Legalectric

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…

And AGAIN! It’s the Power Plant Siting Act Annual Hearing! You can attend in person, MASKED, or via webex or phone. Primary documents are posted below.

December 20, 2021 @ 9:30

PUC Large Meeting Room

121 – 7th Place East – 3rd Floor

St. Paul, MN

Comments? BE SURE TO NOTE DOCKET NUMBER FOR COMMENTS:

PUC Docket E999/PR-21-18 & OAH Docket 65-2500-37832

Written comments will be accepted through January 10, 2022, by 4:30 p.m.

Note notice only to those “who have requested notice” above? Nope, notice should be to all who are on service and project lists for projects active in the calendar year. Thankfully EERA does give notice to a lot more than just those “who have requested notice” (see “Notice & Service Lists” link posted above).

From the EQB Monitor:

Here are the projects EERA’s Summary says were approved — note that for wind it does NOT list applicable parts of 216E, such as Minn. Stat. 216E.03, Subd. 7!

Meanwhile, the update of rules for PPSA siting, Minn. R. ch. 7850, is stalled out again, WITHDRAWN by the PUC last Thursday, supposedly based on many comments made over the last few weeks by a bunch of people and orgs who were utterly absent through the NINE YEARS of this rulemaking proceeding. My grits are FRIED! The PUC Agenda Item starts at the very end of the meeting, and note the bogus statements about the “why” of this rulemaking. Let’s be clear here — it’s due to the 2005 legislative changes, SIXTEEN YEARS AGO. See PUC Docket R-12-1246. Good grief… Discussion starts at 2:48:28:

Summit Carbon Solutions, LLC is looking to build billions in pipelines, ostensibly to ship CO2 out of state.

Here’s another map, from the “Presentation-Materials” below — look how far into Minnesota it goes from the south, and even from the west:

Yeah, right. Great idea… NOT! Whether it gets built or not, for sure they’re working to get federal grants and loans! Here’s their plan, the handout and presentation from recent Iowa meetings, and after the Iowa meetings, it’s open season, they can file a project proposal with the Iowa Utilities Board at any time:

I fired off this missive to the Iowa Utilities Board:

To look at the IUB’s Summit Carbon Solutions pipeline docket, go HERE, and in that press release, click on the link for Docket No. HLP-2021-0001 and click on the left side the “FILINGS” and there you’ll find a LOT to read! These two studies are among the filings — issues and risks are not new, but here’s a few new studies, newer than what we had back in the Mesaba Project days:

I cannot believe that anyone would regard this as a feasible concept, but what with the millions being shoveled at toadies like Great Plains Institute to promote CO2 capture and storage (nevermind it just isn’t a thing), it’s no surprise:

I guess they can’t read:

We learned a LOT about CO2 capture and storage during the years of Excelsior Energy’s Mesaba Project. CO2 capture is absurdly expensive to capture even a little CO2, and most cannot be captured. And then what? For the Mesaba project, the “plan” they offered captured a tiny amount and then took it to the plant gate — and then what? Who knows, nothing further was disclosed other than a map showing allegedly suitable sites, but no, there was nothing real. This map:

Their plan? Read it and guffaw, snort, hoot and holler:

And Excelsior Energy’s press release:

And check this, about CO2 leaks:

Some other info:

Now remember, when we’re talking about Carbon Capture and Sequestration, there are three distinct parts:

1) Capture (this has been focus of industry studies)

2) Transport

– $60k/inch/mile = $1,080,000/mi for 18″ pipe

– Repressurization stations along the way

3) Sequestration ($3-10/ton, per Sally M. Benson)

And this is all old news:

CO2 pipelines? It’s a red herring!

Do we really need to go through this again??

And some more old news:

Economic Modeling of Carbon Capture and Sequestration Technology

Hydro & Geological Monitoring of CO2 Sequestration Pilot

Electricity without CO2 – Assessing the Costs of CO2 Capture and Sequestration

Geologic Carbon Dioxide Sequestration – Site Evaluation to Implementaion

The Office of Attorney General’s Residential Utility Division (OAG-RUD) has told the gas utilities in search of recovery for its EXTREME supply expenses during the natural gas price spike in February where to go… or more correctly, where NOT to go — that this should NOT come out of ratepayer pockets — that it’s the on the shareholders. YES! Love it when this happens.

The Minnesota Public Utilities Commission has an “investigation” into the massive gas price spike in February, and how the huge price spike and increased costs should be handled (Many other states’ Commissions have opened an investigation too). Thus far, it’s appeared that the Commission’s intent is to pass it on to the ratepayers and spread it out so it’s not so painful. But not so fast folks! It’s so heartwarming to read a pleading, particularly one filed by Office of Attorney General – Residential Utilities Division, where they say “NO!”

Read it HERE:

There are three ongoing dockets at the Minnesota Public Utilities Commission looking at the “gas crisis” from February.

Now pay attention, because this HUGE gas spike was only 2-3 days:

Some background Legalectric posts:

Texas — it’s a gas — natural gas… DOH! February 17th, 2021

It’s still a GAS! February 28th, 2021

The PUC is looking at a few questions, but what troubling is that the Commission seems to presume that the utilities will recoup from ratepayers! This presumption was evident in previous Commission meetings, and was disturbing, to put it mildly!

There are three dockets trudging along on the same path, and to look at all the filings go to eDockets and look up the dockets:

• 21-135
• 21-138
• 21-235

In May, the Commission issued another Notice of Comment Period and noted these issues, followed by a laundry list of topics for comments:

The AG’s Office minced no words and told them “NO!” For example:

Once more with feeling — ENJOY!

OAG_20217-175863-02

I’m particularly interested in storage, because a client lives above Minnesota’s only gas storage dome, an at least 10 square mile just north of Waseca, with 7 billion c.f. of natural gas stored below. A gas intermediate (not peaking) plant was proposed there, first a very small one, then one 10 times that in MW, and thankfully neither was built.

Knowing about that storage (and too many Minnesotans do not), storage was the focus of my comment in this docket last February:

OAG-RUD did address the failure of the gas utilities to utilize storage:

Bottom line to the OAG-RUD?

RIGHT NOW! It’s the PPSA Annual Hearing… sigh… here we go again.

Go to webex, Event # 146 311 2620. The powerpoint slides will be here (and will also be filed on eDockets).

To be able to comment, you have to get on the phone 866-609-6127, Conference ID: 4449079, and to comment, you need to press #1 and get in queue.

Here is the Commerce info about this year’s projects:

And for the record, folks, note that wind is not exempt from many of the parts of the PPSA: