Legalectric

It’s that time of year… the time that we get to tell the Public Utilities Commission what does and does not work about the Power Plant Siting Act.  We’ve been doing it for years, 15 or so years, and have spent over a year now in a rulemaking on the PUC’s rules, Ch. 7849 (Certificate of Need) and Ch. 7850 (Power Plant & Transmission Siting) where some of these long complained of problems will be address (with any luck).  And now, again, it’s time to reinforce those comments with another round of comments:

After the hearing, now officiated by an Administrative Law Judge (new as of a few years ago), a report is issued to the PUC and then ???  It used to go to the legislature, and it used to go to the EQB… guess I have to find out what happens now.

December 19, 2014 beginning at 9:30 a.m.

Public Utilities Commission

3rd Floor Large Hearing Room

121 – 7th Place East

St. Paul, MN  55101

Each of you who have experience siting and routing of large electric energy facilities — this is the time to weigh in.  Remember that this is NOT project specific, it’s not about where a project goes of whether it does, but it’s about how the process works or doesn’t, so for example, it’s the time to let them know that notice isn’t being provided, or that witnesses should be sworn on oath so that testimony will be given more weight, etc.   You can do it in person, and you can do it by filing comments.

Here is the Power Plant Siting Act, which governs the siting and routing of large energy facilities:

Power Plant Siting Act – 216E

Here are some prior dockets (to access the entire docket, individual comments, etc., go to the PUC’s “SEARCH” site and plug in the docket numbers :

2000 Summary of Proceedings

2000 Report EQB

2001 Summary of Proceedings

2001 Report EQB

2002 Summary of Proceedings

2002 Report to EQB

2003 Summary of Proceedings

2003 Report to EQB

2004 Summary of Proceedings

2004 Report to EQB

2005 Report to PUC

2006 Report to PUC – Docket 06-1733

2007 Report to PUC – Docket 07-1579

2008 Report to PUC – Docket 08-1426

2009 Report to PUC – Docket 09-1351

2010 Report to PUC – Docket 10-222

2011 Report to PUC – Docket 11-324

2012 Report – Docket 12-360 –2012 Report Exhibits

2013 Report  – Docket 13-9650143-96999-01

There’s the Forbes article about American Wind Energy Ass (AWEA) advocating for this massive mess of new 765 kV lines.

Experts: Reducing Carbon Emissions and Increasing Grid Reliability are Doable

Experts?  Ummmm, AWEA?  No, they are NOT transmission experts, they are only expert in doing what their masters pay them to do.  Here’s their “vision” from a couple of years ago:

Green Power Superhighways

Report – Update to the Superhighways report that AWEA’s Michael Goggin wrote in fall 2013.

In Minnesota, there’s one paralleling the CapX 2020 line, then another cutting the state in two from Big Stone to the Metro, and another from Split Rock to Adams along I-90.  Who the hell do they think they are to advocate for this overkill of transmission?  And note that in the Dakotas, as always, they start at the big coal plants.  Infrastructure like this is the best way to assure coal never shuts down, adding capacity instead of shutting coal down and using that capacity.  And if they do it this way, then they can run our coal plants forever.  Oh, right… this is the plan AEP supports.

First and foremost, remember that this is about economics — money and profit from building transmission and providing transmission service — the grid IS electrically reliable, so says NERC in its latest State of Reliability 2013 Report:

And here’s the NERC Report (one should be due out soon, used to be October, but they’ve pushed it back):

2013 NERC Reliability Assessment

What strikes me is that so many are willing to believe that the electric grid is not “reliable” and are willing to attribute economic issues like “congestion” to claims that the system is not reliable.  And then there’s their successful effort to shift cost allocation so that the generators no longer pay for transmission necessary to access and safely operate the grid.  In the past, generators paid, but then in the gas plant surge over a decade ago, so many were built without transmission upgrades that we were in transmission deficit, evidenced in the 2001-2004 SW MN 345 kV Four Certificates of Need (MN PUC Docket 01-1958).  Check this TLTG Table, click for a larger version:

For their 1-H option, the one that the enviros agreed to in this project, acquiesced to (remember, this was the project where they got a group together and asked “What would it take to support this project?”), the system starts out with a 1475 MW deficit.  It’s not until they’ve fixed some long standing problems, such as the sagging Wilmarth line, and the FT. CALHOUN INTERFACE which is in the base case (!!!!), and after spending over $138 million including their wide ranging “base case” of necessary fixes, that they start actually adding some system capacity.  DOH!  Give me a break…

The real problem is failure to make those added generators pay for fixing the system impacts, and then the desire to add wind projects without making them pay for system impacts, and more importantly, of wanting to add wind on top of the existing coal generation, without removing the coal which would make plenty of room for wind.  The price of their wanting to “find a way forward for coal.”

American Wind Energy Ass, how dare you.  This one’s for you:

From AWEA’s 2012 IRS 990 (the most recent one on Guidestar), p. 25 and 29:

AWEA_2012_IRS990

For an update on Testimony filings last week, hop over to “Not-so-Great Northern Transmission” and check it out:

Rebuttal Testimony filed in GNTL Certificate of Need docket

One small step… and a giant leap!  A transmission easement settled, and at more than twice the original offer.  Yeah, we can live with that.

The troubling thing is that the appraisal didn’t really make sense, and they way they came to the appraisal amount didn’t add up.  But despite that, the bottom line was good, so we’re not going to quibble.

Onward, heading up north for transmission hearings for the Not-so-Great Northern Transmission Line.

I’ve been saying this for so many years, that electric demand is down, down, down, and instead, Xcel Energy (and all the others) have been saying it’s going UP, UP, UP (even though Mikey Bull said years ago that they wouldn’t need power for a while), and they’re applying for and getting Certificates of Need for all these permits for utility infrastructure that are obviously designed to market and sell the surplus, and the Public Utilities pretends to be oblivious (I say “pretends” because I cannot believe they’re that unaware and uninformed.).

This is a must read:

Xcel Compliance Filing_CN-13-606_20149-103251-02

Here’s the short version from Xcel:

2024 is expected to be about what it was back in 2007, the industry peak year.  DOH!  But note this — there’s a “small capacity surplus in 2016.”  DOH!

And given the surplus which we’ve known has been present and looming larger, that’s why they then ask for withdrawal of the Certificate of Need for the Prairie Island uprate because it isn’t needed (and really, that was just what, 80 MW or so?  Or 80 MW x 2 reactors, 160 MW?).  If they don’t need that small uprate, why on earth would they need so much more?

But what do I know…

Hollydale Transmission Line was clearly not needed, and they withdrew that application…

CapX 2020 transmission was based on a 2.49% annual increase in demand, and for Hampton-La Crosse in part supposedly based on Rochester and La Crosse demand numbers, yeah right, we know better, but that was their party line.  Again, DOH, it didn’t add up to needing a big honkin’ 345 kV transmission line stretching from the coal plants in the Dakotas to Madison and further east, but who cares, let’s just build it…

ITC MN/IA 345 kV line — the state said the 161 kV should be sufficient to address transmission deficiencies in the area, but noooooo, DOH, that wouldn’t address the “need” for bulk power transfer (the real desire for the line).

Here’s a bigger picture of the bottom line (I’m accepting this as a more accurate depiction, not necessarily the TRUTH, but close enough for electricity), keeping in mind that these are PROJECTIONS, and that they’re adding a “Coincident Peak adjustment” which should be included in the “peak” calculations):

Notice the only slight reduction in coal capacity, just 19 MW, nuclear stays the same, a 320 MW decrease in gas, a 128 MW reduction in Wind, Hydro, Biomass, which I hope includes garbage burners and the Benson turkey shit plant , slight increase in solar of 18 MW, and Load Management also a slight increase of only 80 MW.  This is Xcel Energy with its business as usual plan, which has to go.  We can do it different, and now is the time.

Will someone explain why we paid so much to uprate Monticello, and paid to rebuild Sherco 3?

From the archives:

500+ give LS Power a piece of their mind