Legalectric

This is the tail 1/3 of this LONG, LONG train, headed west with military equipment. The first 2/3 was the dark green, tanks, some medical equipment, but primarily instruments of war, and then this change to the sand colored.

This is similar to what I saw in late 1990, and early 1991 before the start of the Gulf War, during the end of my time driving cross-country. Evidence of extreme military build-up was everywhere, long trains like the one above, and loaded flatbeds on the interstates.

Here we go again.

Just filed, Comments on behalf of Sue Madson:

Just filed, Comments on Scoping for Environmental Review, and more importantly, request for Advisory Task Force and referral to Office of Administrative Hearings for Contested Case proceeding:

On May 12, 2022, the DOE released a “Notice of Intent and Request for Information Regarding Establishment of a Transmission Facilitation Program.” Comments are due June 13. Here’s the Federal Register publication:

https://www.govinfo.gov/content/pkg/FR-2022-05-12/pdf/2022-10137.pdf

One aspect that particularly concerns me is focus on NIETC transmission corridors, designated more than a decade ago, 2005 to be precise, and also containing a category of claimed need for “transmission across more than one state or transmission region.” That criteria would apply to almost every transmission project I’ve worked on, although most were segmented (so that the full extent of the project would not be considered or evaluated, DOH!):

What to comment on? Go to the above Federal Register link, and specific issues for comment start on page 6, “Questions for Requests for Information.” However, if you know of issues that should be considered but are not specified, have at it, put it down in detail.

I do get a little paranoid when they request comments on subjects like this — that “barriers to transmission” is one often raised by Beth Soholt, WOW (now as “Clean Grid Alliance” even more directly identifiable as transmission toadies), and here it is:

Comments are due by June 13, and should be sent to the “Federal eRulemaking Portal” (the only option), and must include the “agency name and identifier.” The agency is “Grid Deployment Office, Department of Energy.”

A decade ago or more, our state agencies eliminated consideration and scrutiny of “need” for transmission by making transmission a “regional” and market matter, making state permitting review nothing more than a rubber stamp. There’s never been a transmission proposal that state agencies didn’t love, rubber stamping everything that came their way. Now that fossil is to be shut down, that should free up immense capacity, but you’ll note that that doesn’t ever seem to be in the mix. Even NERC notes that fossil generation isn’t projected to decrease much, and locally, a good example is GRE’s walk-back on their promise to close Coal Creek, and instead “sold” the plant and transmission, and signed PPA to buy the Coal Creek generated energy.

Here’s NERC’s 2021 Long Term Reliability Assessment’s projection of MW of resources, note that coal doesn’t seem to be going anywhere anytime soon:

If shuttering down fossil is not incorporated into the transmission capacity “need,” exactly what are they basing the “need” claim on? Inquiring minds want to know.

Anyway, do check out the request for comments and let them have it. There are a many specific issues presented that has something for everyone!

Another PUC comment period, this time regarding Freeborn/Xcel Energy’s post-construction noise study and Commerce-EERA’s “analysis” of that study.

Here is the Freeborn/Xcel Energy post-construction noise study (Xcel steadfastly refuses to produce the results of the 22 day noise study done on Sue Madson’s property, GRRRRRRRR):

Here is the Commerce-EERA analysis and recommendation:

Here’s the notice from the PUC — Comments due May 27:

What’s a “Supplemental comment period” I ask? Well, it’s a “clean up” to address things at issue, whatever, so another whack at the apple.

What are they wanting to hear about?

Commerce-EERA is recommending that night-time curtailments be discontinued… WHAT?!?! So they better hear about that in technicolor.

Send comments as below, and also file on eDockets, and be sure to put the docket number on your comment — PUC Docket WS-17-410:

Freeborn Wind?!?! It was 4 years ago today that we showed up, participated, filled the record with testimony, studies, photos, and then received the ALJ’s recommendation that the Freeborn Wind project be DENIED. BUT just four months later, the Public Utilities Commission disregarded the noise issues raised by the ALJ, turned that around, and gave them a permit.

WE WON!!! ALJ Recommend Freeborn Permit be DENIED, or… May 14th, 2018

Freeborn? PUC upends ALJ’s Freeborn Wind Recommendation September 21st, 2018

The project is now built, operating, and making too much noise.

Freeborn Wind Noise Again! November 9th, 2021

Freeborn Wind is too noisy! February 1st, 2022

What’s next? Well, get those comments in to the PUC, and we shall see…

Ain’t “working within the system” grand?!?!