Legalectric

It’s no work of art, but in the scenario this proceeding is in, with Prairie Island Indian Community and City of Red Wing deep in it with or working on agreements with Xcel Energy, there’s not much we can do, little impact, as they’re the players, and also, AAAAACK, I just didn’t have time.

The DEIS did grossly misrepresent the history and status of Xcel’s Utility Personal Property Tax payments to local governments, so I did include the City of Red Wing comment in the IRP (below page 13, Attachment A).

The main purpose of this is to push for reworking of the “low-dose” radiation exposure modeling using Aaron Datesman’s cutting edge Three Mile Island “shot noise” work to correct for the GIGO current modeling and more accurately characterize the risk.

Sooooooo, anyway, here’s what I filed:

UPDATE: Tsunami warning canceled for San Francisco Bay, Northern California coast

So much for that!

Northern California tsunami warning issued after 7.0 magnitude earthquake hits

Here’s the USGS map from that article:

And this tsunami WARNING — what could go wrong?

Right on the ocean:

Well, there is a jetty there, but…

Remember this post about the Draft Environmental Impact Statement?

Prairie Island cask DEIS released

October 31st, 2024

Yes, it’s true! Tempest ist a fugiting, and comments on this DEIS are due next week:

Friday, December 6, 2024

Per the Dept. of Commerce — a few ways to comment:

For more info, for the full docket, go to the Minnesota Public Utilities Commission site: mn.gov/puc (https://mn.gov/puc). Select eDockets, and at the bottom, select eDockets again, then enter the PINGP docket’s year (24) and the docket number (68), and select “Search,” and fill in like this:

You can also check the Minnesota Department of Commerce project page, but keep in mind that not all of the documents filed in eDockets are here: eera.web.commerce.state.mn.us/web/project/15425

Once more with feeling, here’s the DEIS Narrative, and the rest in links below:

Lukewarm off the press, the USG air permit is up for renewal. It’s regarded as a “major emitter:”

…so it’s important to pay attention if you’re concerned about air quality here in Red Wing, and who isn’t, eh? This is on the MPCA’s website, and from there, hit “Review Documents” that you’ll see in green:

Comment period ends at 4:30 on December 26, and their procedure for comments is pretty specific, an “I don’t like it, I don’t want it” won’t do it, so if you want your comment to count, here ya go:

Procedure for public participation
As stated in Minn. R. chs. 7000 and 7001, there are three formal procedures for public participation in the MPCA’s consideration of this matter. Interested persons may:

1) Submit written comments on the draft permit.
2) Petition the MPCA to hold a public informational meeting.
3) Petition the MPCA to hold a contested case hearing.
Submitting written comments
Comments may be submitted:
1) Online at https://mpca.commentinput.com/comment/search; or
2) By U.S. postal mail to the following address:
Benton Campbell
Minnesota Pollution Control Agency
520 Lafayette Rd
Saint Paul, MN 55155
Submitted comments or petitions must state:
1) Your interest in the permit application or the draft permit.
2) The action you wish the MPCA to take, including specific references to the section of the draft permit you believe should be changed.
3) The reasons supporting your position, stated with sufficient specificity as to allow the MPCA to investigate the merits of the position.

Here;s their NOTICE PAGE, as above, and I’ve also downloaded the documents here:

And the Draft Permit:

And last but most is the Technical Support Document, which won’t make sense to most people, BUT this is what the Draft Air Permit is based on, sooooo… here it is:

Oh my… looks like I fell asleep at the switch. I’m working on getting back up to speed on transmission, making sure all the Power Plant Siting Act Reports are posted, and yikes, I don’t see the 2023 NERC Long-Term Reliability Assessment here on Legalectric. Here it is, quick before the 2024 LTRA comes out:

Short version – we’re not short now and won’t be for a while — we are NOT going to freeze in the dark in an incubator without a job:

Here’s the caveat, per that MISO link, page 39 of the LTRA, where things start not adding up:

It’s always been the claim that building all these BILLIONS of dollars of transmission, that WE pay for, means that we can get electricity from a wider range of sources and that the reserve margins would DROP. Yet look at that chart, lower left. It starts at ~16% (above 15%) and instead of going down, it’s ramping up to above 20%! Were they lying then or are they lying now.

Another thing to keep in mind is the “prospective” number is low because of the definition of prospective, that it required a firm development threshold beyond an interconnection agreement, purposefully reducing prospective generation:

Bottom line — take those reserve margins with a grain of salt, both the rising reserve margin over time, and the reduce prospective generation additions.

To check out NERC Reports through the ages, go here:

NERC Reliability Assessments