Yet another example of GI/GO noise monitoring, following the GI/GO noise modeling, notice of the discrepancies between modeled noise expected and the actual noise found in the post-construction noise modeling.

It doesn’t want to embed, so here’s the link:

https://minnesotapuc.granicus.com/MediaPlayer.php?view_id=2&clip_id=1737&meta_id=205848

The noise study for Freeborn Wind at issue, Parts 1 and 2:

And Commerce-EERA “analysis” of it, with the emphasis on “anal” eh?

There was a lot of talk about the Minnesota noise standards (which are admittedly NOT designed to address wind noise), Minn. R. 7030.0040:

And not until quite late in the discussion did they even bring up the 47 dB(A) limits imposed by the “Special Condition” deal that Commission did with Freeborn:

Note that when there are levels above 47 dB(A), “the Permittee shall work with the Department of Commerce to develop a plan to minimize and mitigate turbine-only noise impacts.” Where does the landowner/resident/human “receptor” fit in? Zero consideration, evidence shows. GRRRRRRR.

Is that sort of like the “working hard” v. “hardly working” conundrum?

Last week was almost a pre-COVID “back to normal” with a trip to Freeborn County to meet with two clients, new pipeline and long-time wind. I so miss being on the road, miss trucking, and miss travel out and about to meet with folks. Timing worked so well, it was a good opportunity to take out the trailer and continue to debate about whether it’s time for the trailer to go on to new owners (oh, that mpg hurts!), to debate whether a tent is really workable. And the debate is over. Now to clean it out and sell… sigh…

The Freeborn Wind project is up at the PUC next Thursday, July 7, to address the noise studies, not that they’ll do anything — seems the primary goal is to duck and cover, not deal with noisy turbines.

And the pipeline is going to be a recurring issue. There’s the “little” line going in under Northern Natural Gas’ FERC blanket authority (seems cost/size of project determines whether NNG applies to FERC); there’s the Ventura North E-Line, part of NNG’s Northern Lights 2023 Expansion applied for at FERC earlier this year; and supposedly this month, the “Albert Lea” project. We’ll see how this goes. I know there’s natural gas storage under the Prehn home along Hwy 13, below Hwy. 60, north of Waseca, and DOH, that gas has to get there somehow. And there’s the east/west gas transmission line along Hwy. 14, through my client’s yard in Kasson (and TOO MANY others). But check the map — I didn’t know that there are this many lines.

More to follow…

The Lava Ridge wind project is likely the country’s largest wind project thus far, with turbines twice the size of those in Minnesota. Here’s the “Magic Valley” developer page: https://www.magicvalleyenergy.com/

And the BLM page for the project:

LAVA RIDGE WIND PROJECT

Cut & paste of some basic facts for the project:

The proposed project includes up to 400 wind turbines, up to seven new substations, approximately 198 miles of 34.5 kilovolt (kV) collector lines, 34 miles of 230 kV transmission lines, 18 miles of 500 kV transmission lines, 381 miles of access roads, 47 miles of temporary crane paths, a battery energy storage system, three operations and maintenance facilities, five permanent met towers and construction-related staging yards. The project proposal has identified a range of possible turbine sizes that would have a generating capacity of 2 to 6 megawatts (MW) per turbine and would have heights ranging from 460 to 740 feet tall. MVE has proposed to locate all components of the project within a series of corridors. These corridors are approximately 1/2 mile wide and cover approximately 76,000 acres, of which 73,000 acres are located on public lands managed by BLM and 3,000 acres are State Lands managed by the Idaho Department of Lands.  The project infrastructure proposed within the corridors is estimated to have a 10,000-acre footprint (emphasis added).

BLM National NEPA Register — Lava Ridge Wind Project

The “Friends of Minidoka” are actively challenging this project, more info here, the link is dated, a cut & paste blurb from BLM:

Bureau of Land Management Extends Public Scoping for the Lava Ridge Wind Project

The prerecorded presentation and scoping posters are available on the project website at https://go.usa.gov/xFKxg.

Contact info for BLM, please contact Kasey Prestwich, Lava Ridge Wind Project EIS Project Manager, Phone: 208-732-7204, E-mail: kprestwich@blm.gov.  

