Does anyone else think it odd, when solar projects in Wisconsin are in the 2-10MW range, to apply to site the 300MW Badger Hollow solar project when there are no rules?  Yeah, I know, it sounds like Minnesota siting 2,000+ MW of large wind projects with no rules and using small wind standards, way too similar.  But this is real.  300MW of solar is a LOT of solar.  It’s central station solar.  It’s on some of the best ag land in Wisconsin.  And it just happens to be on the route of the proposed Cardinal-Hickory Creek transmission line!

What to do?  Rulemaking, of course.  Yeah, we know how that goes (PUC denies Reconsideration re: Wind Rulemaking), but without rules, how will they reasonably site this project?  Without rules, how will they reasonably site any solar project?  So of course here we go, the Jewell Jinkins Intervenors’ solar rulemaking petition:

Petition for Rulemaking_JJI_Solar_FINAL_Signed

And Wisconsin’s PSC “ERFed” it today.  It’s docket 1-AC-254.  It’s my understanding that a comment period will be announced and then the Commission will decide whether or not to proceed with rulemaking.

Photo of DOE project in Alamosa, under 30 MW

There’s a 300MW solar project proposed for southern Wisconsin, in Iowa County.  Thing is, as with Minnesota and large wind (PUC denies Reconsideration re: Wind Rulemaking), there are no siting rules for solar in Wisconsin!  Really, no rules!  Typically thus far, solar projects are 2-10 MW.  This one proposed is 300MW!  Central station power to put it mildly.

Not only are there no siting rules, but there is no Environmental Impact Statement required for a project covering 3,500 acres!

WHAT?!?!

So on behalf of Jewell Jinkins Intervenors, I’ve just filed this Petition for Rulemaking to get them going on solar rules.

Petition for Rulemaking_JJI_Solar_FINAL_Signed

We shall see what, if anything, they do.

Lots of filing in Wisconsin

November 20th, 2018

Apparently Invenergy doesn’t like the idea that we’re intervening in their Wisconsin dockets.  I guess after Freeborn Wind, it’s not hard to understand why.

Intervention in Badger Hollow HUGE 300 MW solar project docket — approved by the Administrative Law Judge (Docket 9697-CE-100):

Jinkins Jewell Wendhausen_Intervention

Order_Interventions_11-1-2018

And then the related dockets, the transmission line and the acquisition docket, appropriately known as the BS docket, our intervention, their objection, and our response.  The transmission docket (Docket 9697-CE-101):

Jewell Jinkins_101_Intervention_FINAL

9697-CE-101 Badger Hollow – Response to Request for Intervention (Objection!)

Jewell Jinkins Intervenors_101_Reply to Objection

And the acquisition BS docket (Docket 5-BS-228):

Jewell Jinkins_228_Intervention_CORRECTED

Applicant Response to Motion to Intervene (Objection)

Jewell Jinkins Intervenors_228_Reply to Response

Oh, and the Cardinal Hickory Creek 345 kV Transmission Line!  Docket 5-CE-146.

Jewell Jinkins Intervenors_Cardinal-Hickory Creek_Intervention

To look up any of these dockets, go to the Wisconsin Public Service Commission’s Search site, and  plug in the numbers.

Meanwhile, we’re waiting on the Minnesota Commission meeting on Reconsideration for our Rulemaking Petition, and waiting on two orders, project and transmission, for Freeborn Wind.

And around all these filings, I’ve been to band practice, made wild rice and garbanzo salad, and I hear a Ferndale Market turkey calling…

What a long week it’s been!  WHAT?  Tuesday?!?!  No, really?!?!

Yes, it’s that time of year again, and today’s the deadline for Comments for the Power Plant Siting Act Annual Hearing:

PPSA_Overland Comment FINAL

And there ya have it.  Until next year…

These folks drive me crazy!  Katherine Kersten has been on my list since the 80s when she wrote an editorial in the STrib about student loans, praising the Reagan cuts to student loans, and major decreases in income limits for “need based” student loans, just at the time I was winding up my BA and trying to get into law school.  Who paid for her legal education?  Anyway, yeah, obviously we don’t see eye to eye on anything, but this latest blather from them goes beyond a difference of opinion, to a too frequent spewing of conflatulence. And when I see this, yeah, I get on a rant too, it’s kind of disjointed, so I’ll be reworking soon.  These claims are so insidious, because the facts do take some digging and some sifting.  Add to that there is so much misinformation going on about transmission, about the Clean Power Plan…  GRRRRRRRRRR…

Check this out:

Energy Policy in Minnesota: The High Cost of Failure

Yeah, this CAE thing is going around, it’s arrived in my inbox via clients working on wind projects, it’s arrived via a transmission person from ND who put it on my facebook page via a WindAction post, which cut and pastes another “reporters” blog about the CAE “Report.”  Playing “telephone” and we know how that goes… So let’s go straight to the horse’s … well, the other end.

This CAE “Report” is taking multiple things, trying to patch together an argument they want to make, but the patches aren’t holding.  This comes on the heels of another report that found its way into my inbox with the claim that wind is very expensive, that it costs about 8 times the PPA cost because it’s intermittent, and because of that, they added in cost of power to cover when wind isn’t blowing (ummmm, you only pay for what you use, at the PPA price, DOH!).

Point by point in the “report” from CAE, they claim:

Minnesota has lost its advantage on electricity

That’s true! But sorry, CAE, it’s not because of wind.  Rates have gone sky high in Minnesota for a couple of reasons. 1) Wholesale deregulation allowing sales from any Point A to any Point B, and 2) Transmission for coal and whatever else, from every Point A to every Point B.  It is NOT 3) Wind is higher priced, because it is not.

Reason one that are rates are as high as Illinois rates?  The economics of deregulation aren’t rocket science.  When you have something to sell, you sell to the highest bidder. If someone else wants it, then they have to pay the going rate.  A good resource on how we got to where we are is “The Economics of Regulation: Principles and Institutions,” by Alfred E. Kahn.  It’s a major tome, but hey, just read Chapter 2, the chapter on electricity, “The Traditional Issues in the Pricing of Public Utility Services.  Then, go back and read the introduction, where it gets into building more capacity than is needed, and the burden on ratepayers when utilities go overboard, particularly relevant when we get to the next point, that of overbuilding, and also consider the 105+ coal plants proposed but not built, including many coal gasification plants (i.e., Excelsior Energy’s Mesaba Project here in Minnesota and the NRG plant in Delaware, both of which I helped tank.  The Mesaba Project provided much needed details about the technical problems and economics of coal gasification and the impossibility of carbon capture and storage that doomed any project from the get-go. IGCC – Pipedreams of Green & Clean), and the economic and technological disasters of the new Vogtle and V.C. Summer nuclear plants,  and two coal gasification plants in Edwardsport , Indiana (coal gasification off more than on, often down completely) and Kemper IGCC in Mississippi (over $7 billion and now burning natural gas) that got off the drawing board but are economic disasters with ratepayers holding the bag.

Take a look at the cost of electricity, in real time:

FYI, here’s some wallpaper for ya, with the MISO Market LMP price in real time (keep in mind, this is spot market, so prices higher than PPA prices):

https://www.misoenergy.org/MarketsOperations/RealTimeMarketData/Pages/LMPContourMap.aspx

Check this slide from FERC info on EIA page:

What? Delivery costs?  Oh, TRANSMISSION!!  (full story from EIA HERE)

Note also, from the same EIA post, the shift away from Power Purchase Agreements that came with the decrease in demand electricity glut:

Now, let’s move on to 2) Transmission for coal and whatever else may happen to be there, from every Point A to every Point B.

When you’re thinking about this, and about all the whining about shutting down coal plants, remember that the older very high priced to operate coal plants are being shut down.  What about other plants?  If all, if the majority, of coal plants were shut down, what would that mean for the transmission system?  This is important — if those plants were shut down, there would be lots of room on the transmission system.  But they didn’t. Instead, they built this huge transmission overlay called CapX 2020, at a cost of over $2 BILLION, and are now building the MISO 17 project MVP Portfolio (see MVP Dashboard  — now up to $6.6 BILLION).  MISO is now talking about a Regional Transmission Overlay above those (click on the maps in the link, AAACK!).  Check the 20170131 EPUG Preliminary Overlay Ideas List. Get your pocketbook ready to pay for this. And for your nightmares, piece by piece:

In the process of getting from any Point A to any Point B, we’ve overbuilt transmission to the point that Xcel Energy is whining that the grid is only 55% utilized.

