Legalectric

Just filed in the ITC Midwest MN/IA transmission case — because Minnesota Center for Environmental Advocacy, Wind on the Wires, Fresh Energy and Izaak Walton League refuse to answer Information Requests:

CETF and NoCapX2020’s Motion to Compel

It’s important that they disclose, and important that the record reflect, the agreements that Minnesota Center for Environmental Advocacy, Wind on the Wires, Fresh Energy and Izaak Walton League have entered into, and the terms of the agreements, including terms regarding positions taken in interventions, what they are required to advocate for, in what venues, and prohibitions from advocating against utility policy and/or projects.  These agreements have had such wide ranging policy impacts, I’m sure they think for the good, that the end is worth the means, but I’ve been picking up the pieces of their messes, representing people and communities harmed by the deals, by the impacts…

Why are these agreements a problem?  Because the agreements they’ve entered into, at least those I know of, are primarily agreements of self-interest, without consideration of the impacts… think about the “alternate site mandate” or the Benson turkey shit burner of the 1994 Prairie Island bill, or the “Innovative Energy Project” Excelsior Energy Mesaba Project and expansion of dry cask storage of nuclear waste of the 2003 Prairie Island bill,  or the 2005 Transmission Bill from Hell and all the perks to allow CapX 2020, plus C-BED and a substation and turbine on Speaker Steve Sviggum’s land too… nope, no way, no how, these agreements are not in the public interest, are not in their “members” interests, and have had significant detrimental impacts on clients that have come to me for help in dealing with those impacts.

It’s a different kind of “Wild West” in transmission these days (the photo up above could well be the old 230 kV line through PA and New Jersey!).   But it gets pretty exciting reading through these applications and seeing what it is that these evil transmission promoters are doing.

I did send out a lot of Information Requests today on the ITC Midwest MN/IA transmission project:

IR 1 to ITC (sent a while ago, responses received)

ITCM Response to CETF-NoCapX2020 IR No. 1

IR 2 to ITCMidwest

IR3 to ITCMidwest

IR 4 to ITCMidwest

IR 5 to ITCMidwest

IR 6 to ITCMidwest

IR 7 to ITCMidwest

IR 8 to ITCMidwest

IR 9 to ITCMidwest

IR 10 to ITCMidwest

What I’m most concerned about is that they’re touting all these benefits resulting from this project, but the benefits are associated with not just this project, but the REST of MVP 3, which is this project PLUS the MidAmerican part of MVP 3 in Iowa, PLUS MVP 4 (heading eastward to the Mississippi, and MVP 5, which is heading up to the Madison 345 kV ring, not just the part connecting the MVP 3 and MVP 5, but also Badger Coulee connecting CapX from La Crosse to Madison.  IT’S ALL CONNECTED, and the benefits, as modeled by PROMOD, are economic benefits, where a fundamental assumption of the modeling which includes ALL of the MVP projects, and not just MVP 3, MVP 4 and MVP 5, but all 17 of them.  17.  OK, find, we’re including all those benefits…

… but what about costs?  Wellllllllllllll…

They’re only addressing costs for their teeny-tiny portion of MVP 3, about 1/2 of it in Minnesota and a little bit into Iowa, the red part on this map, and no other costs:

The cost/benefit analysis of this project is a little unbalanced:

And it should come as no surprise that their lead witness, ITC Midwest’s David Grover, was behind the TRANSLink docket (oh my… for that docket, go to the PUC search page, and search for docket 02-2152 (NSP) and/or 02-2119 (IP&L) where both utilities were asking the PUC for permission to transfer transmission assets to TRANSLink, what was to be the first transmission only company in Minnesota.   It wasn’t exactly going well, and so they bought out the enviros who had intervened:

Settlement Agreement – ME3(Fresh Energy), Izaak Walton League, Minnesota Center for Environmental Advocacy, North American Water Office

Things went south in transmission from there, because even though the TRANSLink Petition was withdrawn, the utilities just did it another way, and got everything they wanted,  including legislation authorizing transmission only companies:

2005 Ch 97 – Transmission Omnibus Bill from Hell — Xcel’s transmission perks and C-BED

… plus perks like construction work in progress (CWIP) rate recovery, broadened definition of “need,” on and on, a transmission company or utility’s dream.

It’s all connected…

It’s like winter in Minnesota — will this rulemaking never end?  We’re pretty much ensconced in Minn. R. ch. 7850 now, siting.  PROGRESS!  Here’s where it stands:

January 22 Meeting Synopsis

February 13 Draft 7849

February 13 Draft 7850

The next meeting of the Rulemaking Advisory Committee is TOMORROW:

February 26, 2014 @ 9:30 – 11 30 a.m.

Rulemaking Advisory Committee

PUC Building, Basement (look for signs)

121 – 7th Place East

St. Paul, MN  55101

Talk about being behind the curve…  a news blackout.  I’ll post this on all my sites and watch, NSA’s going to push my stats up!

Very strange timing here — an incident where “multiple transformers,” 17 transformers, or 5 transformers, 5 out of 7 transformer banks, depending what you read/hear, were taken out occurred on April 16, 2013, and it’s just now being reported.  Try googling “news blackout California substation electrical terrorism” and see what comes up. Maybe it’s that former FERC chair Wellinghoff is out there talking about it?  There was also a congressional hearing in December that got some coverage…

At the time, the incident wasn’t publicized, but since he stepped down as FERC chairman in November, Wellinghoff is raising public attention to the California sniper’s attack to demonstrate the vulnerability of the nation’s electricity system.

Wellinghoff started talking about it publicly in November, 2013 it seems.

Do some googling and see for yourself the news blackout.  Also,several articles are noting it occurred a day after the Boston Marathon bombing, but not one yet is noting that it occurred the day after taxes are due.  How many anti-tax wing-nuts are out there?

They publicized similar sabotage in Arkansas and arrested the perp (interesting, he unbolted a tower, connected a cable, and used a moving train to tip over the pole!):

Arkansas man charged in connection with power grid sabotage

Back to California — here’s what the substation and surrounding area looks like, and the actions taken, from the Wall Street Journal article:

In today’s STrib:

Who knocked out 17 giant transformers in Calif. — and why?

In the Wall Street Journal (I don’t have access… do you?):

Assault on California Power Station Raises Alarm for Potential Terrorism

From PG&E at the time:

April 16, 2013

Grid Operator Calls for Conservation after Substation Incident

April 17, 2013

PG&E Crews Continue Repair Work at Damaged Substation

Now going back to April, 2013:

Vandalism at San Jose PG&E Substation called ‘Sabotage’

AT&T Offers $250,000 Reward for Fiber Vandalism

CAISO’s Alert:

Flex-Alert-Urgent Conservation Needed Now – Santa Clara Silicon Valley  April 16, 2013

Here’s one from December, 2013, that is the most detailed and credible I’ve found:

‘Military-Style’ raid on California Power Station Spooks U.S.

In this one there’s a statement that’s a recurring theme that I think is off base, the theme being that it’s a rehearsal for a “real” attack, and in other articles calling it a “dry run,” when I’d call taking out 17 transformers a “real” attack:

“These were not amateurs taking potshots,” Mark Johnson, a former vice president for transmission operations at PG&E, said last month at a conference on grid security held in Philadelphia. “My personal view is that this was a dress rehearsal” for future attacks.

Another good detailed article in the NY Times:

Months Later, Sniper Attack at Power Hub Still a Mystery

And a video:

San Jose: Sheriff’s Office release video of attach on PG&E substation

On NPR:

Sniper Attack on Calif. Power Station Raises Terrorism Fears

In Bloomberg:

Rifle-Toting Terrorists Pose Great Threat to Power Grid

Now let’s see some other coverage that I’ll nominate for “wing-nut” status:

False Flag: New Details Emerge on Santa Clara County ‘Military-Style” Power Grid Attack

Latest ‘Domestic Terror’ Sniper Attack is Likely a Government False Flag

In which they say:

Those who still believe that this was the work of a home-grown terror cell, read between their own lines: according to the U.S. Navy investigation ordered at the request of  FERC chairman Wellinghoff, “it was a targeting package just like they would put together for an attack”.

‘Just like they would put together for a real attack’, he says?

Exactly, because this wasn’t a real terror attack.  ???  Again the mantra of a “dress rehearsal” or a “dry run.”  Isn’t taking out the fiber-optic and 911 service and then multiple substation transformers “real” enough?

Chilling: Why an Underreported, ‘Significant Incident of Domestic Terrorism’ Might Not Be A Failed Attack At All

In today’s STrib, the full article:

YEAAAAAAAAAAAAA!!!

The Minnesota Public Utilities Commission has just issued the:

Notice Of Comment Period_20141-95340-01

Initial Comments are due by January 29, 2014 at 4:30 p.m.

Reply Comments are due by February 19, 2014 at 4:30 p.m.

That’s plenty of time to say what needs to be said, and scoot in a little trip to a warmer clime before it comes up at the Commission (in March?).

And best of all, the range of issues before the Commission:

So get to writing those comments!

Send comments via email — and be sure to write both docket numbers in the subject and body, i.e., “Comments for Dockets 11-152 and 12-113” — send to:

PublicComments.PUC@state.mn.us