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):

June 26 Meting Synopsis

July 8 Draft

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

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.

7849 June 5 DRAFT New

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 – 6664261-v1-MN Wind Coalition 7849 June 5 DRAFT New and 6664261-v4-MN Wind Coali (2)-c

   Change-Pro Redline – 6665625-v1-MN Wind Coalition Project Notice 7849 0130 (Revisions to Participati (3)-c

   Change-Pro Redline – 6665625-v1-MN Wind Coalition Project Notice 7849 0130 (Comments added 7-3-13)-c

Participating Utilities – Alan Mitchell

   List of Issues

   Project Notice 7849.0130

   Explanation of part 7849.0130

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

   Overland Comments July3

   Rulemaking – email – CEII (Critical Energy Infrastructure Information)

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:

Federal Siting
In addition to regional planning and cost allocation,
substantial reform of the transmission siting process is
required to meet national renewable energy goals. The
most effective model is the siting authority that was given
to FERC over interstate natural gas pipelines. For green
power superhighways, the extra-high-voltage facilities
defined in the regional plans would be subject to FERC
approval and permitting. Separate siting approval at the
state level would not be required. FERC would act as the
lead agency for purposes of coordinating all applicable
federal authorizations and environmental reviews with other
affected agencies.
Check their “Policy Solutions on p. 3:
Again, this is not new news, I remember fighting over this with the Waltons/Wind on the Wires in 2005, their agenda was all about increasing federal authority and decreasing state authority… and of course they’re not part of this rulemaking, there are NO, NONE, NOT ONE enviro group participating in this transmission rulemaking docket.
The point of JCSP is to increase power flows along those red pathways — who benefits and who loses:
There’s been little talk of JCSP lately, but given the rate of return for transmission construction, it’s hard to believe it’s not lying in wait.
And if it’s not all about coal, why is this the case (Vol. 1, p. 190):