Legalectric

Next up, MISO Tranche 2’s #20, Public Utilities Commission Docket CN-25-116, adding a second circuit between “Bison” and Alexandria. The PUC is seeking comments on their Notice Plan, as with the previous MISO #21, CN-25-111, Iron Range – Arrowhead docket. (catch up on MISO Tranche 2 HERE – 24 projects at $2.1 BILLION)

Here’s their Notice Plan — now’s the time to pick it apart. Because it’s “just” adding a double circuit to the CapX 2020 Fargo line, there’s not much to say:

And here’s the PUC’s full request for Comments:

And the short version:

I quickly slapped together No CapX 2020 Comments based on the ones I’d filed the day before on the first MISO Tranche 2 project, further below. Again, this is “just” adding a 2nd circuit, but the “need” question remains — why is this needed — justify it, it has to be more than MISO/MISO’s utility & transmission members want it. MISO’s “approval” does not mean it meets Minnesota’s need criteria in Minn. Stat. 216B.243:

And for that other project, MISO’s #21, PUC Docket CN-25-111, the only Comments filed last week — ONLY THREE COMMENTS. This is a new greenfield project — what does it take to wake people up?

Expect to OD on MISO over the next few years:

• CN-25-109 MISO 20 – Maple River – Cuyuna 345 kV
• CN-25-111 MISO 21 – Iron Range – Arrowhead 345 kV
• TL-25-112 ” “
• CN-25-116 MISO 19 – Bison-Alexandria 345kv
• CN-25-117 MISO 22 – Brookings – Lakefield 765 kV
• CN-25-118 MISO 23 – Lakefield – East Adair 765 kV
• CN-25-119 MISO 24 – Lakefield-Pleasant Valley – N Roch 765 kV
• CN-25-120 MISO 25 – Pleasant Valley – N Roch – Hampton 345 kV
• CN-25-121 MISO 26 – N Roch – Columbia 765 kV Dairyland
• CN-25-122 ” ” Xcel

Here we go… It’s MISO Tranche 2, which means more transmission, and BIGGER transmission coming to Minnesota, and this is for the “Iron Range to Arrowhead” transmission line, the first Notice Plan and Exemptions Request of the bunch. Here’s the BIG picture:

To look up any of these projects, go to eDockets: https://www.edockets.state.mn.us/documents then plug in the docket number, i.e. 25-111 for this one:

Interactive Map for Iron Range to Arrowhead HERE!

The PUC dockets to plug in (and FYI, the MISO number from above, substations, and voltage) are:

• CN-25-109 MISO 20 – Maple River – Cuyuna 345 kV
• CN-25-111 MISO 21 – Iron Range – Arrowhead 345 kV
• TL-25-112 ” “
• CN-25-116 MISO 19 – Bison-Alexandria 345kv
• CN-25-117 MISO 22 – Brookings – Lakefield 765 kV
• CN-25-118 MISO 23 – Lakefield – East Adair 765 kV
• CN-25-119 MISO 24 – Lakefield-Pleasant Valley – N Roch 765 kV
• CN-25-120 MISO 25 – Pleasant Valley – N Roch – Hampton 345 kV
• CN-25-121 MISO 26 – N Roch – Columbia 765 kV Dairyland
• CN-25-122 ” ” Xcel

The project with the just filed Notice of Comment Notice Plan and Request for Exemptions is MISO #21, and PUC Docket E015/CN-25-111, from the Iron Range sub to Arrowhead sub.

And here’s the Comment Notice:

The “Topics for Comment” that the PUC lists is just one, about the Exemptions Minnesota Power (MP) and American Transmission Company (ATC) have requested:

But… but… but… where’s mention of the Notice Plan? Do check out the Notice Plan and if it’s deficient, let them know in your comment.

Send Comments to:

I highly recommend signing up for eFiling and filing them directly in the docket — that way others can benefit from your filing to help recognize and address issues. INSTRUCTIONS TO REGISTER (yeah, it’s over 20 pages, but there are screen shots to walk you through, and once you’re registered, it’s EASY to file.

p.s. Here’s a post (linked HERE) from over a decade ago predicting this mess of 765 kV transmission:

Thanks, American Clean Power Ass., f/k/a American Wind Energy Ass.

