FYI: MN PUC – How To eDockets

Last night in Marshall, 175-200 people showed up at the “MN Energy Connection” scoping meeting for an Environmental Impact Statement for both Certificate of Need and Routing. This is a meeting very early in the process, and the level of interest, and the distress, is very high. That’s more people than showed up for even the later hearings on CapX 2020, except maybe the last hearing held in Cannon Falls after a new route segment was produced with inadequate notice to landowners, when the large high school auditorium filled to the brim.

The “MN Energy Connection” is a scam, emphasize the CON in CONnection. The purpose, stated clearly in different ways, is to preserve Xcel’s 1,996MW of “valuable transmission interconnection rights.” That number is oft repeated, but there’s another number on the first page of its application:

So now we’re enabling “interconnection of more than 4,000 MW of generation… How so? Do explain, but it’s no surprise given that there’s always more going on than what’s immediately apparent.

To do this, Xcel wants to build a 160-180 mile long apparently radial transmission line from Lyon County in SW Minnesota to its Sherco plant, where it’s shutting down the coal plants, and it’s framing this as a “Gen-Tie” line. A “Gen Tie” line is typically a few miles long connecting generation to a substation, hence the grid. This one? Oh, that’s a stretch.

A few points that call this scheme into question (but no doubt about it, it’s brilliant):

Xcel is putting in 710 MW of solar generation in the area:

710 MW is a big chunk of 1,996 MW. How are they getting away with saying they “need” this line to interconnect 1,996 MW at Sherco?

Another factoid — line loss is disclosed, for a change, and it’s over 10%. That’s enshrined in the Public Utilities Commission Order of August 10, 2023. I filed the STrib article and this Commission order, with my bar napkin jottings, with the PUC early yesterday:

Here’s the important admission, that 2,200 MW is put into the lines, and over 160-180 miles, only 1,996 MW arrives! That’s 11.33-12.75% line loss.

That means that the new “big” 250 MW solar project is only 45 MW over what’s lost going from Lyon County to Sherco! Does this make any sense?

Now consider the generation capacity factor of wind and solar. Wind is actually 40% though the MISO number is just over 15%. Solar is about the same. If there’s 11.33-12.75% line loss in transmitting a 15-40% generating source, what’s the sense in that?

This project is now estimated to cost $1.114 BILLION. This is to be spent to preserve Xcel’s “valuable transmission interconnection rights,” and logically, enable continued revenue from transmission service. Xcel is expecting to get Commission approval to claw this out of ratepayers pockets, and to get the land through eminent domain — that this project should be built on the backs of ratepayers and landowners.

What’s the “value” of these “valuable transmission rights?” Shouldn’t that value that value be deducted from the amount to be shifted to the ratepayers? Shouldn’t that be covered by Xcel stockholders? And what of the value of continued provision of transmission service, shouldn’t that also be removed, perhaps as charged?

Another thought. I’ve seen so many interconnection studies where MISO estimates the cost of interconnection, the upgrades to the system needed to put that generation online, and the generator pays those costs. So does that mean the generators will pay the costs of this line, and then ratepayers pay for it too? Hmmmm, color me confused.

Something else bothers me about this. They say this conductor is 636 Grosbeak ACSR, two twisted together, “bundled.” The photos used show what’s probably a CapX line, bundled in that there are two conductors held together in each position, giving twice the capacity. So my question is, are the twisted conductors (bundled) also bundled together in pairs? And then let’s consider that it’s a double circuited project.

Xcel says the amperage is 3,000. The MVA is ??? I’m a math idiot, 46th percentile, but I want to know the conductor configuration. For the magnetic field charts, they’re using 1,100 and 660 MVA. Now I know that 3,000 amps per ? per what?? Their engineer admitted the capacity was more than that 1,100 or 660 MVA, so what exactly is it, and though they claim it’s limited by the Sherco substation’s 1,996 MW interconnection limit, I can’t imagine that’s forever engraved in stone.

Another thought… the need for “voltage support.” That’s because of the line loss and instability over the long distance (not only is transmission inefficient, but it’s inherently unstable). That will cost a lot. $253 million, plus synchronous condensors at the Lyon County sub. Are we ratepayers gong to be charged for all this as well? But of course!

