Here are Comments filed on behalf of Association of Freeborn County Landowners:

Association of Freeborn CountyLandowners_Petition & Initial Comments – Filed July 6, 2017

Association of Freeborn County Landowners — Add to Service List

Process Issue – Timing of Request for Contested Case

Reply CommentsCompleteness – Association of Freeborn County Landowners

For years, for decades, I’ve been going on and on about the inefficiency of transmission, the electric system, and line losses ad nauseum.  Y’all know that, if you’ve been paying attention.  And here we are, back to discussing inefficiency in the electric system.

The SW MN 345 kV Transmission Lines (PUC Docket 01-1958) turned on line losses.  After that close call, line losses were calculated and considered on a very different model, framing it as a percentage of THE ENTIRE EASTERN INTERCONNECT.  So what’s a little loss of 0.1%, who cares… well, as a part of THE ENTIRE EASTERN INTERCONNECT, it adds up fast.  Let me make this perfectly clear, transmission line loss is substantial.  It’s particularly substantial when you’re talking about using transmission to ship lower capacity energy, like wind and solar.  If you have long, hundreds of miles long, transmission lines, there’s not much, if any, of that energy that would find its way to its destination.

This is not news.  My engineer, Art Hughes, PhD EE, taught me so much about power engineering.  It was a struggle to keep up with him, but the knowledge I gained working with him opened doors in challenging utility infrastructure projects.  Here he is at a public hearing in Peosta, Iowa,  telling people a thing or two about transmission:
Art Hughes filed testimony in the SW MN 345 kV Transmission Lines case, PUC Docket 01-1958) — search the testimony for “losses” upon which this case turned, and was erroneously granted a Certificate of Need, and later a Routing Permit:
Oh well.   It’s long done, this transmission project and many others, the horse is out of the barn, dead, and beaten to a pulp.  There’s been a massive transmission build-out, and now they want to build yet another “transmission overlay.”  Great idea, MISO, Xcel, and all of you dreaming of this revenue generation via capital investment and ROI scheme.
Anyway, back to today’s email.

There’s a “Stakeholder Meeting” coming up:

Register here

Those words, “Stakeholder Meeting” get my attention, because just who is a stakeholder, who decides.  I don’t recall getting this email, but thankfully a client who is regarded as a “Stakeholder” did, so I’ve signed up and will spend the time to show up and raise a few points.

Minnesota Department of Commerce Division of Energy Resources Header


Upcoming Stakeholder Meeting: Opportunities and Barriers to Utility Infrastructure Efficiency

Friday, July 28th from 8:30 a.m. – 12:30  p.m.

Wilder Center – 451 Lexington Pkwy. N, Saint Paul, MN 55104

Register for this free public meeting

Meeting Details

An estimated 12-15% of the nation’s electricity production is consumed by generation auxiliary loads, transmission and distribution losses, and substation consumption. As such, there is significant potential to increase utility infrastructure efficiency by decreasing conversion losses, improving plant operations, and mitigating transmission and distribution losses throughout Minnesota’s electric grid.

The Minnesota Department of Commerce invites you to participate in a stakeholder meeting to explore opportunities and barriers to utility infrastructure efficiency projects, and to begin developing a framework to improve the overall generation, transmission, and distribution efficiency of Minnesota’s electric system.

Meeting attendees will hear from national and local experts and gain insight into how existing, new, and on-the-horizon utility infrastructure technologies can increase system efficiency, including:

  • A presentation by the Electric Power Research Institute, highlighting innovative utility infrastructure efficiency projects and approaches from around the country.
  • A presentation from Minnkota Power Cooperative, discussing lessons learned from implementing infrastructure efficiency projects in Minnesota.
  • Information about next steps in the stakeholder engagement process, including a deeper-dive examination of supply-side efficiency policy issues.

Register here

20161006_0934531

It was a long, long day. Bottom line? Based on the record, and based on acknowledgement of Xcel’s peak demand history, we can shut down Sherco 1 & 2 now without missing it, and by 2025 or so, shut down Prairie Island and not have to pay for significant rehab to keep it running.