And yes, transmission and markets, or American Clean Power’s “Markets & Transmission,” — it’s all about money:

This has been just too much to bear, but it’s time to acknowledge that there are indeed 765kV transmission lines targeting Minnesota, more targeting the “Midwest,” and get these (*#&%#( things posted. Thanks, Midcontinent Independent System Operator (MISO), thanks a bunch.

In the Jackson County Pilot:

Upper Midwest’s first 765-kV line could run through county

Here’s the general idea:

In numerical order, PUC Docket wise, the first is MISO #22, is the Big Stone-Brookings-Lakefield part of the system, promoted by our friends at Xcel Energy. The PUC Docket number is CN-25-117, and it only covers the part that’s mostly in Minnesota, Brookings to Lakefield Junction. The Big Stone to Brookings is in South Dakota, though a 345kV “Big Stone-Brookings” line was built not long ago, 2017, so why another, and why a 765kV?

Here’s the rough for this new proposal, duplicating the Big Stone to Brookings, and then, from Brookings to Lakefield Junction (anyone remember the “Split Rock-Lakefield Junction” circa 2001??? That was the first of the 345kVs in the area, Docket 01-1958.

Thus far, the only filing for that project in Minnesota is from Xcel Energy, opening a docket and the notice that it plans to apply for this Brookings-Lakefield Junction transmission line. PAY ATTENTION TO THIS LANGUAGE ABOUT MISO:

Right out the gate, they’re asserting MISO as the basis for need. There’s the statement that “MISO, a federally registered planning authority and regional transmission organization, approved its Long-Range Transmission Planning (LRTP) Tranche 2.1 portfolio of projects…” and why? Here’s what our new Minnesota statute says:

Yes, really. Did legislators have a clue that this means? I doubt it. Here’s the full statute, 216B.246 FEDERALLY APPROVED TRANSMISSION LINES; INCUMBENT TRANSMISSION LINEOWNER RIGHTS.

What’s MISO Tranche 2.1?

• MISO MTEP 24 Transmission Portfolio
• MISO LRPT Report
• Tranche 2.1 Fact Sheet
• LRTP Tranche 2 Business Case Metrics Methodology Whitepaper

The Minnesota Public Utilities Commission has long been allowing reliance on MISO “approval” for PUC “approval,” and there’s been no recognition that the MISO standards for “approval” are NOT the Minnesota standards. For too long, utilities, typically Xcel Energy, but any utility proposing high voltage lines, have not been required to demonstrate need for their transmission projects.

The next one is a continuation of that project, heading south, MISO #23, this time an ITC project, from Lakefield Junction to East Adair.

ITC filed its Notice of Intent at the same time Xcel filed its Notice in the other docket, using that same language as Xcel to describe it’s project and relation to MISO’s Tranche 2.1:

What about that connector from Lakefield Junction heading east, MISO #24, a 765kV from Lakefield Junction to North Rochester, and MISO #25, a 345kV from Hampton down to Pleasant Valley (note the existing Hampton-North Rochester CapX 2020 345kV line, and the OLD Prairie Island-Byron-Adams 345kV line).

And yes, next up is MISO #26, a 765kV from North Rochester to La Crosse to Columbia, paralleling part of the CapX Hampton-LaCrosse & eastward line. Who’s claiming MISO #26? Yes, that’s coming too…

In PUC Docket order, Docket CN-25-121, another Notice of Intent to file a Certificate of Need application, Dairyland Power Cooperative (DPC) intends to “to construct, own, and maintain the Minnesota portion of the North Rochester – Columbia 765 kilovolt (kV) Transmission Line Project (the “Project”) from a midpoint structure on the new 765 kV line from North Rochester to Marion Road (as will be agreed between Dairyland and Northern States Power Company d/b/a Xcel Energy) to the Minnesota-Wisconsin border.”

Dairyland uses the same language as Xcel, except adding its “abundance of caution” at the end:

And then Xcel Energy chimes in, Docket CN-25-122, stating that “Xcel Energy intends to construct, own,
and maintain the North Rochester – Columbia 765 kilovolt (kV) transmission line.”

Xcel Energy again discloses its reliance on MISO:

Earth to Mars, MISO is not the decider in any of these Minnesota Certificate of Need proceedings.

