Legalectric

Time for a nap.  Just filed Comments on the USDA RUS’s Environmental Assessment for Dairyland’s Q-1 D South transmission line.  Here’s the EA:

Q1-South_Environmental Assessment

And here are the Comments I filed on behalf of No CapX 2020:

No CapX 2020 EA Comment_July 1, 2016

zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz

Oh, and the interesting thing is that just this morning, I got a copy of the “Briggs Road-La Crosse Tap 161 kV Rebuild Study”  Thank you, Chuck Thompson!

Dairyland Power Cooperative’s transmission through Onalaska and La Crosse is something to see…

Dairyland Power Cooperative and USDA’s Rural Utilities Service has released the “Q-1D South” Environmental Assessment, open for Comment until July 1, 2016:

Q1-South_Environmental Assessment (BIG FILE)

And from Dairyland’s site:

Briggs Road to La Crosse Tap (Q-1D South) – Environmental Assessment

Comments are due July 1, 2016 — send to:

USDA’s Dennis Rankin:  dennis.rankin@wdc.usda.gov

(I’d also cc DPC’s Chuck Thompson:  cat@dairynet.com)

By U.S. Mail:

Dennis Rankin

Environmental Protection Specialist

USDA Rural Utilities Service

1400 Independence Avenue S.W.

Mailstop 1571, Room 2242

Washington, DC  20250-1571

What’s to comment on?  I see two issues that should be sufficient to stop this project in its tracks — the debt load of Dairyland Power Cooperative and the physical setting of the project which too near and right over people’s homes.

Debt load — Dairyland Power Cooperative’s debt is excessive and should prohibit taking on more debt:

Dairyland Power Cooperative’s Annual Meeting was last week.  One purpose of an organization’s Annual Meeting is to discuss its financial status and approve plans going forward.

Dairyland depends on federal USDA/RUS loans to pay for its transmission expansion, such as the Q-1 transmission upgrades, including Marshland-Briggs Road and now the stretch from Briggs Road to North La Crosse south of I-90. Another USDA/RUS loan paid for Dairyland’s share of the CapX La Crosse line now blighting the bluffs. Dairyland will also be part owner of the MISO Hickory Creek to Cardinal line from Iowa to Madison. That’s a lot of transmission and loans.

Dairyland recognized this financial risk and lopsided debt/equity position, and in 2012 sought help from FERC_(DPC_Request4DeclaratoryOrder), requesting a hypothetical capital structure of 35 percent equity and 65 percent debt when its actual capital structure was 16.5 percent equity and 83.5 percent debt, and FERC did grant this relief in an Order for DPC for CapX 2020 (see FERC Docket, go HERE and plug in docket EL13-19-000).  That Order, and the 83.5/16.5% debt/equity ratio was prior to the present Q-1 D South project and the MISO MVP Hickory Creek to Cardinal transmission line.  Dairyland requested a “hypothetical” (bogus) debt/equity ratio to preserve its credit rating and enable low cost loans. The true debt level makes DPC a higher risk.

Are Dairyland members aware of the 83.5%/16.5 % debt/equity ratio and reliance on loans for major transmission projects? What’s the debt level where new projects are included? This new transmission enables increased power marketing and sales, a private purpose. Is this highly leveraged position for new transmission in the best interests of Cooperative members?

Physical setting of the project — it’s just too close!

The map way above is what the transmission system in the area looks like theoretically, according to the Wisconsin Public Service Commission, but here’s what Dairyland’s Q-1 South line looks like on the ground:

Really… Here’s what it looks like from a satellite with the lines drawn in, on the far south:

Here’s what it looks like further north — look at all those homes:

And here’s what the Wisconsin PSC Code says about clearances in PSCW 114.234:

(2) Transmission lines over dwelling units. [Follows NESC 234C1b, p. 119] (Addition) Add the following paragraph c:

c. Transmission lines over dwelling units.

No utility may construct conductors of supply lines designed to operate at voltages in excess of 35 kV over any portion of a dwelling unit. This provision also applies to line conductors in their wind-displaced position as defined in Rule 234A2.

