Legalectric

Xcel Energy”s Hiawatha Transmission Project is sticking in my craw again.  I’m having one of those “Xcel is evil” kind of days.  Xcel is hiding reliability information under a claim of “Security.”  How absurd can they get?  Don’t they get that if I was going to blow up substations, a) I don’t need their stupid info to do it, and b) I would have done it a long time ago?  Earth to Mars, that’s not my M.O.  But noooooooooo…

I’ve been looking at Xcel’s SAIDI, SAIFI and CAIDI distribution reliability reports, one of the things I’m happiest about in the 2001 legislative session.  Minn. Stat. 216B.029. Why?  Because Xcel’s Scott Zima testified at the public hearing for the Hiawatha Transmission Line Project that the claimed “reliability” problems did not show up in their SAIDI, SAIFI and CAIDI reports.  WAS ANYONE LISTENING?

What is SAIDI, SAIFI and CAIDI?  They’re distribution reliability indices.  Here are definitions stolen from Rochester Public Utilities 2009 Electric System Engineering & Operations Report:

• SYSTEM AVERAGE INTERRUPTION DURATION INDEX – SAIDI

SAIDI is defined as the average duration of interruptions for customers served during a specified time period.  Although similar to CAIDI, the average number of customers served is used instead of number of customers affected.

The unit of SAIDI is minutes.  A common usage of SAIDI is: “If all the customers on the distribution system were without power the same amount of time, they would have been out for _________ minutes”.

• SYSTEM AVERAGE INTERRUPTION FREQUENCY INDEX – SAIFI

SAIFI described the average number of times that a customer’s power is interrupted during a specified time period.  “SAIFI-short” is calculated using the number of customers affected by momentary interruptions (such as brief breaker or recloser operations).  “SAIFI-long” is calculated using the number of customers affected by sustained interruptions.

The units for SAIFI are “interruptions per customer”.  A common usage of SAIFI is: “On the average, customers on the distribution system experienced _______ interruptions”.

• CUSTOMER AVERAGE INTERRUPTION DURATION INDEX – CAIDI

CAIDI is the weighted average length of an interruption for customers affected during a specified time period.

The unit of CAIDI is minutes.  A common usage of CAIDI is:  “The average customer that experiences an outage on the distribution system is out for ___________ minutes.”

Here’s some background info about SAIDI, SAIFI and CAIDI reports from Edison Institute:

State of Distribution Reliability – 2005

Here’s the Minnesota rule about reporting SAIDI, SAIFI and CAIDI:

7826.0500 RELIABILITY REPORTING REQUIREMENTS.

Subpart 1. Annual reporting requirements.

On or before April 1 of each year, each utility shall file a report on its reliability performance during the last calendar year. This report shall include at least the following information:

A. the utility’s SAIDI for the calendar year, by work center and for its assigned service area as a whole;
B. the utility’s SAIFI for the calendar year, by work center and for its assigned service area as a whole;
C. the utility’s CAIDI for the calendar year, by work center and for its assigned service area as a whole;
D. an explanation of how the utility normalizes its reliability data to account for major storms;
E. an action plan for remedying any failure to comply with the reliability standards set forth in part 7826.0600 or an explanation as to why noncompliance was unavoidable under the circumstances;
F. to the extent feasible, a report on each interruption of a bulk power supply facility during the calendar year, including the reasons for interruption, duration of interruption, and any remedial steps that have been taken or will be taken to prevent future interruption;
G. a copy of each report filed under part 7826.0700;
H. to the extent technically feasible, circuit interruption data, including identifying the worst performing circuit in each work center, stating the criteria the utility used to identify the worst performing circuit, stating the circuit’s SAIDI, SAIFI, and CAIDI, explaining the reasons that the circuit’s performance is in last place, and describing any operational changes the utility has made, is considering, or intends to make to improve its performance;
I. data on all known instances in which nominal electric service voltages on the utility’s side of the meter did not meet the standards of the American National Standards Institute for nominal system voltages greater or less than voltage range B;
J. data on staffing levels at each work center, including the number of full-time equivalent positions held by field employees responsible for responding to trouble and for the operation and maintenance of distribution lines; and
K. any other information the utility considers relevant in evaluating its reliability performance over the calendar year.