And on eastward to Wisconsin… It looks like MISO #30 is a 765kV from Columbia to Rockdale. Is it going through Middleton/Madison on existing corridor?

Dropping four HUGE lines, 765kV, which has not before been done at 765kV in the Midwest, and all relying on MISO “approval” as a demonstration of need?

December 10, 2024 was the Power Plant Siting Act Annual Hearing. It was before ALJ Christa Moseng, and there were very few commenters. I’m not seeing any minutes, and don’t know if they’ll ever be posted. There were only two of us commenting, myself, and Dan Wanbeke, who has a CapX 2020 line on his land. If the proposed MN Energy CON line is built, he could be surrounded by transmission.

Wanbeke gave a detailed description of his experience and takeaways, one of the most important was a comment of the PUC’s Bob Cupit (since retired):

There are winners, and there are losers.

A very interesting part of Wambeke’s testimony was regarding the stray voltage problem, all the water in their farm was energized, and the shower tested at 15 VOLTS! The local utility has been out many times, and when Capx 2020 was down for a brief time, no stray voltage, and when it was again energized, the stray voltage was back. He testified about induction current, that when there’s a distribution line running parallel to a massive transmission line, there can be induction current (this also happens with pipelines), and the distribution lines are indeed parallel with CapX transmission. This is NOT rocket science, and the CapX utilities better deal with this. If meeting minutes come out, I’ll post, though the thought occurs to me that this was a “hearing,” so it will probably be a top secret transcript. Will keep an eye out.

These next two tidbits were handouts at the hearing:

And now on to comments filed since:

FYI, the DOT “Policy of Accommodation” that should be entered in every docket, because it sets out how utilities can interact when projects are proposed near roads — I’ve observed cases where the utility paid no attention to DOT comments and landowners nearby were screwed with little notice because utility had to quickly alter plans because DOT would not allow planned placement:

On to the regular folks, so far just two of us!

I’d made oral comments at the hearing (via web), but had to put it in writing to be more specific, because the changes are immense, and there needs to be a record. As I said in my Comment, not for the first time, “I’m disgusted, frustrated, incensed, and committed to showing up before the Public Utilities Commission until I drop dead someday in the large hearing room.” I had to file a corrected version, was bleary-eyed and found typos, missing words and punctuation, and FYI, the first one below has been corrected:

This one, from Kristen Eide-Tollefson for CURE, Communities United for Responsible Energy, is important because she’s seen the changes over the decades, THREE decades, of dealing with the Power Plant Siting Act. Now it no longer exists, hence Eulogy for the PPSA:

Let’s trot out this one again, we’re overdue for a Transmission Transition:

In the StarTribune today:

Soaring CWD numbers in southeastern Minnesota prompt DNR to stop culling deer

Here’s the STrib’s map below — this map might be from just this year’s testing?

I’ve been tracking chronic wasting disease in deer for a while, right up there with bovine spungiform encephalophy (BSE, “mad cow”) sheep scrapie, even in pigs, and of course Creutzfeld-Jakob in humans (ages ago, it was also Jakob-Creutzfeld). This came to my attention in the late 1990s, when a swimming coach at Northfield high school died of Jakob-Creutzfeld.

• Of mad cows and pissy deer… September 15, 2005
• Downer cows = Mad Cow disease? February 11th, 2008
• Mad Cow Beef & MN Dept of Education February 11th, 2008
• They’re actually saying “MAD COW” February 19th, 2008
• Creutzfeld-Jakob variant – 4th declared case June 6th, 2014
• More CWD (chronically wasted deer) in MN December 30th, 2016

And then there’s all the elk at Elk Run:

Sharpshooters begin destroying elk herd

What does CWD mean to Elk Run development?

From CWD-INFO.org, a detailed source of info which seems up to date:

Preliminary Test Identifies CWD-Positive Wild Deer in Southeast Minnesota

MN – News release: CWD confirmed in a wild deer near Wheaton in western Minnesota

Here’s the CWD-INFO.org map:

And reason for concern among hunters:

2 hunters may have died of prion disease from eating contaminated deer meat, researchers say

Deaths of three men prompt Wisconsin to look for connection to fatal brain disease in deer