Legalectric

Here’s a study from 2018 that I found in connection with a recent article about the controversy over the Colstrip coal plant and whether it will be rehabbed, whether it will continue to provide Idaho with some power after withdrawal from Washington state.

Idaho regulators have Colstrip concerns

Here’s the study:

Carbon Capture was to be considered in the plan for Colstrip rehab, but here’s the conclusion:

45Q CO2 tax credits? Get out the waders. From our “good friends” at Great Plains Institute, its Primer: Section 45Q Tax Credit for Carbon Capture Projects.

To implement the reformed 45Q, the US Treasury requested public comments in IRS Notice 2019-32 on several key issues. The IRS issued guidance on beginning and continuous construction requirements along with a revenue procedure for business partnerships that include investors claiming the tax credit. The IRS released proposed regulations to address additional implementation issues, including requirements for demonstrating secure geological storage, credit recapture, credit transferability and contractural assurance, and requirements for lifecycle analysis of emissions reductions for projects that beneficially use CO2 or CO to convert manufacture fuels, chemicals, or other useful products like cement.

https://www.betterenergy.org/blog/primer-section-45q-tax-credit-for-carbon-capture-projects/

Yes, Great Plains Institute has a big money-suck program AGAIN, pushing “carbon capture and storage/sequestration.”

Money suck? Yes, look at this from 2017 IRS 990, most recent I could find, but for sure there is more since:

Current Legalectric post, and going back… been there, done that, must we?

More Carbon Capture PR BS

February 21st, 2020

CO2 pipelines? It’s a red herring!

March 22nd, 2017

Do really need to go through this again? Apparently, because as Bill Grant, formerly Deputy Director of Commerce on the Energy side, and before that Izaak Walton League forever, said circa 2005 and coal gasification and CCS, “we need to find a way forward for coal.” We’ve been there, done that, and carbon capture is a pipedream:

And even though we knew it then, the science and economics were in the record, regulators and applications paid little attention until plant after plant was blocked, denied, and withdrawn. Then again, they got a LOT of money to promote coal gasification and carbon capture, but those of us without funding, without resources, kept at it, and prevailed.

IEDC gets carried away

February 15th, 2007

And here are the presentations from that fiasco, the shameful promotion of CCS contrary to science and economics:

Presentations at IEDC

February 16th, 2007

CO2 sequestration is so… like… not happening!

January 26th, 2007

Great Plains Institute – is Joyce getting their $$ worth?

January 18th, 2007

Dodge County Concerned Citizens asked me to do an information presentation on NextEra’s Dodge County Wind project, which was recently applied for at the Public Utilities Commission.  Here’s my presentation:

Turbine and Transmission Neighbors?

Completeness comments are due August 10, 2018, with reply comments due August 17, 2018.

20187-144854-01_PUC Notice_Completeness Comments_ALL dockets

How to file?

Here’s a form you could use for guidance — yes, its a test, and an essay test at that.  Your original words are what count, because you know your community best, what impacts on the ground might be.  You can best identify the material issues.

To the Public Utilities Commission_Sample Comment

It was interesting that Beth Soholt, is concerned enough to show up on a Saturday morning!  She’s the ED of wind industry association Wind on the Wires (f/k/a program of Izaak Walton League Midwest until Bill Grant was appointed Deputy Commissioner – Energy – Dept. of Commerce)   But her being there was not much of a surprise, because NextEra’s Julie Voeck is Chair of the WOW Board.  And don’t forget that PUC Commissioner Matt Schuerger’s “Energy Systems Consulting Services” was a primary recipient of Waltons/WOW consulting funds.  As we say in transmission, “It’s all connected.”

Can’t find a Dodge County Wind, LLC website (it is a Delaware LLC registered with Minnesota Secretary of State), and NextEra has nothing on its website about the LLC, nor about the Dodge County project, that I can find, ALL Press Releases are about MONEY, not a one about “Dodge County.”  There is a separate transmission page with “project info” but no project specific info there either.

This project was really difficult to dig through, because there are THREE dockets: Certificate of Need (17-306); Wind Siting (17-307); and Transmission Routing (17-308).  WHEW!  This would be overwhelming to anyone, and to try to explain what’s proposed, the process (UGH!), and issues, that’s a couple of books… whether fiction or non-fiction remains to be determined.

Post Bulletin – Proposed Dodge County wind farm raises questions

KTTC – Dodge County Concerned Citizens holds informational meeting on proposed wind turbine project

KIMT – Wind project proposed in Dodge County

This project has been brewing for a while, because there’s a Certificate of Need requirement of a Notice Plan before anything is applied for, and then notice goes out as laid out in the Notice Plan.

20186-144410-04_Order_Approval of Notice Plan

I’m on the general service list for all projects, pretty much everything, so I have an idea what’s new and exciting at the PUC, but it’s pretty hard to track it all.  For this project, the initial “notice” filings for 17-306 (Certificate of Need) & 17-308 (345kV transmission line) were in April, 2017, and the transmission route app and wind site permit app were not filed until 6/29.  The wind site permit is most significant in terms of cost and geographic spread, and nothing was filed until June 29, 2018, less than a month ago.  The wind site permit filings contain an affidavit of mailing of notice but NO ADDRESSES, and the transmission affidavit of mailing of notice DOES have addresses.  Why are no addresses included?

Three dockets, all those filings, at least 1,000 pages, and I confess haven’t read all of it! What jumps out at me is that this is another scattered site project, with a large footprint. It’s a 170MW project, not unusual in that way, but the turbines proposed are 2.5 MW turbines.  That’s BIG!  The reported hub height is 291 feet, and from ground to tip of blade, 485.5 feet.  That’s BIG!