Note: It is the intent under s. SPS 316.225(6) that the public not construct any portion of a dwelling unit under such lines.

Note: The term “dwelling unit” has the meaning given in ch. SPS 316, which adopts by reference the definitions in NEC-2008.

Note: See s. SPS 316.225(6) Clearance Over Buildings and Other Structures, which refers to ch. PSC 114 regarding clearance of conductors over 600 volts and the prohibition of dwellings under or near overhead lines.

Remember Xcel Energy’s Hollydale Transmission Project that was derailed when it was clear it wasn’t needed, and so Xcel Energy withdrew the application with regular compliance reports on status of the project, and a promise of a need study so long ago???

Yeah, I’ve been forgetting too, it’s been so long.  Here’s Xcel Energy’s page on what’s now called the “Plymouth Project.”

But, here it is!!  Finally, it has arrived, the Hollydale System Assessment Report from Xcel Energy that we’ve all been waiting for:

Plymouth_and_Medina_Electrical_System_Assessment-Final_Complete

Pay particular attention to the map above of the “study area,” and note that it is the Interstate 494/694 ring and Hwy 55 to the east and north where the problems are, and the problems are yellow and orange, and not red.  The problems are not in the area of the Hollydale substation and not to the west, towards Medina.

When do we start seeing problems?  Looks like it’s in 2036, 20 years from now, double the usual 10 year transmission planning outlook (hint, that means it STILL is not needed) — and note, again, the problems are to the east and north, along the highways:

I’ve got to scour this report, but I do not think that they’ve considered select placement of distributed generation, i.e., solar panels on all the big boxes in the areas above in red!  Or residential solar on those in yellow.  What’s so difficult about that?

Here’s their choice:

On the plus side, there’s new substations planned in the red territory.  On the minus side, they still want to utilize the Hollydale substation.  On the plus side, they plan to expand transmission using 34.5 feeders, which is what I promoted as a solution.  On the minus side, they plan to keep the 69 kV line through Plymouth, with an eye on utilizing it in the future.  On the PLUS side, they claim that there’s no impact on the Hollydale – Medina section of the 69 kV line, claim that there’s no change from present use and non-use, and for my clients in Medina, that’s a good thing.  On the MINUS side, they don’t propose to tear that “unused” 69 kV line down.  On the MINUS side, they don’t propose to put all the transmission and distribution underground.  And remember, just yesterday, when there was a large distribution outage due to wind out in the western suburbs?

So now, it’s time to read this report!

50 years ago, on a family vacation, we went to Ft. Peck, stayed at Hell Creek State Park, which more than lived up to its name then, with miles and miles of nothingness, except for the Park Ranger and his trusty pup.  He’d spent his day shooting rattlesnakes, he had a bagfull of them, and showed them to us, advising that we keep an eye open!  The coolest, and hottest, camping experience ever.  So of course I’ve wanted to go back, and this is the perfect time.  It’s cool at night, and it had rained the night before, and it was SO green, blinding, and not at all like the desolate wasteland I’d remembered.  Same spot 50 years later… (how did THAT happen?)

The park is in a pickle, seems there’s no money available for needed improvements, like a single phase line that’s at capacity (AACK, just found a tick!  Now it’s a dead tick!), septic over capacity, and tens of thousands of folks come there to fish. They put together a “Master Plan” but it wasn’t clear the purpose, and instead of being a Master Plan, I think it was a way to set out the issues facing the Park and to try to figure out what to do about it.

Hell Creek State Park (Montana) – Comments due 11/25

I don’t get it, it’s a foreign world to me.  Everyone there had a big honkin’ pick up truck, and a 5th wheel and towing a big boat that probably cost more than my house!  And if they didn’t have the three part rig, they pulled a YUGE trailer and a friend pulled the YUGE fishing boat.  To get there, it’s a 26 mile drive over washboard gravel, with so much dust that I don’t know if it will ever come out of the van.  Washing it might induce a mudslide!

Not all that far away in miles, but a trip out and back over that long dirt road, is the Ft. Peck dam and power house, and so of course I called up and arranged a tour.  Very cool, but no photos allowed.  I recognized the museum, the first part of the tour, from 50 years ago, back in the days when we took family “utility infrastructure” trips.  And guess who worked on the dam?

