Legalectric

Testing… one… two…

This upload is too much for me, but it looks like it might be working.

Anyway, finally, here’re the Discovery responses about the Mesaba G519 study that says they have to cut 675MW of wind in SW MN, that the Big Stone II generation must be “kept in North Dakota” and more, but MP’s response isn’t in yet. Here’s the G519 study link. I’d asked each affected party, Big Stone II partners, Xcel, Minnesota Power and Excelsior about cost impacts of the generation cuts and limitations that the Stability Study calls for.

Here’s the Big Stone II partners responses to my questions about cost impact of “keeping generation in ND” which of course they knew nothing about until now:

Big Stone II Response to MCGP Discovery I.pdf

Big Stone II Response to MCGP Discovery I – Exhibit 1-C.pdf

Here’s Excelsior’s responses to my questions about redirecting BSII generation:

Excelsior Response to MCGP Big Stone II First IR-3.pdf

And here’s Xcel’s response about cost of cutting 675MW, i.e., curtailment payments, if Mesaba is connected and 675MW of wind from SW MN is cut:

Xcel Response to MCGP-001-002.pdf

Minnesota Power’s responses are on the way someday soon, they asked for an extension.

Now, if I can just figure out how to upload pictures, I can post some of last Tuesday’s CAMP meeting, which was a great success. Standing room only on a hot and muggy night in Grand Rapids — people want to hear about the Mesaba project and ask questions!

If you have questions about Excelsior’s Mesaba project, you can try their site, Excelsior Energy, and for even more, see www.mncoalgasplant.com.  Citizens Against the Mesaba Project (CAMP) is under construction but open for business at www.camp-site.info.

It’s scary the way coal gasification proposals are flying around — methinks they are all vying for a chance at a limited pot of federal funding, clawing their way toward the prize. I heard today from someone fighting the American Electric Power IGCC proposal in Ohio, and it sounds too familiar. When I searched for images of the project, here’s what I get, maybe what Santa’s giving to them? naaaaaaa:

Last year they started front-end engineering on the AEP project. Here’s their blurb on that. And here’s a promotional article:
The new clean fuel: Coal producer goes green

Really, that’s the headline! And funny, the link for AEP in the above article provides a “corporate snapshot” and stock prices… Links for more info on the coal gasification proposal? Not in that article!

Here’s where the Ohio PUC started down that familiar trail of altering “business as usual” to “business as unusual” by authorization of recovery of preconstruction costs in the rates. Here’s their blurb on that.

Remember that coal comes from somewhere — how and where? As Andy David said Tuesday in Grand Rapids, “Remember from chemistry class that elements cannot be destroyed.” If it’s not coming out the stack in as great quantities, it’s going somewhere else.

For a refresher about the story of coal, see Mountaintop Removal. It’s all connected.

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Tyson Slocum has got it right, for the most part, but I wish every time someone mentions blackouts they’d also note the loading of the lines just before the blackout — that the lines are overloaded!

Pattern: Overloaded lines at off-peak times, overloaded with bulk power transfers. Operators are working hard to get those transfers through and don’t heed warning signs, don’t follow NERC protocol — they put private profit above public service.

In the Arrowhead transmission proceeding, I entered post-blackout studies, and in cases since. In the June 25, 1998 blackout study by MAPP, it notes that the system operator was focused on playing with the phase-angle rather than cutting loading, running at 1,004MW on a line with a stability limit of 700MW. Well, DUH, running the line 30% over limits, and then ignoring requests to decrease loading, is it any wonder?

A similar scenario occurred in June 10-11, 1997, when the lines were overloaded for MAPP exports, everything crashed. As the industry report notes:

This event should not be filed away as just another close call. We need to recognize just how close we were to collapsing portions of the Eastern Interconnection and adjust operating guides and reporting practices to avoid reoccurrence. There are real limits to the transfer capability out of the MAPP region and those limits are interedependent. This event is an alarming representation of how the MAPP regional interconnected system is being operated at or even beyond its capabilities.