Here are selected pages of the Xcel Revised Application that I filed in eDockets, because I’m referencing them in this round of meetings (p. 8 of this pdf is Ex. 35 from the SW MN 345kV transmission proceeding, docket 01-1958):

On that happy note, time to get ready for day two!

Here’s last night’s meeting in the news:

Swedzinski: Xcel lines should not be built

People attending Marshall meeting ask for energy company, PUC to reconsider proposal to install 345-kilovolt line in region

Local News

Jan 25, 2024

Deb Gau – dgau@marshallindependent.com

Photo by Deb Gau Representatives of Xcel Energy, including Matt Langan, right, answers questions from the public before the start of a meeting in Marshall on Wednesday night. A public comment period at the meeting was part of the review process for Xcel’s permit application on a proposed 345-kilovolt transmission line running from Becker to Garvin.

MARSHALL — A proposed electric transmission line running from Sherburne County to Lyon County is raising concerns for many area residents. A packed crowd at a public meeting Wednesday night urged representatives of the Minnesota Public Utilities Commission and Xcel Energy to consider how the project would affect their farms and families.

“The process of making these decision where we’re running these lines is very critical to all of us, especially in what we do here in the land,” Brian Hicks said. “I’m just really encouraging you to take this serious, because it impacts us greatly.”

A few different speakers at the meeting — including state Rep. Chris Swedzinski — said the lines should not be built at all.

“I think Xcel is making a mistake shutting down the coal-fired plants,” Swedzinski said at the public comment session. “Give us more than just two choices. Give us a third, to just say no.”

Xcel Energy has applied for state permits to build a proposed 345-kilovolt electric transmission line running from Becker to a new substation near Garvin. Xcel spokespeople said the project would make it possible to connect with sources of wind energy in southwest Minnesota, to replace the coal-fired Sherco power plant in Becker.

Two possible routes have been proposed for the transmission lines. One route roughly follows the path of Minnesota Highway 23 between Willmar and Marshall, before turning south toward Garvin. The other proposed route approaches Lyon County from the east, through Redwood County.

“At this early point in the process, there is no preferred route between the two,” said Matt Langan of Xcel Energy

Part of the review process for Xcel’s permit applications includes public meetings, written comment periods, preparation of an Environmental Impact Statement (EIS), and hearings conducted by an administrative law judge, said Scott Ek of the Minnesota Public Utilities Commission. The purpose of Wednesday’s meeting was to help determine the scope of the EIS.

Members of the public at the meeting could comment on the human and environmental impacts of the transmission line that should be studied, said Andrew Levi, environmental review manager with the Minnesota Commerce Department. Commenters were also encouraged to suggest alternatives that would help address those impacts.

Several members of the public said they were concerned about the effects of soil compaction from construction of the power lines, and the possibility of stray voltage affecting their homes or cattle. Lyon County resident Dan Wambeke said he and others living near the CapX 2020 power lines in the area have already experienced those problems.

“We are united in the feeling that it would be an unjust and unreasonable burden to ask us to support another high-voltage power line in our vicinity,” Wambeke said. He presented a petition asking the PUC to remove part of one of the proposed routes, between Highway 23 north of Marshall and Highway 19 east of Marshall, from consideration. “This is the section of the power line, or of the route, that interacts with CapX.”

Other commenters, like Hicks, shared concerns on how the proposed lines would affect the environment and the land in their neighborhoods.

“We’ve got native prairie ground, we’ve got environmental easements, and drainage systems that all have to be taken into account. And without the drainage, it really hinders our ability to be profitable,” Hicks said.

Mike Truwe, of rural Tracy, said one proposed route for a connector line ran very close to his property.

“The line, the right of way, would basically remove a whole front row of trees in front of my property,” he said. “If it were to be moved a half mile down the road, to 310th Avenue — no one lives on that run, and it’d be working with the same landowners, so there’s no change there.”

Lisa Dallenbach said one of the proposed routes ran close to her home north of Walnut Grove.

“Same as everybody else, I’m worried about the stray current. Because I’ve heard of fellow farming rock pickers being subjected to stray currents when they pick rock,” Dallenbach said. “I do a lot of rock picking, probably three or four weeks as soon as we get the crop put in, and I’m not super excited because we farm the piece where the line is going to be.”

Dallenbach also shared Hicks’ concerns about how the lines could affect the environment near the Cottonwood River. The area gets wildlife like trumpeter swans, bald eagles and migratory birds that could be affected by the power lines, she said.

Dallenbach said she wanted the PUC to address the fact that Xcel could potentially take property for the transmission lines through eminent domain.

“Because it is a public utility, and it’s trying to do what’s best for the public, I have no say. You guys can come within 50 feet of my house. Nothing I can do about it. And that should frustrate all of us landowners, that we don’t have a choice,” Dallenbach said. “We don’t want our land stolen from us. We’ve worked hard for it.”

“If a public utility such as Xcel Energy gets a route permit from the Commission, they can use the provisions in eminent domain,” Ek said. However, before that could happen the Commission would first need to determine there was a need for the project, and go through the route permit process. That was why it was important for the public to give feedback and suggest alternatives.

“During the comment period, we really want to see alternate routes,” he said.

Swedzinski told the Independent he had heard concerns from constituents about the proposed transmission line. It was one reason why he was attending the meeting.

“People are largely not wanting it,” Swedzinski said. The transmission line proposal was seen as the first step toward a more power lines crossing the state in the name of green energy, he said. “The people that are against coal, they don’t have to see any of this,” Swedzinski said.

EIS scoping meetings will continue to be held in the project region this week and next week. On Thursday, meetings will be held at Max’s Grill in Olivia and the Redwood Area Community Center in Redwood Falls. The Olivia meeting starts at 11 a.m., with doors opening at 10 a.m. The Redwood Falls meeting starts at 6 p.m., with doors opening at 5 p.m.

Written comments on the project’s environmental impact are also being accepted. Written comments must be submitted by Feb. 21.

Here’s the ALJ’s denial of World Organization for Landowner Freedom’s Petition for Intervention:

And just filed is W.O.L.F.’s Motion for Reconsideration of Denial of World Organization for Landowner Freedom Intervention – can’t let this slide by:

Got a pissive from American Transmission Company (ATC) — apparently it objects to World Organization for Landowner Freedom’s (WOLF)_Petition-for-Intervention in the Minnesota Power “HVDC Modernization” docket (Public Utilities Commission dockets E015/CN-22-607 and E015/TL-22-611).

Here’s ATC‘s Objection:

And here’s World Organization of Landowner Freedom’s response, filed this afternoon:

Take that, American Transmission Company! I clearly remember how nasty they were during the Arrowhead-Weston projects, years of hearing their arguments that were so twisted. I wish I still had the 12 or more boxes from that project, Minnesota and Wisconsin dockets, stretching from 1999 to 2005.

In Minnesota, the issue was whether the project should be exempt from the Power Plant Siting Act. W.O.L.F. was the only intervenor to take it to the MN Court of Appeals, and we lost, went down in flames.

The Wisconsin hearing (05-CE-113) starting in January 2000, or was it 2001… anyway, learning the technical aspects of transmission was intense, so much so that my brain hurt.

But back to ATC’s Objection to W.O.L.F.’s Intervention… Later this afternoon, Minnesota Power filed stating it had no objection to W.O.L.F.’s Intervention, and no objection to LIUNA’s (union group) late-filed Petition for Intervention, noting they’d been participating all along:

Well, that’s good! Now, onward! Any time now, the Administrative Law Judge Mortenson can decide on Intervention.

Here’s the schedule from the Prehearing Order:

Time to get some Information Requests ready to file!

Here we go, World Organization for Landowner Freedom is BAAAACK!

Here we go!

Minnesota Power’s Arrowhead-Weston Transmission Project was probably the longest and most torturous transmission project in Minnesota and Wisconsin, at least, if not worse, than CapX 2020 Hampton to La Crosse. Arrowhead_Weston ran over a less than 15 mile distance in Minnesota, crossing over the St. Louis River near Duluth, and the over into Wisconsin where it headed down to the Weston coal plant.

