7849 Rulemaking update
July 9th, 2013
Updates on rulemaking ongoing at the PUC (not that they put anything in the PUC docket, but don’t worry, I’ll post there too):
Is this too wonkish, or does anyone else see the irony in having to struggle so to get opportunity for public input in these Certificate of Need rules?
If you have comments on the draft rules, and BE SPECIFIC, label with rule citation (i.e., Minn. R. 7849.0100, and show how you’d change the rule, with the narrative explanation and the exact words you suggest, and send to kate.kahlert@state.mn.us and post to docket 12-1246 at the PUC site if you can, (www.puc.state.mn.us and click on “eFiling” and sign up to post if you’re not already registered).
History and background, with links to the comments thus far:
7849 Rulemaking Update – July 4th, 2013
Critical Energy Infrastructure Information NOT! -June 26th, 2013
Rulemaking – Certificate of Need 7849 – June 12th, 2013
7849 Rulemaking Update
July 4th, 2013
Last week was the second meeting of the “Advisory Committee” for the Minnesota Rules Chapter 7849 (Certificate of Need) pre-rulemaking drafting. Here’s the most recent draft — and the Ch. 7850 draft is ??? overdue… will post it as soon as it’s in.
It’s frustrating, because the informal “pre-rulemaking” drafting is the only real opportunity to offer any changes, once it’s into formal rulemaking, it won’t change in any substantive way. Meanwhile, it’s ongoing and the public isn’t well represented, well, they ARE represented, but only in nominal numbers, i.e. ONE regular person, and three attorneys who represent citizens, advocacy, landowners, environmental groups. SOOOOO, I’m doing what I can to let people know what’s going on. They’re not even making the drafts public so … here it is AGAIN! And I posted it on the PUC’s 7849 rulemaking site, go HERE and search for docket 12-1246!
If you have comments, write them up, very specifically explaining your comment and linking it to the specific rule or part of the rule the comment relates to, and post on the PUC’s eDockets or send to kate.kahlert@state.mn.us (she’s the PUC staff person in charge of this rulemaking).
A previous post with the details:
Rulemaking – Certificate of Need 7849
June 12th, 2013
Some comments were filed just before the first meeting, after the first meeting, before the second and after the second:
Wind Coalition – Christi Brusven
Change-Pro Redline – 6665625-v1-MN Wind Coalition Project Notice 7849 0130 (Comments added 7-3-13)-c
Participating Utilities – Alan Mitchell
Xcel Energy – Lisa Agrimonti
Project Notice 7849 Xcel Energy Comments
Rulemaking – email – Certificate of Need Chapter 7829
North Route Group – Suzanne Rohlfing
Rulemaking Comments for June 26
NoCapX 2020 & U-CAN – Carol A. Overland
Rulemaking – email – CEII (Critical Energy Infrastructure Information)
JCSP Big Picture – who pays? WE DO!
July 2nd, 2013
Transmission — it’s all connected. In looking at the Minnesota rulemaking, and the existing and proposed rules that utilize the word “regional,” I’m thinking about big picture stuff, the big proposals in the wings, and that Joint Coordinated System Plan (JCSP) map sure presents a big picture. For some reason, I’ve not been able to find the full JCSP report until recently:
Who cares about JCSP? Well, WE’D better care, because look who’s paying for the transmission build-out (p. 68 of Vol. 1):
Look at the numbers for Midwest ISO, a $-10,293, or for MAPP, a $12,292, that’s a COST, not a savings. MISO and MAPP get nominal production cost savings and massive load COSTS. This is not news, but is worth repeating as we discuss “regional.” And another take with the same take-away of big costs for MISO and MAPP customers, used by our good friends at AWEA to promote this transmission buildout in their flyer called “Green Power Transmission and Consumer Savings” (flyer below):
Read the whole thing:
What a deal, eh?
Look what AWEA has been advocating to make this happen: