Minnesota Public Utilities Commission process for Certificate of Need and Routing? Good luck with that.

Ja, it’s a little fuzzy, and that’s how PUC process is! I’m drawing up a flowchart for my peeps all over Minnesota in these transmission dockets, and gotta love the internet — this turned up:

What do they have to say about “informal process” for Certificate of Need? Well, from our friends at Taft, the Modern Law Firm, nothing new, but here’s what they’re telling their clients (says “Attorney-Client Privilege” but here it is in the interwebs):

MEMORANDUM 2025-Permitting-Book, p. 20-21. And here’s what Xcel Energy has to say:

And we know all about that pesky Minn. R. 7829.1200 — that is THE rule about “informal process,” with its three points to determine whether it’s appropriate — there is no other:

And Minn. R. 7829.2500 — The Commission must make a decision to utilize the informal process, the informal process governed by Minn. R. 7829.2500, mindful that it must meet the criteria in that rule.

On to the Public Utilities Commission — what does the PUC have to say about “informal process?” MOST?!?! STREAMLINES?!?!? For the first long string of 765kV transmission from South Dakota into the middle of Wisconsin… INFORMAL PROCESS? In what world is this reasonable? Over my dead polar bear…

And Contested Case?

So either way it takes a year. Sounds to me like they don’t want to do the work of a contested case, and/or don’t want the “more rigorous and detailed examination.”

Here’s the “Gopher to Badger” notion of process:

Here’s the utility version of process from the Maple River-Cuyuna transmission project, PUC Docket CN-25-109 (filed yesterday: Supplemental Comments – Maple River to Cuyuna 345kV)

Notice how it goes from “Commission reviews application for completeness” to “Commission issues Certificate of Need decision” in that flowchart and nothing in between? Hmmmm… what’s missing?

THE PUBLIC!!!

For example, missing are these opportunities for the public to weigh in – insert these points in their perception of process:

• Public Comments on Notice Plan
• Public Comments on Completeness
• Public Hearing and Comments on Project
• Intervention
• Evidentiary Hearing
• Briefing
• ALJ Recommendation
• Exceptions to ALJ Recommendaiton
• Staff Briefing Papers
• Commission Agenda Mtg
• Oral Argument if requested and granted
• Commission Decision and written Order after Agenda Mtg
• Motion for Reconsideration
• Agenda Mtg on Reconsideration (usually denied)
• Appeal direct to Minnesota Court of Appeals
• Briefing, maybe Oral Argument
• Decision – usually dismissed/denied/tossed out

The Power on Midwest is a little better — they even mention “INTERVENTION!”

But I’m still looking for that PUC flowchart.

“Informal process” for these big transmission projects? I don’t think so. Particularly when you’ve got toadies lining up pushing for “informal process.” Again, if it’s the same length of time, no “delay,” why? It’s got to be that they don’t want that “more rigorous and detailed examination.” Ja, so?!?!?!

Right… once more with feeling… REMEMBER THE PUC’S PUBLIC PARTICIPATION MANDATE:

MINN. STAT. 216I.16

THE PUBLIC!!!

… AAAAARGH… they’ll have to pry my computer out of my cold dead hands!

Whew, third Comment filed this week, this was Supplement Completeness Comment on the Maple River to Cuyuna transmission line, a 345kV headed from Fargo area to a substation near Baxter. The application is linked here:

Maple River – Cuyuna 345kV line

As for Supplemental Comments, here we go:

And the Applicants, the Supplemental Comments draw on the new info, different info, in the Reply Comments. They’ve changed their tune and now are wanting this “informal process” that does not exist in statute or rule, a simple round of written comments:

And this one from LIUNA is a hoot — seems to be a problem with a real review process, and seems to be toadying for the utilities. Why? How would a serious review of a Certificate of Need application harm LIUNA? Makes no sense.

Busy day today. We’ve had the final round of Completeness Comments on both the Gopher to Badger and Power on Midwest web of 765kV transmission across southern Minnesota. Really,all the way across southern Minnesota. On the western border, it runs through South Dakota from Big Stone coal plant down to Brookings, near Sioux Falls, and then across through Lakefield Junction over to Pleasant Valley… then for some reason up to North Rochester sub just north of Pine Island (with a 345 kV line also running that way, and up to Hampton, WTAF?) and then from North Rochester substation down to the southeast to Marion, then to the southwest (?) back to Pleasant Valley, and from their straight across following Dairyland’s 161kV line to the Mississippi and beyond to the Columbia substation near Portage, Wisconsin. That’s a LOT of 765kV transmission line:

Filed by North Route Group and NO765MN in both dockets – Gopher to Badger CN-25-121 and Power on Midwest CN-25-117. WHY? Because it’s all connected:

Filed by Applicants in both dockets:

Filed by Commerce-DER in both dockets:

Last and least, filed by Liuna – least because how off can ya get??:

Itasca State Park is looking for comments on two amendments to its Management Plan:

View the current Itasca State Park management plan (PDF)

It’s THE Minnesota State Park, though it’s been a decade since I’ve been there.

Over the years, I’ve stayed in Douglas Lodge, Nicollet Court, the 4-Plex, and both campgrounds, Maple Loop 199, and here’s Bear Paw #38, moving up in the world from tent to pop-up:

What do they want to do? Two areas of change, one, overnight use and winter trails and the other, water access:

• Review the Itasca State Park overnight use and winter trail activities draft plan amendment (PDF).

• Review the Itasca State Park public water access redevelopment draft plan amendment (PDF).

Comment period ends April 10th, send comments to Jade.Templin@state.mn.us or mail to:

Itasca State Park Plan Amendments comments, c/o Jade Templin
Parks and Trails Division, Minnesota DNR
500 Lafayette Road, Box 4039
St. Paul, MN 55155-4039

Is this classic or what? There were several, and they were popping up as if they were diving under the boat and appeared on the other side.

Step by step, MISO is slogging through the Variance Analysis for the Northland Reliability Project as set out in MISO Tariff FF (P. 182-193). This just came through the wire, it’s BIG, but interesting tidbits:

Much of this process is confidential, don’t know if it matters at this point. The parts I care about are the cost questions, and the responses may well be confidential. We’ll see.

Generally, there’s this:

And the specifics are what needs to be produced, p. 6-16 of the first document, above:

I don’t/can’t do math, have grey mush in that part of my brain, but if I think on this a bit, and scan through the 347 pages, the trajectory will become clear!

For your reading enjoyment, here’s the part of MISO’s Tariff FF that covers the Variance Analysis process: