Legalectric

Ameren Transmission Company (ATXI) has filed lawsuits in two Missouri counties, Adair and Marion, challenging the county decisions to reject the “Mark Twain” transmission line (isn’t there some copyright or defamation law preventing use of Samuel Clemens’ “name” that way?).

What exactly did the counties do?  Well, the counties need to approve or deny the Mark Twain transmission project, a condition of the Missouri PSC permit for the project, under the terms of the permit:

Adair and Marion Counties said NO!  Ameren Transmission Company seems to think they have no right to say NO!

The actions of the counties sounds reasonable… and Ameren’s pleadings are mostly repeated whining that they were not invited, not notified, and that County Commissioners oppose the Mark Twain transmission line.  GASP!  They even attended a PSC meeting and opposed the line:

Ameren’s position seems to be, “How dare they!”  Ameren, it might be wise to consider who it is that these Missouri County Commissioners represent.  They’re elected officials, and Ameren was not elected to office, and they Commissioners’ job is not to represent Ameren!  DOH!  What a concept!

Here are the pleadings filed by Ameren in Adair and Marion Counties:

Ameren Transmission Co. v. Adair County

Ameren Transmission Company v. Marion County

Kudos to the County Commissioners for standing up!  And a big thanks to attorney Paul Henry for the heads up and forwarding the primary documents — it sure helps to know the whole story!!!

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.

Legalectric_Handout_IRP

If you start with Xcel’s 2015 actual peak demand, and extrapolate using the 0.3% annual increase out to 2030, here’s what it looks like (click for larger view):

These are the charts that they’re using, starting with inflated forecasts of 9,409 and 9,442MW for 2016, note how far off the resulting 2030 “forecast” is — it’s 800 – 1,234 MW off!

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.

Here’s to preservation, download quick to have this bit of history:

Just in (well, it came in a while ago, but I was being tortured at the U of M Dental Clinic):

Minnkota Request for Withdrawal of Clearbrook-Clearbrook West 115kV Transmission Line  20169-124828-01

YES!!  Now, a quick Comment for the record, essentially a thank you note, PUC staff Briefing Papers, a Commission meeting, and Clearbrook is DONE!

Today was Deadline #1 for Comments on NDPC’s Petition for Withdrawal of the Sandpiper pipeline Certificate of Need and Route applications.  Here’s what was filed:

Sandpiper_Landowner Comments_Xmsn

Yup, that’s it.  My Sandpiper transmission clients weighed in.  I’ve been watching the docket, watching the inbox for service…. NO other comments, nothing, nada…

Just get to it.  Quick – take a few minutes and send a missive to the Public Utilities Commission encouraging them to allow Enbridge to withdraw their application for the Sandpiper pipeline WITH PREJUDICE so that they can’t refile it again.  Send to:

Daniel P. Wolf, Executive Secretary  (dan.wolf@state.mn.us)                        Minnesota Public Utilities Commission                                                           121 Seventh Place East, Suite 350                                                                    Saint Paul, MN  55101-2147

Ann O’Reilly and James La Fave, Administrative Law Judges
Office of Administrative Hearings
600 North Robert Street
P.O. Box 64620
St. Paul, MN 55164-0620

But it doesn’t end there, with zip comments… it gets weirder.  I’d saw there was no notice from the PUC about a comment period, nothing.  Here’s what they did with Hollydale, Notice, and there was a comment period and reply comments!  In that docket, Xcel Energy filed to withdraw its Hollydale applications on December 10, 2013, and this notice was issued on January 10, 2014:

20141-95340-02 Notice of Comment Period

Here’s what we got:

And when I asked:

Here’s the response:

Oh my… what do I do with that?  Guess I write a post about it!!!