(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).

OK, let’s look at “any Point A to any Point B.”  Where does this CapX 2020 that started the big transmission build-out start and where does it end (keeping in mind it began with WIREs and WRAO released in 1998, they’ve built almost all of those proposed then)?

Well, fancy that.  It starts in the coal fields of the Dakotas, at the major coal plants fueled by the neighboring coal mines.  Oh, and look, it goes east to the Madison ring and off to Illinois… huh… funny how that works…  Now, think about what it means for “pass through” Minnesota!

How about the MISO 17 project MVP Portfolio, again, now priced at over $6.6 BILLION (it was $5.24 billion when approved by MISO):

MVP portfolio map

And the addition of the capital costs of these projects to the rates has not been adequately considered.  Xcel admits in its latest rate case initial filing (15-826), now water over the dam, that it’s transmission driven.  In the CapX 2020 cases that No CapX 2020 intervened in, the Certificate of Need and multiple routing dockets, we were not able to raise rate issues, consistently and adamantly told that no, that can only be addressed in rate cases.  Was Center of the American Experiment there? Nope.  They were just agitating to get people to comment, but no substance. Maybe if they’d read the rate case dockets, they’d have some credibility, but nooooooo.

Look at PUC Rate Case Docket 15-826, and the one before it, 13-868. What is driving Minnesota’s price is not wind (it’s much lower PPA price than any other resource) but transmission. We’re now paying for CapX 2020 transmission and the MISO MVP 17 project portolio (an apportioned share). Transmission ROI is 12.38%, though it’s in a fight at FERC which will lower it to maybe 9+%, which is much more than they get on electricity because price is so low. We are also now paying for rebuilding the Sherco 3 coal plant which was down for two years after the turbine went wild and blew up, and that rehab was over budget (2 years that power wasn’t needed, but rebuilt it anyway and we’re paying!). And the Monticello nuclear plant rehab and uprate which cost twice as much as they thought (and so because of too high cost and lack of need, they started but then cancelled the same at Prairie Island here in Red Wing). (the electric market is so bad, prices so low, that Xcel is wrangling to have its “business plan” determine rates, not cost! And they want to focus on building things to get that ROI which is a lot higher.) Center of the American Experiment is not a credible source, they do this sort of thing all the time to advance their agenda, and don’t dig into the facts.  WindAction latches on to this, without looking for details, facts. That comes out in the rate case.

I tried, both individually and on behalf of No CapX 2020 to intervene in the most recent rate case (15-826) because CapX and MISO MVP transmission is the driver, and got into quite a testy fight with the ALJ, Judge Oxley.  He was so extreme in his resistance, worked so hard to exclude No CapX, beyond anything I’ve ever seen before.  When I presented at the public hearing, he refused to allow cross examination of the witnesses, said he wouldn’t require their witnesses to be present at the hearing, and started yelling at me, all on the record, and it looked like he was about to start crying, eyes red and watery, shaking visibly. It was so bizarre.  Details here – particularly the Denial #2_Overland-NoCapX Intervention where he declared NO, NO intervention in a very pissy way, and despite this being the rate case, and throughout the CapX 2020 dockets (all 5 of them over 8 years!) and ITC’s MISO MVP Line 3, where we were repeatedly prohibited from addressing rate impacts, nope, no intervention in the rate case:

And here’s an interesting tidbit exposing Xcel’s failure to pay taxes, in essence a public subsidy of Xcel:

Xcel Energy Rate Case — taxes & xmsn rider

June 27th, 2016

From my NoCapX2020 site:

Xcel Rate Case in CapX territory

Well, look who’s intervened in the rate case!

Also, note how CAE goes into a spiel about wind “subsidies” but they don’t address that ALL forms of generation are subsidized, with nuclear getting the most expensive of all, coal second (and shall we get into subsidies for failed IGCC/coal gasification? OH MY DOG!). I have no time for these “subsidy” arguments when there’s no charge to remove ALL subsidies for energy across the board.  They also talks about wind needing coal as “backstop.” Ummm, no, that’s natural gas. Coal can’t ramp up and shut down quickly. Natural gas can and does.  Shame, they should know better… Coal as “backstop.” Good grief. And on top of that, they try to argue that the cost of backup power for intermittent should be considered as part of the cost of intermittent?  Oh, right… tell that to the natural gas plant operators, tell that to those negotiating PPAs for intermittent power!  What a hoot!  FYI, no, it doesn’t work that way.

And here’s a simple way to clairfy — think about what it would mean if they shut down the coal plants, as we keep hearing about… would we need ANY new transmission?  And think about what we’re paying in our utility bills to shuffle this power eastward.  Which we’ll get back to further down, and now, on to the next point:

Minnesota’s energy policy primarily promotes wind power.

Yeah, that’s true, wind and solar.  For years wind has been a “least cost” option, as declared by the Dept. of Commerce and the Public Utilities Commission, as they do the Integrated Resource Planning and review of Power Purchase Agreements.  But don’t forget when talking about energy policy, the massive promotion and subsidization of coal gasification, which even with all the push, couldn’t make it.  It was tossed out of the PUC based on the outrageous costs, despite the state subsidies from several sources, and federal bankrolling, grants, and subsidies (for more info, search here for “Mesaba” and “IRRB,” “Mesaba” and “DOE” and just “Mesaba” and scroll through. There’s a lot, that was a 5+ year fight.).

CAE states that there will be only “modest increases in solar,” and that’s way off, both for commercial and residential.  Watch!  FULL DISCLOSURE: My father designed the solar at the Minnesota Zoo (which was hot water, they didn’t know much about that in early-mid ’70s and produced way too much, was taken down, and the pieces parted out across Minnesota — Ralph Jacobson, IPS knows more about that.).  Solar is best because it produces on peak, is storable, particularly at a residential level, and it’s right where load is.  Why isn’t every big box in Minnesota covered with solar?

Minnesota has also policy-wise, or unwise, pushed biomass, which has been an economic disaster and Xcel Energy has cut the “biomass mandate,” and is trying to get out of the PPAs for biomass plants that they don’t own, and working to slash the price at the HERC garbage incinerator. Biomass, high priced as it is, however, is a very small percentage of total generation.

Minnesota energy policy also focuses on conservation and efficiency.  Conservation is by far the cheapest, because if you don’t use it, it doesn’t cost a thing!

And look at Xcel Energy demand over the years:

It’s Xcel Energy’s, and the utility industry world’s, “new normal,” as Xcel’s CEO Ben Fowkes calls it.  Here’s their 2017 3Q powerpoint that came out with their 3Q investors call: CLICK HERE!  New capital investment of $1.5 billion and “Targeted ownership” = “Steel for Fuel” plan, making money off capital costs, and significant decrease in fuel costs.  Base capital plan of $19 billion = ~5.5% rate base growth — that’s the point! Making money in a way that’s not dependent on selling electricity.  And slide 10, Minnesota’s 0.5% DECREASE in sales, overall Xcel 0.2% growth.  The “new normal.”

Minnesota’s energy policy is falling on its own terms, as it has not achieved a significant reduction in CO2 emissions.

True, but…  This is an area of conflatulence.  State policy promoting wind DOES NOT EQUAL reduction of CO2 — it only equals building wind.  Building billions of MW of wind will not decrease CO2 emissions.  Closing coal plants will.  Stopping burning will.  That’s the only way.

Minnesota has not closed all, or even most, its coal plant generation.  We have only closed some of the older coal plants that are not economical to run.  Look at Sherco 3, a plant that had a major turbine failure and fire and was off line for nearly two years and was rehabbed to the tune of over $200 million.  With that plant off line, CO2 emissions would have been greatly reduced, were in fact greatly reduced, but the Clean Power added those emissions back in for their modeling!  WHAT? Here’s the poop on that:

Look at how the “adjusted” Minnesota’s baseline levels due to Sherco 3 being out for nearly 2 years:

The EPA examined units nationwide with 2012 outages to determine where an individual unit-level outage might yield a significant difference in state goal computation. When applying this test to all of the units informing the computation of the BSER, emission performance rates, and statewide goals, the EPA determined that the only unit with a 2012 outage that 1) decreased its output relative to preceding and subsequent years by 75 percent or more (signifying an outage), and 2) could potentially impact the state’s goal as it constituted more than 10 percent of the state’s generation was the Sherburne County Unit 3 in Minnesota.  The EPA therefore adjusted this state’s baseline coal steam generation upwards to reflect a more representative year for the state in which this 900 MW unit operates.

Clean Power Plan Final Rule (PDF p. 796 of 1560).

… sigh… much ado about nothing.  But remember, it’s not binary.  Wind isn’t “replacing” anything.  Wind is added on top of the existing generation, of which we have a surplus before it’s even added.  Once more with feeling, WIND ISN’T REPLACING ANYTHING! We could shut down those coal plants now and wouldn’t miss them, but then the utilities couldn’t sell the surplus generation, couldn’t make money providing transmission service from Point A to Point B, and couldn’t make money on capital costs of transmission with a much higher return for building transmission than for selling electricity.

Here’s more on that, from a study released when they were working to get the transmission scheme rolling.  The purpose of MISO Midwest Market — where ever would I get the idea that the purpose of it is to displace natural gas with coal generation?

ICF MISO Benefits Analysis Study

Well, look at pps. 14 and 83:

RTO operational benefits are largely associated with the improved ability to displace gas generation with coal generation, more efficient use of coal generation, and better use of import potential. These benefits will likely grow over time as:

• Reliance on natural gas generation within the Midwest ISO footprint grows as a result of the ongoing load growth and a general lack of non gas-fired development over the last 20 years. This may increase the scope for potential savings from centralized dispatch in future years.

• Tightening environmental controls and the resulting greater diversity in coal plant fleet variable operating costs will make optimization of coal plant utilization more important in future years.

• Tightening supply margins throughout the Eastern Interconnect over the next three to five years increase the importance of optimizing interchange with neighbors such as PJM, SPP, and others.

• Transmission upgrades which could increase the geographic scope of optimization within the Midwest ISO footprint.

Again, the purpose, to sell from any Point A to any Point B.  That’s what it’s all about!  It has nothing to do with displacing coal with wind, and it has nothing to do with taking coal off line, shuttering plants, and it has nothing to do with reduction of CO2 through reduction of burning to generate electricity.

To satisfy Minnesota’s renewable energy standard, an estimated $10 billion dollars has been spent on building wind farms and billions more on transmission.

When talking about costs, True, lots has been spent on building wind farms.  However, until very recently, utilities have not been spending those billions of dollars, the wind developers and wind companies have, and utilities are buying the energy via Power Purchase Agreement, and not spending the billions of capital costs, instead letting the independent power producers do it.  There’s a big difference there between PPA and capital costs, and CAE does not acknowledge it, and does not acknowledge that we’re being billed for PPA costs and not capital costs in most instances.

Billions on transmission, yes, that’s true, as above, but that transmission is not for wind.  It’s for wheeling their surplus power through Minnesota and out of the state, whatever power is there, and remember, those lines start at the coal plants!  Again, check the ICF MISO Benefits Analysis Study to see why they want to build all this transmission.

$10 billion capital cost spent building wind farms? Compare with the $29 BILLION cost of building two nuclear reactors, 2,200 MW, at Vogtle, which will never run. Building generating plants of any sort costs money.  The failed Mesaba Project coal gasification plant was expected to cost, at last estimate by DOE, over $2.1 billion, for 663 MW.  Failed Kemper IGCC 582 MW for $7.1+ billion. As of year end, 2016, there was over 3,500 MW of installed wind capacity $10 billion capital cost?  Cost comparison anyone for construction of generation?

I want people to know that relying on pieces like this is not a good idea!  Sending around these “reports,” i.e., the CAE “report” with its many misstatements about things where the authors they should know better, is not helpful because it’s a false spin, FAKE NEWS from the masters of misrepresentation.  This rate issue and cost of generation, the decreasing demand and increasing conservation, and transmission for coal is something I’ve been enmeshed in for a long, long time, and I can’t let stuff like this slide.