Legalectric

Summit Pipeline Solutions, LLC, has been threatening to file an application for a pipeline, well, pipelines, several, around Iowa, and also southern Minnesota in Jackson and Martin counties, in Nebraska, South Dakota, and getting into North Dakota. The Iowa docket was opened up in October, people have been commenting and objecting.

CLICK HERE for the Iowa Utility Board docket summary!

The Iowa Petition was filed last Friday, you can find it and all the appendices at the link above.

The Petition filed by Summit Carbon Solutions was so detail-lite that I filed this, with some basic questions to be answered, basic info to be provided:

Here’s what I think they need to consider, a very narrow part of it, but based on what I learned through the Mesaba Project CO2 capture fiasco:

• The total CO2 generation of each facility proposed to utilize this pipeline;
• The tons/year of CO2 to be captured from each facility proposed to utilize this pipeline;
• The percentage of total CO2 generation at each facility to be captured and shipped from each facility proposed to utilize this pipeline;
• Megawatts of CO2 capture technology at each facility and whether there is sufficient capacity in facility transmission to operate carbon capture equipment;

• Efficiency impact of CO2 capture to each facility proposed to utilize carbon capture;
• Pumping stations at each facility to bring psig to pumping level and megawatt requirements of each;
• Disclosure of transmission load and capacity and whether there is adequate transmission capacity at CO2 generation facilities to handle CO2;
• Locations and megawatts of each pumping station along the pipelines’ approximately 681 miles traversing Iowa;
• Disclosure of transmission infrastructure, load, and capacity for pumping stations at each location along the pipelines’ approximately 681 miles traversing Iowa;
• Disclosure of company’s plan for acquisition of land for pumping stations and transmission lines to power pumping stations;
• Megawatt requirements for all the pumping stations combined for total parasitic load;
• Disclosure and consideration of CO2 impacts of increased electric generation required to capture CO2, pump into pipeline; pump through pipeline, and pump into earth at receiving end;
• Disclosure and consideration of annual operations and maintenance costs.
• Disclosure of locations and total area of land needed and costs for easements and fee purchases;
• Disclosure and consideration of cost per ton of CO2 capture, pipeline, pumping stations, and transmission capital and interconnection costs, and easements for all infrastructure.

That should keep them busy for a while. I attached the Mesaba Project proposal to give them an idea that these considerations are REAL, and that these CO2 proposals are not all they’re cracked up to be. CO2 capture is difficult and expensive, even small amounts cost a lot in dollars, and costs a lot in efficiency, and that’s not even getting into pipelines sending it somewhere. Yet they had this vision… a nightmare:

And the important details weren’t revealed then, and for sure aren’t now. From Mesaba Project’s Exhibit EE1067, p. 20:

Details matter, facts matter, and what’s hidden here matters.

Meanwhile, back in Minnesota, anticipating an application of some sort, the Public Utilities Commission has requested comments on whether the definition of “hazardous” for pipelines should include “CO2.”

INITIAL COMMENTS DUE TODAY! JUST 2 HOURS LEFT!

But really, look at that — the only thing they think is worth addressing is amending the definition of “hazardous liquid.” Good grief… we need CO2 specific rules.

My initial comment:

And then after a quick review of the Summit Carbon Solutions Petition, got this filed today, with the Excelsior Energy Mesaba Project bogus proposal for CO2 capture and sequestration (to the plant gate!!! What then? They didn’t say… ahem…), so I let the Minnesota Public Utilities Commission know what I’d filed in Iowa, not that they care, and revived Excelsior Energy’s Mesaba Project exhibit EE1067, their bogus CO2 capture proposal, TO THE PLANT GATE:

Once more with feeling:

Details matter, facts matter, and what’s hidden matters.