, found in many applications, for example, Xcel’s “Mankato-Mississippi” 345kV line now in permitting )”need” Reply Comments are due Friday). In the intro to that Mankato-Mississippi f/k/a Wilmarth – N Rochester – Tremval Application, the “Summary of Need Analysis” on page 48:

On p. 62-63, more of MISO‘s dream:

And in the section on need, “Xcel’s Need Analysis” was based on MISOs “analysis” — p. 68:

Again, it’s all about MISO and transmission buildout, despite peak demand falling, falling, falling, yet to rise to the record peak in 2006. Where’s the need? It’s all about economics, again, MISO is all about marketing – and check out the view of this transmission build-out per MISO’s Independent Monitor.

The big picture plan:

Here’s what MISO claims the benefits are, page 60 of application, the benefits accruing to MISO MEMBERS, not the public, not the ratepayers. For building transmission, MISO members get a good ROI plus they then charge for transmission services, a new revenue stream.

Here’s the short version, the Concurrence only, from FERC:

And the ENTIRE FERC Order, well worth a read:

What does a federal funding freeze mean for Minnesota? We really need to get a handle on how this directly affects us, services we depend on, funding for local projects, because we’re gong to be hit hard and need to get to work to deal with this. From a new state website on Federal Funding Disruptions, the state budget, and about a third of our budget is federal:

Federal funding to state CANCELED (some affected by funding restraining order):

Funding at risk — LOOK HOW MUCH OF IT IS FEMA:

Here’s the list of federally funded IIJA – Infrastructure Investment and Jobs Act/IRA – Inflation Reduction Act/CHIPS – CHIPS and Science Act Funds (Committed or Spent) for projects in Goodhue County (I think that bulkhead on the 3rd line was discussed at last night’s Council meeting):