Here is the PUC webcast:

 

Here is my handout, noting the 700-788MW overstatement of peak demand forecast.

Legalectric_Handout_IRP

peakdemand_2002-2016

If you start with Xcel’s 2015 actual peak demand, and extrapolate using the 0.3% annual increase out to 2030, here’s what it looks like (click for larger view):
forecast_adjusted

These are the charts that they’re using, starting with inflated forecasts of 9,409 and 9,442MW for 2016, note how far off the resulting 2030 “forecast” is — it’s 800 – 1,234 MW off!
staffp12

With the “forecast” that much off, it’s as absurd as the CapX 2020 2.49% annual increase. Staff questioned the forecasts in the Briefing Papers, Commissioner Lange raised forecasts right off the bat, and Commissioner Schuerger claimed it was at least 300 MW off (don’t know where that 300 MW came from). These discrepancies havce been noted, and they should dig deeper, because the numbers used by Xcel do not add up. Were they lying in the SEC filings or are they lying now? Why isn’t Commerce challenging this, given admissions of the existing surplus? This forecast overstatement, plus admission of under-utilization of grid (meaning grid has been overbuilt, DOH, CapX 2020 and MVP projects are not “needed” in any sense) raises a few issues:

1) This misrepresentation is NOW equivalent to at least one coal plant, and by the end of 2030, or by the time presumed for shut down of Sherco 1 and 2, it’s much more than that.

2) This misrepresentation avoids consideration of shut down of Sherco 1 & 2 NOW, and shutdown of Prairie Island at the 2024-2026 time frame, and avoidance of $600-900 million in capital costs, or more, for Prairie Island.

3) This misrepresentation circumvents discussion of the admitted surplus now existing, even Dr. Rakow admitted to that at least twice in Thursday’s discussion. Where there is surplus, they can sell it elsewhere, and that is, after all, the purpose of CapX 2020 and MVP transmission.

Got that? We can shut down Sherco 1 & 2 now without missing it, and by 2025 or so, shut down Prairie Island and not have to pay for significant rehab to keep it running. This is not rocket science. It’s as simple as using actual peak demand as a starting point and not making up numbers as they have been doing.

Starts in Rochester on Tuesday MORNING at 9:30 a.m.  Whose brilliant idea was that, who can show up at 9:30 a.m. on a Tuesday?

How did this slashing of environmental review, started under Gov. Pawlenty, continue under Gov. Mark Dayton?  It started right after Dayton got into office, with Executive Order 11-04, gutting and muzzling the MPCA and DNR:

E.O. 11-04 Establishing Goals and Procedures to Ensure that Certain Environmental Permits are Issued More Efficiently

That E.O. pushed the MPCA and DNR to ram through permits through FAST (and delay has NOT been a demonstrable problem, because the delays have been caused by applicants not providing required information) as if that “improves” environmental review.

And then comes Gov. Dayton’s Executive Order 11-32, which started this round:

Executive Order 11-32

He’s pushing for “streamlining” and those words are just so wrongheaded.  And they way he’s doing it, all this activity at the EQB making recommendations on “improving environmental review” and “governance and coordination” BEFORE they have the public meetings and this “Environmental Congress.”  So tell me, how is it that the fix isn’t in, and we’re now going through the motions after it’s already a done deal?  Do tell, how are these “oh-so-proud we’re DFL” Democrats any better than the “strip-the-funding-until-regulation-collapses” Republicans?  It’s bad news any way you look at it.

But yes, let’s look at it.

Here’s what the EQB released last week.  Deputy Commissioner Bill Grant (Settlement Agreement – ME3(Fresh Energy), Izaak Walton League, Minnesota Center for Environmental Advocacy, North American Water Office) now in charge of Energy Facilities Permitting, and Matt Langan (who now works for Xcel, so two different sources have said, way to go Matt… sigh… after blowing environmental review on CapX Hampton-La Crosse, omitting transmission where there’s a HUGE corridor, and saying there’s transmission where there is none, GOOD JOB!) were to do the “Report Card.”  They have no business doing any such thing, are uniquely disqualified.  But Matt left, leaving Bill Grant… that environmental review is in any way in his hands is disturbing.

Reading the Evaluation and Recommendations for Improving Environmental Review, maybe the Comments got through to some extent.  The ultimate recommendations are better than the draft, for sure.

OH MY!  The Recommendations for Environmental Governance and Coordination are even better, recommending no changes to recognizing that there isn’t sufficient staff to do the work.  The MPCA part could still be a problem, as it recommends MPCA address how to change, so keep on it!

Some of the meetings are this week, starting Tuesday at TOO EARLY O’CLOCK!  It looks to me that Ellen Anderson is doing for Dayton what Mike Bull did for Pawlenty (well, among other things), these dog and pony shows across the state.  I’ve been passing out handouts about this hoping to get folks to turn out and give them a piece of their mind about what “improvement” of environmental review should mean.   Handout – RW Forum

Blue Check Mark November 27 – Rochester, Wood Lake Meeting Center 9:30am – 12:00pm

Blue Check Mark November 27 – Bloomington, Normandale Community College 6:30pm – 9:00pm

Blue Check Mark November 28 – Duluth, Lake Superior College 5:30pm – 8:00pm

Blue Check Mark December 10 – Worthington, Worthington High School 3:30pm – 6:00pm

Blue Check Mark December 12 – St. Cloud, Stearns County Service Center 5:30pm – 8:00pm

Blue Check Mark December 14 – Moorhead, Minnesota State University 3:00pm – 5:30pm

Time to subpoena Mike Bull!!!

December 21st, 2010

texaslonghornsancho

Let me see if I understand this… we’ve got Ingrid Bjorklund, a wind industry lobbyist/employee now Commerce employee and Deb Pile, also Commerce, using Affidavits to argue LEGISLATIVE intent based on statements by Mike Bull, Commerce employee working under Pawlenty’s roof now working for Xcel.   EH?  LEGISLATIVE intent based on industry lobbyist/employee & Exec agency employee hearsay affidavits of Pawlenty’s Energy Boy.  Where’s the LEGISLATURE in legislative intent?  And what does Mike Bull have to say about this?

Duck and cover, Mikey!  Commerce has trained their sights on you!

HUH?  What’s going on?  Well, we just had a deadline for submittals in response to the First Prehearing Order in the AWA Goodhue Wind contested case regarding application of Goodhue County’s Wind Ordinance.  for the whole docket, go to www.puc.state.mn.us and click on “Search eDockets” and search for docket 08-1233.

Here’s the prelude to yesterday’s filings:

PUC’s Order – Referral to OAH

Goodhue County Wind Ordinance

Staff Chart of Differences between Goodhue Ordinance & State Standards prepared for PUC Chair Boyd

After a Prehearing Conference and the ALJ’s request for our positions in this case, we submitted memos and then the ALJ issued a Prehearing Order:

First Prehearing Order

In that order we were asked to set out the differences between county and state standards; whether county ordinance is a conflict, supplement, or something new; whether it should be applicable to this project; material facts regarding this issue; and what evidence we’d introduce. and here’s what was filed — where’s everybody else?  Anyway, read the Deb Pile and Ingrid Bjorklund Affidavits and note who’s sayin’ what, whose interests are at issue, whose intent is couched as “LEGISLATIVE” intent, and while you’re at it, ask just what role they had at that time.  Seems to me they’re putting it all on Mikey Bull.   Hey Mikey?!?!  Get ready!

Goodhue Wind Truth 2nd Prehearing Memo

Belle Creek Township 2nd Prehearing Memo

MOES Comments

MOES Comments – Attachment 1

MOES Comments – PUC Briefing Papers on Goodhue

MOES Comments – Affidavit of Deb Pile

MOES Comments – Affidavit of Ingrid Bjorklund