Subp. 2. Initial reporting requirements.

By March 30, 2003, each utility shall file its SAIDI, SAIFI, and CAIDI for each of the past five calendar years, by work center and for its assigned service area as a whole. If this information is not available, the utility shall file an explanation of how it has been tracking reliability for the past five years, together with reliability data for that period of time. If the utility has implemented a new reliability tracking system that makes comparisons between historical data and current data unreliable, the utility shall explain this situation in its filing.

Statutory Authority: MS s 216B.81

Xcel has to file these reports annually.  And since Xcel’s Mr. Zima’s testimony that the reliability problems they claim as the basis for need for the Hiawatha Project are NOT reflected in the SAIDI, SAIFI and CAIDI reports (WAS ANYONE LISTENING?), I spent some time looking at the annual reports filed this year:

Xcel’s Initial Filing – Docket 10-310

Xcel’s Initial Filing – Docket 10-310 – Attachment D – Part 1

Xcel’s Initial Filing – Docket 10-310 – Attachment D – Part 2

And there’s another older docket where similar information was recently filed:

Xcel’s Annual Filing – 02-2034 – Part 1

Xcel’s Annual Filing – 02-2034 – Part 2

Xcel’s Annual Filing – 02-2034 – Part 3

To search these dockets,go to www.puc.state.mn.us and click on “Search eDockets” and then plug in the docket numbers.

And here’s an example of what’s wrong with this picture – look at the crudely whited-out Feeder Line column:

Who cares?  Well, I do… why?  Because when they say that the distribution system is such a problem that they need a big honkin’ shiny new transmission line, and then one of their engineers testifies that this distribution “reliability problem” they’re whining about and inflicting an oversized transmission “solution” on a community about ISN’T showing up in the SAIDI, SAIFI and CAIDI distribution reliability reports, that’s a problem.  IS ANYONE TRACKING THIS?  It’s not rocket science, it’s basic vetting of their claims!

Looking at their letter in the filing in Docket 02-2034, there’s this amazing statement:

Security Data

The raw reliability data provided with this filing includes “security data” as
defined by Minn. Stat. § 13.37, subd. 1(a). Xcel Energy believes that some of the
raw data on the disks and/or that has been eFiled could be manipulated to reveal
the location and size of certain facilities that have been summarized in the
Monthly Report. The public disclosure or use of this information creates an
unacceptable risk that those who want to disrupt the electrical grid for political
or other reasons may learn which facilities to target to create the greatest
disruption. For this reason, pursuant to Minn. Stat. § 13.37, subd. 2, we have
excised this data from the public version of our filing.

p. 5,  Xcel’s Annual Filing – 02-2034 – Part I (emphasis added).

Excuuuuuse me?

The public disclosure or use of this information creates an unacceptable risk that those who want to disrupt the electrical grid for political or other reasons may learn which facilities to target to create the greatest disruption.

What a load o’ crap. It is so illogical — those they’re having problems with aren’t necessarily, and probably just AREN’T, the ones to target to create the greatest disruption!

So I calls up Xcel, I do… and leave a message with Bria Shea because Jody Londo who signed the cover letter with the “Security” note was not in, explaining what info in what dockets I’m looking for and that I’m wanting to sign a confidentiality agreement to get it.

But noooooooooooo, guess again.  I get a call back from someone in “Legal” (I didn’t know they had an Illegal department) and here they are making a bogus argument about PUBLIC disclosure, and I’m asking for disclosure with a confidentiality agreement.  She wants to know if I’m a party, which I’m not, there are no parties in these dockets.  And even if a party, even with a confidentiality agreement, no, because it’s a SECURITY issue.  Oh, yeah… right… I’m a terrorist, wanting their “feeder line” information to take out electricity to some select target…  Guess she’s been talking to Mike Krikava, thinking only a terrorist would want to enter a 2005-MAPP map into a transmission proceeding.  That’s as wacky as a judge thinking it’s appropriate to do a transmission proceeding without a map entered in as evidence!

So now I get to “evaluate my options.”  It’s possible to do some triangulation with the reports and with the Attachments to Xcel’s Hiawatha Project Application, but… sigh… we all know what their concern is — that someone might read it and make some sense of it, and understand what it means.

It’s out, hot off the press:

BPU Susquehanna-Roseland Order

I feel a Motion for Reconsideration coming on…

I’ve had a few inquiries as to whether I was dead!  So FYI — no, sorry Xcel, I’m not, but when my Kady-doggy went after Lake, the big happy yellow lab down the block, no way could/would I let go and she took me with her, I took a dive, and without my generous padding, I’d be flat on my back in Ortho with a tib-fib fx and external fixator… OH MY DOG!!!!  I hit right below my knee and thought I’d broken it, that little 1″ spot bruised instantly and darkly, but it wasn’t broken.  Then overnight my leg from the knee down swelled up so bad I could barely get pants on, and my ankle all around turned the most vivid purple, and over the next two days, it slowly creeped upward to my knee.  Felt like it was going to burst!  The part I landed on remained just a small spot of purple and everything else was a psychedelic collage.  Shoes?  Forget it!  Walk?  Hobble at best… Finally, after ice packs, TEDs, and 6 days later, I can say with confidence, YUP! I am going to live.

So back to work!

Tomorrow there are FOUR AWA Goodhue Wind dockets at the PUC, a siting docket where a Draft Permit is proposed, a Certificate of Need docket, and two Power Purchase Agreement dockets.

MOES Reply Comments – Siting Docket 08-1233

Staff Briefing Papers – PPA Dockets 09-1349 and 09-1350

Staff Briefing Papers – Certificate of Need 09-1186

So in response to that:

Goodhue Wind Truth – Siting Docket Comment 08-1233

Goodhue Wind Truth Comment – CoN & PPA 09-1186, 09-1349, 09-1350

To look up the dockets, go to www.puc.state.mn.us and then “Search eDockets” and then search for the docket numbers, as above.

And check out the Goodhue Wind Truth site.

What’s the big deal?  Well, they want to site this project when the maps provided in the application are way way off, as in claiming land rights where they have none, “forgetting” to put homes on the map, that sort of thing.  No environmental review has been done and it’s a BIG project, the “Environmental Report” won’t be done until June — so why is this before the PUC now? And they claim it’s a C-BED project which has some preference in the scheme of Power Purchase Agreements and fulfilling the renewable energy mandate when it’s not exactly local ownership — remember those T. Boone Pickens articles last week? Pickens comes to Goodhue?

Pickens wind turbines come to Goodhue

Goodhue Wind is in the news, and the timing is perfect foreshadowing for next week’s PUC meeting.

In yesterday’s MinnPost:

T. Boone Pickens Tilting at Minnesota Windmills?

In today’s STrib:

Pickens wind turbines coming to Goodhue

In going through the THREE FOOT pile of mail waiting here when I got back, I’ve been reading the Dept. of Commerce Information Requests to Goodhue Wind, and I am pleasantly shocked, they are ON this.  What is “this?”  The basic financing and C-BED claims of this project — it’s been smoke and mirrors from day one, and Commerce is paying attention, digging for more information, and it’s impressive.  MUST GIVE CREDIT WHERE CREDIT IS DUE, particularly to Commerce!!!

MOES Reply Comments

Staff Briefing Papers

THESE FILINGS ARE MUST READS!

Just in — here are the PUBLIC AWA/Goodhue’s responses to Commerce Information Requests.  All of these below are the PUBLIC versions — I don’t see much to gain by reviewing the specifics because that’s pretty restrictive.

First, Dockets 09-1349l 09-1350 and 09-1186 (PPA & Certificate of Need):

IR 1-4

IR 5

IR 5a

IR 5 Supplemental

IR 6

IR 7

IR 8 & 10

IR 9

IR 11

IR 12-13-14

Next, Docket 08-1233 (the siting docket)

IR 1

IR 2-3