There are two power houses, one, the oldest, with three turbines and a 105 nameplate capacity, and two in power house #2, which have a 80 MW capacity.  One of the turbines in unit 1 is being replaced, is much smaller, but will be much more efficient and have a higher capacity.

Ft. Peck is the largest earthen dam in the world!  The Army Corps built a handful of dams on the Missouri, Ft. Peck, Tarrison (400 MW)(where we are now), Oahe (595 MW), Big Bend (468 M), Ft. Randall (320 MW), and Gavins Point (100 MW).  Most of these are probably overdue for serious rehab.

Between all of these dams, there’s some serious power generation going on, but there’s also a problem with low water levels, putting generation at risk and requiring a FERC docket to address allocation.  And of course, I was wondering where they sell the power, and it’s operated by the Army Corps to this day, and power is sold through the Pick-Sloan Missouri Basin Power Marketing Area and Western Area Power Authority (WAPA).  Dispatch is supposed to happen out of a complex in Watertown, SD.  Transmission out of Ft. Peck runs mostly east, but some to the west!  From Ft. Peck, there are two 115kV lines, one 230 kV line, one 161 kV line, one 69 kV line, and one 34.5 kV line.  Of the big collection of dams, there’s a transmission network moving the energy around:

Little is said about the impact of the flooding on the Assiniboine Nation, which met Franklin D. Roosevelt on August 6, 1934, to address those issues when he came out to cheer on the construction efforts.  Now there’s “Ft. Peck” Reservation, north and east of the dam.  The impacts of flooding on First Nations was part of the FERC docket regarding allocation, because a decrease in output and change in allocation will likely have an impact on local residents:

PICK-SLOAN MISSOURI BASIN PROGRAM Eastern …

From the “Answers” to comments, it seems FERC didn’t see it the same way:

DOE WAPA_2011-29601

And now we’re on to our second dam of the trip, Garrison Dam, and Ft. (not Grant) Stevenson, which has a great campground.  Very nice, though sites are too close together.  And once again, everyone has these huge rigs, some crammed in 3 to a space, circling the wagons, with a big campfire in the middle where they all hang out.  I can’t help but snort, because many don’t know how to back up!!!  There oughtta e a law, can’t back up — can’t go forward.  And campgrounds accommodate these sorts of folks by making half the sites pull-throughs.

So anyway, on to the Soudan Mine and neutrino lab.  How much fun can I stand?

Be there or be square — transmission open houses in eastern Iowa near Dubuque and southwestern Wisconsin near Cassville.

Monday, May 16 –
Peosta Community Center
7896 Burds Road
Peosta, IA 52068

Tuesday, May 17 –
Pioneer Lanes
1185 US (Business) 151
Platteville, WI 53818

Wednesday, May 18 –
Deer Valley Lodge
401 West Industrial Drive
Barneveld, WI 53507

Thursday, May 19 –
Deer Valley Lodge
401 West Industrial Drive
Barneveld, WI 53507

Where’s Art Hughes when you need him??

Art Hughes has died…  March 31st, 2009

Days before he died, Art Hughes was testifying in Peosta against an ITC transmission line heading east to Peosta, here’s the photo from that hearing, and the article about it is in the “Art Hughes has died…” link above.

And now they’re doing another round of open houses, yesterday in Peosta, IA.  Wherefore Art thou?  Well, Art, where are you?  I guess they remember him, because this time it’s “open house” and not a meeting/hearing.  These “open houses” are held by ATC, ITC, and Dairyland about its plan for the Cardinal-Hickory Creek Transmission Project.  This project is the southern part of the “5” project on the MISO MVP project map below, from the Hickory Creek substation (near Dubuque) to the Cardinal substation (near Madison)(the northern part of 5 is the Xcel/ATC Badger Coulee line).  It’s one of the transmission lines that fills in the 345 kV transmission gaps to enable North & South Dakota to Chicago bulk power transfer.

Once more with feeling: Open House Schedule — each starts at 4 p.m. and goes until 7 p.m. (hello, ITC, it’s planting season, how convenient!):