Legalectric

Just in, Commerce-EERA responses to Association of Freeborn County Landowners’ 11/25/2019 Data Practices Act Request:

This was the one we sent trying to get information on a Pre-Construction meeting that we’d not heard anything about, and damned if the meeting didn’t start about half an hour after we sent this request!!! Here’s the response to that 11/25/2019 request:

Some highlights:

Yes, there is that statement again of that “quick, delete those emails” Commerce policy, stated above: “As your request was received on November 25, 2019, unless I have saved an email, emails that I could provide you with would be from August 27, 2019 to November 25, 2019. ” And six times in that missive, “EERA must reiterate that email correspondence prior to August 27, 2019 had been automatically deleted by the Agency’s email system.” Yeah, we get it…

OK, fine, we send Data Practices Act Request every 90 days… we can do that.

And when we request notice of Pre-Construction meetings, after all, after all, we’re a party, have been for years now, yet from PUC’s Kaluzniak’s email about our April 23, 2019 Data Practices Request there’s an inference drawn about AFCL attendance at meetings…

And EERA says about notice to meetings:

FYI – Here’s Xcel’s Summary of the 11/25/2019 Pre-Construction meeting that no one told us about, filed December 6, 2019:

That same day, just before that Xcel filing and almost 2 weeks after getting confirmation of our 11-25-2019 Data Practices Request from the Data gurus at both PUC and Commerce, this arrives from Rich Davis… can you spell “oppositional” anyone?

Yeah, it’s just more of the “Davis Shuffle.” Save, document, wait… we’re already sitting at the Court of Appeals, and we’re waiting for PUC to address our EAW Petition. Just keep it up…

PUBLIC PARTICIPATION ANYONE?

Minn. Stat. 216E.08

Subd. 2. Other public participation.The commission shall adopt broad spectrum citizen participation​as a principal of operation. The form of public participation shall not be limited to public hearings and​advisory task forces and shall be consistent with the commission’s rules and guidelines as provided for in​section 216E.16.

The June 25, 1998 blackout report needs to be on the interwebs available to the world.

June 25, 1998? That’s the night of the transmission fail that disconnected the Midwest from the Eastern Interconnect. That question was asked by Minnesota Power’s attorney of each and every witness, I think other than MP, but maybe MP witnesses too, in the Arrowhead transmission project hearing, circa 1999-2000. There were cries of “Hospitals will go dark without the Arrowhead project,” “We’re going to freeze in the dark in an incubator” which became “We’re going to freeze in the dark on a respirator without a job” — it was so histrionic.

The Arrowhead transmission project was project 13J of the WRAO Report, and the WIREs Report, which presented many transmission lines, but chose the Arrowhead transmission project as the “be all and end all” of transmission in the Midwest, that it would fix all the transmission problems:

The hearing went forward, 2 weeks in Minnesota, where MP got an exemption from Minnesota Power Plant siting law, and for TWO MONTHS in Wisconsin, for Round 1, then 2 weeks after the cost went way up, and another 3-5 days of hearing later when cost went up again. They got their permit, it’s up…

But in that first hearing, I did get to introduce the report that showed that the June 25, 1998, blackout was NOT caused by too little capacity, it was not caused by an unreliable transmission system. It was caused by corporate greed, transmission operators running the Prairie Island-Byron 345kV’s TCEX flow over the limit, disregarding operating guides, and disregarding requests and demands to ramp the power down, violating MAPP Operating Standards and NERC Operating Policies. SHAME, NSP, SHAME!!! And MP was so tacky, trying to attribute their desire for bulk power transfer to the blackout, that the Arrowhead project would save us. Yeah, right…

Here’s the report, below, it’s a gem, I’m posting this today because I’m shoveling off my desk and there are a lot of gems here, so posting them will get them out into the world in perpetuity — can’t disappear something from the internet! Scanning them in is taking a while, a royal and dusty pain in the patoot, but just for you inquiring minds, HERE IT IS:

Here are a couple snippets, starting with p. 2:

Bottom line?

OPERATE WITHIN OPERATING GUIDE LIMITS!!

DOH!

The report goes on and on with stupid human tricks – the flow was NOT reduced by NSP System Operators:

From pps 10-11:

So if the operators had been doing the job, not focused on keeping that line operating with all that power flowing through it, selling that power, the blackout may not have happened. Great…

And for some reason, NSP operators were not communicating:

300 MW above the operating guide limits:

OPERATE WITHIN OPERATING GUIDE LIMITS!! DOH!

Operator error is a too-generous way to put it — but for the efforts to NOT reduce power flows, the inadequate response of system operators and their failure to communicate the degree of the problem, the blackout may not have happened. And then utilities have the nerve to say that because of the June 25, 1998 blackout, we need the 13j Arrowhead transmission project?

