Legalectric

At today’s 7849-7850 Rulemaking (PUC Docket 12-1246) “Advisory Committee” meeting, a discussion was had… Commission staff has wisely proposed that a map be included showing system transmission infrastructure in the Application, and that notices also have a project map showing nearby transmission lines.  Makes sense to me!  Particularly considering Minnesota’s policy of non-proliferation of transmission lines:

PEER Non-Proliferation of Transmission Corridors

But I was shocked to hear some who should know better claim that maps of transmission lines are a tightly-guarded Critical Energy Infrastructure Information top secret!  Today’s discussion of CEII and inclusion of transmission maps in an application and in notices was disturbing to say the least.   There was no specific information regarding CEII categories at the meeting (internet access, anyone?), so I sent everyone a missive and attached the CEII definition from the FERC website, and this definition from MISO’s Non-Disclosure Agreement, to clarify the status of transmission maps:  NON-CEII!

FERC_ CEII – Related Document Classes

MISO-CEII NDA

And from the MISO Non-Disclosure Agreement, it’s ever so clear:

The lengths that these utilities go to to keep such crucial information from the public is astounding — it’s not that they don’t know, because they are many things, but they are NOT stupid.

Who cares about whether a transmission map is CEII or not?  Well, Xcel sure does, look at the ruse here to keep a transmission map out of the record:

Pages from Vol 2A July 15

And that map never did get in — though today I’d raise a stink, well, today I AM raising a stink. Why?  Maps of the surrounding transmission system should be included in applications and notices, as proposed by Commission staff because, as we say in transmission, “it’s all connected,” and without a system map, it’s impossible for parties, agencies and landowners to visualize the plan and how the proposed infrastructure fits into the whole.   Due to Minnesota’s non-proliferation policy, it’s also important information for notices because it will aid landowners’ assessment of their risk and whether or not to participate in a given docket.

Here’s the map that I’d entered in the 2007 Power Plant Siting Act Annual Hearing to show CapX 2020 Phase I (pink) and subsequent projects (blue), and its relation to the coal plants in queue at that time:

See how it’s all connected?  Without that visual aid, it just doesn’t present the full picture!