Nebraska Public Power District, report on June 10-11, 1997 Disturbance (emphasis added).

Why is the grid “being operated at or even beond its capabilities” by system operators? Because they’re trying to make all the unregulated bulk power transfers they can — for profit. And they’re putting the system at risk, they’re putting us at risk.

The lie of the need for transmission goes back to these reports — transmission cases have been based on fearmongering, that we’re going to freeze in the dark in an incubator without a job if we don’t have these lines. The mantra of the Arrowhead case was “Where were you the night of June 25, 1998?” But we know better. We know we’re not at risk because we can’t get electricity we need, we’re at risk because they’re putting profits ahead of grid stability. We know the lines are for even more bulk power transfer. They’re trotting out these blackouts as reasons for more transmission when it’s their greed that is crashing the system.

Check out reports about blackouts! Look for statements about overloads, about operating beyond limits. Now and then, it’s caused by an unfortunate fried squirrel, but the majority of blackouts are caused by system overload instability. How dare they manipulate the grid that way… how dare they manipulate us that way! And put us at risk! But hey, who’s going to read utility blackout reports for the truth. So read! It’s not rocket science, it’s tinker toys, and the juicy parts are narratives in English that even an attorney can understand.

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From Common Dreams:

Behind the Blackouts

Published Friday, July 28, 2006

by Tyson Slocum

Ken Lay may have passed away and Jeff Skilling and other former executives face dozens of years behind bars, but Enronâ??s legacyâ??single-handedly pushing electric power deregulation at the federal and state levelsâ??unfortunately remains the law of the land. The radical restructuring that Enron achieved a decade ago overturned a century of orderly, accountable electricity planning that had made Americaâ??s power system the envy of the world. But our deregulated system is now a mockery, and consumers are left with higher prices and poorer reliability. Thatâ??s why our electric gridâ??from the August 2003 blackout that cascaded across the Midwest and Northeast, to recent power outages in New York and Californiaâ??is more susceptible to failures that trigger blackouts.

Before the implementation of Enronâ??s agenda, electric utilities were fully regulated by states, with one company responsible for producing and delivering power. These utilities had a legal obligation to serve all consumers and were forced to re-invest a portion of their profits back in to improving reliability. Were there flaws with this system? Of course. But it produced the most reliable and affordable power system the world had ever seen.

Enron and their ilk smashed it apart, replacing legal mandates with â??the marketâ? to regulate Americaâ??s power system. They assumed competition would successfully replace regulators to provide the necessary investments in power generation and transmission.

But that didnâ??t happen. With the requirements to invest a share of profits into improving reliability now removed, Wall Street and the power industry shunned putting their money into unprofitable investments like upgrading transmission lines and distribution networks. Why should investors spend money on low-rate-of-return investments like reliability when they can make a killing buying and selling power plants?

On top of this market failure, deregulation has also encouraged distributional utilities, like ConEd in New York, to skimp on preventative maintenance spending. They have slashed utility workforcesâ??particularly experienced, unionized jobs. And regulators in New York and other deregulated states no longer pour over the companiesâ?? reliability budgets, allowing the utilitiesâ?? service to slide in pursuit of higher profits. As a result, distributional utilities now have too much incentive to replace equipment after, not before, it blows.

Deregulation presents other challenges as well. The United Statesâ?? transmission system was designed to accommodate local electricity markets, not the large, freewheeling trading of electricity and movement of power over long distances under deregulation. Sending power over a much wider area strains a transmission system designed to serve local utilities.

Rather than require electric companies to return to their century-old obligation to re-invest in transmission, Congress and President Bush muscled through an energy bill last summer that jacks up power prices by allowing owners of transmission lines to charge higher prices. The energy bill sticks consumers with as much as $100 billion for the construction of new transmission lines that big energy companies want but consumers donâ??t need. This consumer-funded subsidy prioritizes the construction of power lines preferred by wire-hogging power marketers intent on moving large loads of electricity that will bypass the needs of local households.

Utilities are focusing more of their investments on things outside providing electricity service to customersâ??such as Enron-style power marketing, power plants far outside their retail service area, and ventures into broadband and the like. The result is a pattern where deregulation encourages billions of dollars to flow into non-utility ventures at the expense of shoring up reliability.

Rather than pandering to an electric industry that gave more than $47 million in campaign contributions to federal candidates since 2001 (with 66 percent of that total going to Republicans) Congress needs to restore reliability and affordability to our electric power system. Three steps to improving our system include:

• Providing incentives and assistance to states to help utilities re-acquire generation assets divested during deregulation;

• Promoting decentralized power sources such as distributed generation and wind and solar energy; and,

• Investing in energy efficiency technologies, such as building weatherization, to reduce electricity demand.

And states must insist on regulators that will be accountable to citizens, not utility company special interests. Ending the ability of regulators to cash in through the revolving door of getting a lucrative job after serving on public utility commissions would help restore accountability. And state and local governments can explore government-owned power, which provides lower-cost and more reliable service for millions of Americans across the country.

The recent blackouts were caused by a failure of policy. Ending the disastrous deregulation experiment and establishing locally-controlled power systems will help restore Americaâ??s electricity sector.

Tyson Slocum is the director of Public Citizenâ??s energy program.

© 2006 TomPaine.com

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Well DUUUUUH! A couple days after the SD PUC issues its order and the BSII permit, the applicants announce that oh, by the way, the costs have increased 60%. Right… and they had no inkling of that a few days before? Right…

So here’s an Application for Reconsideration from Mary Jo Stueve, simple and concise, how can they turn it down:

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF SOUTH DAKOTA

In the Matter of Otter Tail Power Compan on Behalf of Big Stone II Co-owners for an Energy Conversion Facility Permit for the Construction of the Bog Stone Project

Docket No. EL05-022

NOTICE OF APPLICATION FOR RECONSIDERATION

PLEASE TAKE NOTICE, that I, Mary Jo Stueve, make this Motion for Reconsideration of the above matter to the South Dakota Public Utilities Commission (the Commission) as set forth in more detail below.

APPLICATION FOR RECONSIDERATION

Pursuant to ARSD 20:10:01:29 and ARSD 20:10:01:30:01, I, Mary Jo Stueve (Pro Se) respectfully make this Application to the Commission for Reconsideration of the Commissionâ??s Order granting the permit in the docket of the Matter of Otter Tail Power Company on Behalf of Big Stone II Co-owners for an Energy Conversion Facility Permit for the Construction of the Big Stone II Project for reasons stated below.

This Application for Reconsideration should be granted because of newly discovered information regarding a material fact in this proceeding — information that estimates that the Big Stone II project will cost 60% more than the $1 billion estimated of cost upon which the Order was based.

In presenting Purpose and Need for the proposed Project for power generation, Co-owners estimated the cost of the Big Stone II Power Plant. Now, we are presented with a cost estimate greatly above that upon which the Big Stone II Petition was based. It was recently reported that the projectâ??s lead engineering firm, Black & Veatch, has produced new cost information that estimates a 60% increase in the cost of the plant, now estimated at $1.6 billion dollars. This is information that the Commission must address to assure that the project is in the public interest and in the ratepayersâ?? interest.

I, Mary Jo Stueve, respectfully request that the Commission:

1. Order Applicants to provide copy of the recent report from Black & Veatch, including cost information and all other contents of the report.
2. Reconsider the Order granting the permit, and take into account this 60% estimated cost increase and the public interest and ratepayer interest.
3. Take any and all other relevant information in the Black & Veatch report into consideration.

Dated this 27th day of July, 2006

________________________

Mary Jo Stueve
Pro Se
196 E 6th St #401
Sioux Falls SD 57104