Goodhue County approves refugee resettlement

What didn’t they get in the packet? Executive Order 13888_2019-21505, which initiated the requirement for consent, prior consent, to accept refugees. That’s new. The consent however, is a restatement of existing county policy. There was no copy of the ” Presidential Determination – 2019-26082_Refugee Admissions FY 2020″ which limits refugee admissions to 18,000, a severe cut from prior years. And a basic outline of the Refugee Resettlement Act and implementation of the law. So I sent the Commissioners that info. Also missing was Gov. Walz’ proclamation of consent:

Governor Walz to Trump Administration: ‘The Inn is Not Full in Minnesota’

How many years have I been saying that the purpose of this massive transmission build-out is to market coal elsewhere? Decades, folks, it’s been decades… And this latest from Xcel Energy, Notice of Comment period just out today, is demonstration that they plan to keep running those coal plants and selling it. Will the Public Utilities Commission care?

Here’s the newly released Xcel Energy plan, and a comment period:

The plan?

Here’s the Notice:

What to comment about? From the Commission’s Notice:

Bulk power transfer was the whole point of the transmission build-out, to be able to sell anything generated at any Point A to any Point B. And then coal generated here could be sold elsewhere, eastward via transmission, while we use generation that isn’t quite so dirty (but that’s dirty in its own way). We’re so clean here in Minnesota… NOT! We’ve been a pass through for Dakotas’ coal for a while, and now, they’re asking permission to keep burning coal here and send that energy eastward.

They built all that transmission, no Commission I’ve seen has ever found a transmission plan they didn’t like and roll over for, and now we’re paying for it. Rate increases anyone? Are you paying attention to what’s pushing those rates up?

Why ever would I say that it’s all about selling coal? Well… there’s a bit of a pattern going here. There was the Chisago project, starting in 1996 and three iterations in Minnesota and Wisconsin, not to mention the WRAO report:

WRAO laid out many transmission lines and the Arrowhead transmission project, circa 1999, was selected as the be all and end all of transmission after many hearings were held, one hearing in Minnesota and THREE before Wisconsin PSC, the price kept going UP, UP, UP!

But then on September 8, 2001, a meeting with likely intervenors to see if they could be convinced to “approve” of the SW Minnesota 345kV line, remember that, Commissioner Matt Schuerger? I pointed out all that coal lined up in the SW MN 345kV study… and from there on to the SW MN 345kV line, part of ABB plan for coal:

Don’t ya just love that name? It says it all. Why the ABB Lignite Vision 21 Transmission Study? The opening paragraph, linked above, DOH! says:

The SW MN 345kV line was the part that’s running east to west on the lower part of that yellow map, from Split Rock sub to Lakefield Junction. Some claimed it was an “It’s for WIND!” line, but that’s a lie, just read that ABB study again. The powerflows showed that it wasn’t to carry energy off of Buffalo Ridge, there was just 213-302 MVA coming off Buffalo Ridge into the over 2,000 MVA capacity line:

How stupid do they think we are? Well, money talked, and that money ruled the day. That SW MN 345kV line and the TRANSLink Settlement Agreement and 2005 Transmission Omnibus Bill from Hell (and changes to Minn. Stat. 117.189) laid the groundwork to bring us $2+ BILLION of CapX 2020:

And then the MISO MVP 17 project portfolio, now over $6 BILLION:

And then they have the audacity to suggest we need MORE transmission?

Upper Midwest utilities to study transmission grid in light of ambitious carbon reduction goals

CapX 2050 Vision Study

So please explain how selling coal generated electricity on the MISO market is consistent with carbon reduction goals?

What a crock…

An odd notice came out today — an extension of the Power Plant Siting Act Annual Hearing comment period, “due to late-filed materials…”

Late filed materials??? Whatever could that be… SNORT!

Naaaah, more likely than not it’s the Comments I’ve filed in all the related wind dockets, plus the PPSA dockets, regarding “ground factor” an inappropriate use of anything but 0.0 as a ground factor:

That’s all about the many wind projects that are improperly using 0.5 and 0.7 ground factor. 0.0 is the only ground factor because the turbine is elevated, and from the source to the “receptor” it is a DIRECT hit! It’s really not hard to understand.

There are so many projects, ALL of the wind projects listed in this year’s Commerce-EERA handout for the PPSA:

These projects were all permitted using bogus noise modeling with GIGO input assumption of 0.5 or even 0.7 for ground factor!!! REALLY! These:

And these:

Guess somebody is wanting time to rebut! May it means we need a contested case, eh?!?! SNORT!

But then, even developer’s expert Mike Hankard agrees that 0.5 is not appropriate for an elevated source like a wind turbine:

It’ll be interesting to see what they have to say.

To look at the PPSA Annual Hearing docket go HERE and enter docket 19-18, using 19 (year number)- 18 (docket number).