How to look at the dockets:

So now, quick because Completeness Comments are due, it’s time for people to take a look at this project, what’s proposed for the wind project, the big honkin’ transmission line, and whether all this is needed.

Oh, and about that big honkin’ transmission line, here’s a cut and paste from their application:

Characterizing this bundled 345kV line as “generation inter-tie?”  Oh, please…

Some have said that the Renewable Development Fund is sacred.  WRONG.  The Renewable Development Fund is profane, not sacred, all the way from its origins to its uses.  It’s now under scrutiny at Minnesota legislature, and institutional memory is nowhere to be found in this discussion.  See HF 235 and SF 214.

The Renewable Development Fund (RDF) came into being in the 1994 Prairie Island bill, and was to be a per cask compensation fund for the Prairie Island Indian Community for storage of nuclear waste next door and extension of Prairie Island nuclear plant life.  That compensation was turned into the RDF in a late night deal by “environmental” groups lobbying, of which Bill Grant (now Deputy Commissioner, Dept. of Commerce, formerly and then Izaak Walton League) was an integral part, Michael Noble (ME3, now “Fresh Energy”), and George Crocker (North American Water Office) too.  Prairie Island Indian Community was supposed to get priority in grants, but that never happened.  The RDF was administered by 3 from Xcel, plus Bill Grant, and one other “environmental” rep.  The composition of the group giving out the grants has changed, and there is now someone from PI on it, but that’s recent. (Full Disclosure: I represented Florence Twp. fighting the “in Goodhue County” alternate site mandate for nuclear waste and the Township worked very mindful of, and often in tandem with, PIIC, where it fiercely refused to acquiesce to Xcel and say “STICK IT THERE” to PIIC.  The working relationship continues and PIIC is now largest private  landowner in Florence Twp.).

1994 Prairie Island bill — Ch. 641, MN Session Laws (https://www.revisor.mn.gov/laws/?year=1994&type=0&doctype=Chapter&id=641).

The RDF was a material term of the 2003 Prairie Island bill, where as part of the deal millions of RDF money was to go to the Excelsior Energy Mesaba Project.  Bill Grant was primary again, and when the Mesaba Project was stricken in one House session, a red-faced Tom Micheletti came flying down the hall yelling at Grant “We had a deal, we had a deal!” That deal was later added back in, and Micheletti’s Excelsior Energy coal gasification plant, Mesaba Project, was added to the factors to keep PI open.  “Environmental groups” got massive grants to promote coal gasification.  Micheletti got $10-12 million from RDF for Mesaba (and lots more from IRRB and DOE) and other regulator perks in the 2003 law, like exemption from CoN, and a mandated PPA with Xcel.  (Full Disclosure: I represented MNcoalgasplant.com against Mesaba Project, and with CAMP and help from Xcel, we got the details of coal gasification, that project was killed, and the info killed others nationwide, but Mesaba still has a site permit in Taconite from PUC valid until 2019!)

2003 Prairie Island bill – Ch. 11, MN Session Laws (https://www.revisor.mn.gov/laws/?year=2003&type=1&doctype=Chapter&id=11) 

On Monday, January 23, the Red Wing City Council voted to accept a $2 million grant from RDF to install a garbage grinder, a project they’ve been lobbying for for years, where they’ll take in garbage from the whole county, grind it up, and burn it in Xcel’s garbage burner here, its air permit expired in 2009!  GARBAGE!!!  DOH!  GARBAGE is not clean, it’s toxic!  The purpose of all this is to keep the incinerators open and burning.  (Full Disclosure:  I have been representing clients being screwed by Xcel’s plan for “ash mining” in their incinerator ash landfill in Red Wing, part of which includes a plan to build a Red Wing laydown yard and crusher on a site half of which is designated Water Tower Burial Mounds — yeah, really. That’s been exposed:

My partner, Alan Muller, is an incineration expert and has worked with groups to stop RockTenn; Midtown Burner in Phillips, Rockford City and Township; HERC uprate, etc.  See the Tyler Hills Neighbors Comments: Comment Extension for Lab USA EAW & Xcel & Lab USA Solid Waste)

The RDF has been a slush fund for deals enabling nuclear, promoting coal gasification, and greasing the skids for scams of great financial and environmental magnitude and impact.  It should be shut down and turned over to Prairie Island Indian Community as originally intended.

The Department of Commerce has hit the brakes on Sandpiper Pipeline and Line 3 Replacement Projects “until such time as Enbridge makes clear its intentions about the projects, or until we receive further direction from the Commission.”

Here’s the letter from Bill Grant:

20168-124424-01_Commerce_EIS Scope Decision Document on HOLD

And the guts of it:

YES!!!  Now, about those transmission lines proposed for pumping stations related to these projects????

Released yesterday by National Institute for Science, Law, and Public Policy (NISLAPP) (never heard of it before, need to do some checking):

Green Electricity or Green Money?

Why is this a question?  We know it’s a problem. But this report focuses on things like “Smart Meters” and doesn’t dig into the the even worse toadying for coal gasification and other harebrained promotional schemes of these orgs.

Here in Minnesota, the money goes to Minnesota Center for Environmental Advocacy, Fresh Energy f/k/a ME3, Izaak Walton League and its former program now independent 501(c)(3) Wind on the Wires (conveniently separate since just after election, when Bill Grant was appointed Deputy Commissioner of Commerce in charge of all things energy)(oh, and Nancy Lange appointed to Public Utilities Commission).  And then there’s RE-AMP.  There’s so much money flying around for promotion of transmission and coal gasification.

Bill Clinton toadying for transmission

WOW’s devil we know… ummm… WOW!!!

Walton’s Bill Grant – Deputy Commissioner of Energy?

Wind up to ELPC Transmission Strategy Meeting

AAAAAAAAAAAAARGH… back to work…