April 21st, 2017
This is about public participation, something that is ostensibly encouraged by the Minnesota Public Utilities Commission. My take on this is that OAH’s modus operandi is the previous, yet unacted upon, Draft Rules for Minn. Rules Ch. 1400 & 1405, in which public participation was proposed to be severely limited:
I’d filed a Rulemaking Petition ages ago, circa 2011, after raising issues over and over and over and over and over and over and over and over again at Power Plant Siting Act Annual Hearings:
The OAH page regarding this 2012 rulemaking Notice, the Draft, and the several Comments received has been disappeared. Hmmmmmmm…
Anyway, as noted before, OAH has been limiting interventions for a while now. See Rate cases, rate design, and intervention for the privileged few…
Here’s a few posts of my current experience with No CapX 2020 intervention in Xcel’s rate case docket:
More Denial of Intervention in Xcel Rate Case May 3rd, 2016
2nd Petition for Intervention in Xcel Rate Case January 25th, 2016
Rate Case – Response filed to Xcel’s Objection to Intervention January 6th, 2016
To review these dockets, GO HERE and look up the docket numbers.
And now AARP has filed for Reconsideration. GOOD!
Very well put, AARP! For example:
How could these parties interests be deemed identical? That’s as absurd as ALJ Mihalchik’s claim that the interests of those I represented in the Big Stone II docket were “adequately represented” by the “Clean Energy Intervenors.”
But here’s an important point:
In another docket, the Xcel Energy rate case, there was a “Settlement Agreement” by many parties, and in that rate case docket (15-826) it was those who had participated in the e21_Initiative who “agreed,” and AARP did NOT agree.
How much is this prior objection to the Xcel Energy rate case agreement related to the current denial of intervention? Methinks quite a bit…
Do take the time to read this entire AARP Motion for Reconsideration.
April 19th, 2017
UPDATE – April 19: Now there’s a Notice 0f Comment Period:
Comments are due by May 15 — see Notice 0f Comment Period for particulars.
Last Tuesday, there was an “Informational Meeting” where Xcel Energy was allowed to present its plan for an “Alternate Rate Design” to the Commission. Nevermind that there is an “Alternate Rate Design” PUC Docket 15-662 and there’s an ongoing rate case right now, PUC Docket 15-826. No, Xcel gets to circumvent all that, and get special time before the Commission.
The Office of the Attorney General registered a complaint, raised some pertinent questions (OAG-RUD_Letter_20174-130495-01) and asked that the meeting be cancelled:
Pretty simple concept, but noooooo… the meeting went forward. And Chair Lange’s position was that we’d deal with the Attorney General’s Office’s objections AFTER the presentation by Xcel — it was absurd.
At the outset, I jumped in and requested that Chair Lange and Commissioner Schuerger recuse themselves due to their work in putting together Xcel’s e21 Initiative:
Here’s the full post with background on that:
Well, that request to recuse went over like a lead balloon…
And when “discussing” this with the Asst. A.G., one Commissioner said, essentially, “Well, Xcel Energy will file its proposal, a docket will be opened, and you can just intervene in that docket.” NOPE, no way, that’s not how it works, intervention is NOT to be assumed, presumed, and no way is that a legitimate rationale for allowing Xcel Energy’s presentation time before the Commission.
What did Xcel have to say? Not much of substance:
Anyway, back to the notion of intervention… We’ve been having problems with OAH limiting interventions, unduly limiting public participation, for some time now:
May 3rd, 2016
January 25th, 2016
January 6th, 2016
Both of these were cases where there were NO objections to their intervention by any party, and yet the ALJ denied intervention, claiming that their interests were “identical” to those of already admitted intervenors. WHAT?
To be continued… In the meantime, work on those comments in the “Alternative Rate Design” docket:
Comments are due by May 15 — see Notice 0f Comment Period.
February 27th, 2017
“Peak Demand” is the number they use to attempt to justify “need” for all sorts of abhorrent and expensive infrastructure, particularly infrastructure of the transmission variety. Here are the specifics in megawatts (MW):
So I think the economies are in decent shape across all our jurisdictions. Doesn’t necessarily mean it translates to high sales growth. And that’s consistent with our forecast. I mean, we’re not anticipating that we’re going to see a tremendous rebound in sales, even as the economies start to improve. I mean, I think, that’s our new normal, frankly.
Hence, they’re looking for other ways to make money, which they found in transmission, specifically CapX 2020 transmission, which was justified with this chart from MN Dept. of Commerce’s Steve Rakow, in his bar napkin depiction of the ups and down of peak demand:
Compare this drunken-dream drawing with the actual peak demand above — doesn’t look at all similar, does it. Nevertheless, we’ve been stuck with over $2 billion in transmission infrastructure build-out which we’re just starting to pay for, and just starting to see show up in rate cases. People are just now starting to get a feel for the economic impact, as if the environmental and quality-of-life impact isn’t bad enough…
Meanwhile, after going through years and years over CapX 2020, followed by the MISO MVP 17 project portfolio, now under construction, MISO wants to spring another bunch of projects on us. Their “Transmission Overlay.” Yeah, right…
Here’s the list, in a spreadsheet:
This is the MN, WI, SD, ND and some IA wish list weeded out from that spreadsheet (click for a larger version):
(N) Identify and develop opportunities to reduce customer costs by improving overall grid eﬃciency. In Minnesota, the total electric system utilization is approximately 55 percent (average demand divided by peak demand), thus providing an opportunity to reduce system costs by better utilizing existing system assets (e.g., generation, wires, etc.). (e21_Initiative_Phase_I_Report, p. 11).
And they want to build more? MORE?!?!
… check out tRump’s Executive Order 13766:
GRRRRRRRRRRRR! As if there’s not enough work to do these days… but you know, the work never ends for us “paid protesters.” And a woman’s work is never done either.
February 2nd, 2017
Xcel’s 2016 Earnings Call was this morning. Look at the above chart, pay close attention to the numbers I’ve highlighted in yellow. 2016 4th Quarter sales growth is down 0.6%. Yearly sales decrease is -0.3%. Here’s the rest of the Earnings Call Presentation:
Remember CapX 2020, based on projections of annual increases of 2.49%. Remember Commerce’s Steve Rakow who introduced the most bizarre chart ever in an effort to prop up need for CapX 2020, one without identifying the X axis or Y axis and just a sine wave trending sharply upward? Yea, this one…
Hasn’t worked out that way, has it… the 2016 10-K isn’t filed yet, so there’s only 2015 to go on, though looking at their 10-Q for summer, I expect it’s flat at best.
So with sales down, I presume it’ll be flat peak demand? It’s not disclosed in the 3rd Quarter 10-Q. Xcel, we’ll be looking for that this month in your 10-K filing!
October 8th, 2016
It was a long, long day. Bottom line? Based on the record, and based on acknowledgement of Xcel’s peak demand history, we can shut down Sherco 1 & 2 now without missing it, and by 2025 or so, shut down Prairie Island and not have to pay for significant rehab to keep it running.
Here is the PUC webcast:
Here is my handout, noting the 700-788MW overstatement of peak demand forecast.
With the “forecast” that much off, it’s as absurd as the CapX 2020 2.49% annual increase. Staff questioned the forecasts in the Briefing Papers, Commissioner Lange raised forecasts right off the bat, and Commissioner Schuerger claimed it was at least 300 MW off (don’t know where that 300 MW came from). These discrepancies havce been noted, and they should dig deeper, because the numbers used by Xcel do not add up. Were they lying in the SEC filings or are they lying now? Why isn’t Commerce challenging this, given admissions of the existing surplus? This forecast overstatement, plus admission of under-utilization of grid (meaning grid has been overbuilt, DOH, CapX 2020 and MVP projects are not “needed” in any sense) raises a few issues:
1) This misrepresentation is NOW equivalent to at least one coal plant, and by the end of 2030, or by the time presumed for shut down of Sherco 1 and 2, it’s much more than that.
2) This misrepresentation avoids consideration of shut down of Sherco 1 & 2 NOW, and shutdown of Prairie Island at the 2024-2026 time frame, and avoidance of $600-900 million in capital costs, or more, for Prairie Island.
3) This misrepresentation circumvents discussion of the admitted surplus now existing, even Dr. Rakow admitted to that at least twice in Thursday’s discussion. Where there is surplus, they can sell it elsewhere, and that is, after all, the purpose of CapX 2020 and MVP transmission.
Got that? We can shut down Sherco 1 & 2 now without missing it, and by 2025 or so, shut down Prairie Island and not have to pay for significant rehab to keep it running. This is not rocket science. It’s as simple as using actual peak demand as a starting point and not making up numbers as they have been doing.