World Organization for Landowner Freedom (W.O.L.F.) intervened and showed up for years in the various proceedings for this transmission project. There was a two week hearing in Duluth (MEQB Docket: MP-HVTL-EA-1-99), I’d started that in a tent in a friend’s back yard, and we were officing in the garage… then off to Madison for a two month hearing (PSC Docket 05-CE-113), which after initial CPCN approval went on through 3 iterations due to cost increases and routing through Douglas County, Wisconsin. FYI,weird, the A-W EIS is HERE in the Library of Congress files, along with other Wisconsin utility EISs:

Anyway, throughout most of this fiasco, other than the very end, World Organization for Landowner Freedom intervened and participated with gusto. In Minnesota, we raised the issue of noise, which as found in the ALJ’s Findngs of Fact, would be too high (lots on noise search the pdf for more) and lack of need for this project, that the applicants were misstating need, claiming we’d all freeze in the dark in an incubator/on a respirator without a job. Over and over, the Applicants’ attorneys asked, “And where were you on June 25, 1998?”

As to noise:

And in the ultimate EQB Order regarding noise:

Regarding the initial Arrowhead-Weston applicants claim, circa 1999, that Arrowhead-Weston transmission was needed, was our finding in the “repository” the proof positive that the June 25, 1998 outage was self-inflicted, that the trip of the line and the resulting wave of outages across the Midwest, was due to the operators failing to ramp down those bulk power transfers that were far over the operating limits for the King-Eau Claire-Arpin line! Here’s that report from the Mid-Continent Area Power Pool, the “MISO” of that day:

And another report entered into the record, another issue of “high exports” that triggered disaster when system couldn’t handle an outage when all that power was being exported:

For these reasons, bulk power transfer was a concern due to utilities’ practice of overloading the system for their marketing gain. Soooooo… the other thing accomplished, other than noise, was a limitation of 800 MVA at the Arrowhead substation, which means that the line cannot be used for extreme bulk power transfer. From the EQB’s Findings of Fact and Order::

… and…

Recently, Minnesota Power has applied for permit from the Public Utilities Commission to “modernize” its AC to DC system, as the converters are ? way, way older than their expected 30 year lifetime. MP’s need statement for the project is based on the age of the DC to AC conversion equipment, that those converters are no longer made, and that parts are difficult to find. Hence, time for replacements to keep that line going.

The Commission did agree to a joint permitting process for “need” and “routing” (a very short line from the old substation to the new one. See PUC Dockets E015/CN-22-607 and E015/TL-22-611:

The purpose of this project is to facilitate use of the Center, ND to Arrowhead substation going forward. That’s a line that Minnesota Power bought a few years back, “for wind,” though I’m not really convinced. That line was built eons ago. Here’s the plan in short, from the application:

There were scoping meetings held for the Environmental “Assessment,” months ago, with comments due September 13, 2023.

Then, the comment period was extended by DOC-EERA for “residents that are farther than 1/4 mile outside of the project boundary.” R-E-S-I-D-E-N-T-S

Bit in swoops American Transmission Company, with a late filed comment with an “alternative” proposal!

READ THIS!

To which Minnesota Power had a well crafted and detailed reply, here’s the gist, but it’s SO well-written, worth a careful dissection:

Then ATC had this to say:

And based on the late ATC filing, Commerce-EERA recommended:

Then issued its Scoping Decision filed December 1, 2023:

BUT, the Commission has a meeting on November 29, 2023, and discussed this EIS Scoping and the ATC Alternative and sent it over to OAH for a contested case.

And then, AFTER the Commission’s Order and Commerce-EERA Scoping Decision is released, long after the Comment period over, ATC submits a CHANGE!

So Commerce-EERA files a REVISED scoping decision, including this new change! REALLY!

I’m recalling that offering system alternatives and routes that did not “meet the need” of the project proponent were rejected out of hand.. but this is OK?!?!?!?!

What ATC is proposing is as Minnesota Power states, a plan to circumvent the Arrowhead-Weston substation limitation of 800MVA by physically, electrically, going around the transformers in the substation!! AND it gets worse, ATC is openly wanting, planning, on EXPANSION! WHAT?!?!

ATC has intervened in these two dockets:

To further this goal, they’ve recruited FIVE (5) big buck Minnesota and Wisconsin attorneys:

And World Organization of Landowner Freedom?

W.O.L.F. is on alert!