• Lava Ridge Wind Project Environmental Impact Statement (EIS) Scoping Report

From that Scoping Report, here’s another, better map:

I’d expect the EIS will take at least a few more months, and perhaps not be released until next year. I’ve asked and will report in if I get a response. And here ’tis, expected that “Draft EIS will be published in September 2022 and a Notice of Availability for the Final EIS will be published in April 2023.”

Just in today (I’d requested to be on developers project list) – there’s a meeting on Saturday,11a-1p at College of Southern Idaho, Taylor Building, Rm. 276:

On May 12, 2022, the DOE released a “Notice of Intent and Request for Information Regarding Establishment of a Transmission Facilitation Program.” Comments are due June 13. Here’s the Federal Register publication:

https://www.govinfo.gov/content/pkg/FR-2022-05-12/pdf/2022-10137.pdf

One aspect that particularly concerns me is focus on NIETC transmission corridors, designated more than a decade ago, 2005 to be precise, and also containing a category of claimed need for “transmission across more than one state or transmission region.” That criteria would apply to almost every transmission project I’ve worked on, although most were segmented (so that the full extent of the project would not be considered or evaluated, DOH!):

What to comment on? Go to the above Federal Register link, and specific issues for comment start on page 6, “Questions for Requests for Information.” However, if you know of issues that should be considered but are not specified, have at it, put it down in detail.

I do get a little paranoid when they request comments on subjects like this — that “barriers to transmission” is one often raised by Beth Soholt, WOW (now as “Clean Grid Alliance” even more directly identifiable as transmission toadies), and here it is:

Comments are due by June 13, and should be sent to the “Federal eRulemaking Portal” (the only option), and must include the “agency name and identifier.” The agency is “Grid Deployment Office, Department of Energy.”

A decade ago or more, our state agencies eliminated consideration and scrutiny of “need” for transmission by making transmission a “regional” and market matter, making state permitting review nothing more than a rubber stamp. There’s never been a transmission proposal that state agencies didn’t love, rubber stamping everything that came their way. Now that fossil is to be shut down, that should free up immense capacity, but you’ll note that that doesn’t ever seem to be in the mix. Even NERC notes that fossil generation isn’t projected to decrease much, and locally, a good example is GRE’s walk-back on their promise to close Coal Creek, and instead “sold” the plant and transmission, and signed PPA to buy the Coal Creek generated energy.

Here’s NERC’s 2021 Long Term Reliability Assessment’s projection of MW of resources, note that coal doesn’t seem to be going anywhere anytime soon:

If shuttering down fossil is not incorporated into the transmission capacity “need,” exactly what are they basing the “need” claim on? Inquiring minds want to know.

Anyway, do check out the request for comments and let them have it. There are a many specific issues presented that has something for everyone!

Recently, I learned that the Minnesota Public Utilities Commission decided that an “informal” process was to be used in reviewing the three NextEra Dodge County Wind applications and three dockets — Certificate of Need (20-865), Wind Siting (20-866), and Transmission (20-867).

This notion that an “informal” process is appropriate is bizarre — this is exactly the sort of project that needs a contested case!. A few years ago, NextEra had applied for permits for Dodge County Wind, and that project as proposed was so unworkable that they withdrew all three of the applications:

• Dodge Co. Wind – Request to Suspend Schedule, and WITHDRAW xmsn application

… though for sure it was also hampered by an equally bizarre proposal by Commissioner Tuma that they run a 345kV transmission line through the backyard of homes in Dodge Center! Regular folks stood up and weighed in and stopped this massive transmission line from going through their yards (in many cases, the easement would have included their homes, and many homeowners would have been displaced!).

• Dodge Center Xmsn – Mission Accomplished!
• Dodge Center Transmission in the news
• Dodge Center 345 kV transmission?
• Xmsn through Dodge Center?
• Dodge County Wind info presentation

What are these Commissioners thinking? They’re supposed to be regulators, not enablers.

Anyway, the task at this point is to file comments before the May 25 deadline. In addition to the areas above, it’s important to request a “contested case” and request that an advisory task force be established.

NEXT STEPS:

First, the easy one — Request an advisory task force, as provided by Minn. Stat. 216E.08:

So far, the Commission has not ordered an advisory task force for wind, EVER! Commerce-EERA has always used a very narrow definition of “siting” to argue against it. However, an advisory task force is exactly what’s needed to point out environmental issues and the impacts of both micro and macro siting of the wind project and transmission, i.e., this is LARGE Wind Energy Conversion System (LWECS) sited using small wind standards (Order Establishing General Wind Permit Standards, Docket No. E, G999/M-07-1102 (MPUC 2008); are all the homes (“receptors”) identified on the map; are wetlands and flood areas shown; are the maps sufficiently detailed to show 3×5 and 5×5 rotor setbacks; are easements identified and secured by this private corporation that is not a utility; impact of blinking red lights and use of new motion detected lighting system; impacts on nearby Rice Lake State Park; transmission and distribution lines identified; are all airports there, including private airports for spraying; are all sloughs and wetlands identified; all FAA applications in application; are participating and non-participating landowners regarded equally in siting and modeling; etc.

Second TO DO, and more complicated. In your own words (cut & pasting doesn’t cut it) REQUEST a referral to the Office of Administrative Hearings for a CONTESTED CASE PROCEEDING, and explain what material issues of fact need to be addressed in a contested case. Commenters thus far have raised issues that need to be addressed, the record developed, before any decision can be made. Some clues were above, and now rehashed below:

• This is LARGE Wind Energy Conversion System (LWECS) sited using small wind standards (Order Establishing General Wind Permit Standards, Docket No. E, G999/M-07-1102 (MPUC 2008) — small wind standards are not relevant to a LWECS project;
• Most wind projects miss homes in the project footprint — are all the homes (“receptors”) identified on the map and considered in siting;
• Does the project have all land rights for wind turbines (“targeted, pending, no status, and not interested” do not count, only leased. It appears that land rights are needed for 14 turbines.
• Does the project have all land rights for transmission. This is a private company with no right of eminent domain.
• Are all wetlands, calcareous fens, sloughs, and flood areas accurately mapped and impacts considered;
• Are the maps sufficiently detailed to accurately depict the 3×5 and 5×5 rotor setbacks;
• Are impacts of blinking red lights considered;
• Is the use of new motion detected lighting system approved and is FAA applications for this system and for all turbine lighting in the application;
• What are impacts on nearby Rice Lake State Park and other state land, easements, waters;
• NextEra has been fined by USFWS and is “on probation” for killing at least 150 bald eagles. Is NextEra’s eagle survey and Avian and Bat Protection Plan sufficient;
• Are all existing transmission and distribution lines identified and considered;
• Is noise modeling predictive of ability to comply with noise standards;
• Will shadow flicker be inflicted on residents?
• Has use of storage rather than transmission been evaluated;
• Is this the highest and best use for agricultural land;
• Does utility scale central station wind fit with county and township land use plans;
• Are claims that energy generated will be used in Minnesota credible, particularly considering typical powerflows to the east and south;
• Will this project directly reduce generation of CO2;
• Are all airports identified, including private airports for spraying, and are impacts considered;
• Are the impacts, risks, and costs of the turbines on aerial crop and insect spraying, medical, and hazmat helicopter flights identified and considered;
• Are participating and non-participating landowners regarded equally in siting and modeling impacts and avoidance;
• Is there a binding road use agreement with townships and counties;
• Does the decommissioning plan sufficiently protect landowners from burden of decommissioning and cost recovery in the event of operator’s failure to decommission, bankruptcy, and/or abandonment of the project;
• etc., etc., etc.

Comments are due by 4:30 p.m. on May 25th. DON’T MISS THIS DEADLINE!!

In addition to sending in your comments using options below, I also STRONGLY ADVISE you post them in eDockets. Registration is easy and immediate, and by posting to all three dockets, others will know about issues you’re concerned with and can join in and amplify these concerns.

OK, let’s get to work — it’s time to print out those documents, the revised application, later filings of maps, etc.

To access the PUC dockets go HERE to eDockets Project Database, then search for dockets 20-865 (Certificate of Need), 20-866 (Wind Siting), and 20-867 (Transmission). Just plug “20” into the “year” space, and “865” or “866” or “867” into the “docket” space.

Subscribe to the docket to get notice of filings — subscribe by clicking on a box under the “Subscribe” column heading, then click the grey “Subscribe” button, and follow the directions:

Here are links to some of the NextEra “Dodge County Wind” docket filings:

Certificate of Need Application – Docket CN-20-865:

Wind Site Permit Application & Filings – Docket WS-20 866:

Transmission Route Permit Application – Docket TL-20-867