OLA Report on PUC

July 27th, 2020

Hot off the press from the Office of the Legislative Auditor, its report:

In short:

And it’s in the STrib:

Minnesota’s state watchdog agency dings utilities commission on dealings with public

We’re in another day of Enbridge Line 3, today no oral argument or comments, it’s deliberation only.  In the intro, Commissioner Sieben introduced a lot of modifications, laid out on a sheet of paper which was passed around to Commissioners, and then Commissioner Tuma did the same with I believe a couple of sheets (he seems to introduce something at every meeting, spring it on people, with no time to review).  Now they seem to be negotiating how they’re going to approve the Certificate of Need.  ??  I have no idea what they’re talking about, there are no copies for the public, and the documents Commissioners Sieben and Tuma have not been eFiled.  ???

Sierra Club and other intervenors have filed a Motion objecting to entry of new information that has not been subject to review, and that the information should be subject to a contested case proceeding before the Administrative Law Judge.

20186-144310-01_New Info_Remand for Contested Case Proceeding

As they’re going now, it’s as if they are negotiating a settlement with Enbridge, but hey, what about the intervenors, who are parties with equal standing in this?

They’re talking about “beneficiary,” but what they’re searching for is “additional insured.”  And they’re talking about unavailability of insurance for this, well, this is right along the lines of Price-Anderson for nuclear, where we subsidize the industry with no-fault coverage with nominal recovery allowed!

I have tried to get copies eFiled of the Sieben and Tuma sheets that have been passed around, struck out.  Ain’t happening.

They’re talking about a “landowner choice” program where landowners have the option of removal of the old Line 3 from their land.  Schuerger is raising issue of need for informed consent.  YES!  So can we hear from intervenors about all this?  Big issue — all of this is proposed to be handled in a Compliance Filing, and there’s no procedural option for anyone to comment on compliance filngs, unless people just jump in and take it upon themselves to file comments — but there’s no suggestion or guarantee that any comments on what Enbridge comes up with, that it will even be considered.

What a mess…  Certificate of Need approved, with directive to adopt the Recommendation of the Administrative Law Judge to the extent that it is consistent with their decision — that’s backwards, putting the cart before the horse.  Are they making such a mess of this so that on appeal the court will throw it out?

Now on to the route permit.


The Minnesota Public Utilities Commission rulemaking for Minn. R. Ch. 7849, Certificate of Need, and 7850, Routing and Siting, is slowly moving forward. Here are the final drafts up for review before they go to the Commission for a rubber stamp and release for general comment:

20173-129606-02_Draft 7849

20173-129606-03_Draft 7850

Final initial comments on drafts were due on Monday and here they are, in alphabetical order:

20175-131641-01_Commerce DER

20175-131640-01_Commerce EERA

20175-131687-01_Goodhue Wind Truth – Marie McNamara

20175-131650-01-1_Great River Energy

20175-131683_ITC Comments and Attachments

20175-131698-01_Just Change

20175-131686-01_NoCapX – U-CAN – NRG & GWT

20175-131675-01_Wisconsin Power & Light

20175-131688-01_Xcel Energy

Reply comments are due by 4:30 p.m. on May 31, 2017.  eFiling is preferred!  If you need to register to eFile, GO HERE!  It’s easy, quick, and makes filing a breeze.  Get to work — there’s a lot here to comment on!

From the Minnesota Office of Energy Security:


… the Minnesota Resource Assessment … sigh…

Get out your waders… from the solicited Comments at the end, from “stakeholders,” (did I miss some notice and comment period here???  Did any of YOU get notice???) the problems raised are nearly universally complaints.


OK, now open it up and look … and in it on page 6 is that MOE’S napkin calulation that they finagled into the CapX 2020 record after we got extracted some damning testimony about decreased demand, this is such utter bullshit, look at this and see for yourself:


And you may ask, what that in the X axis?  Good question, there’s no identification.  And the Y?  Same.


This is the report we’ve been waiting so long for?

This is the report that, at the Legislative Energy Commission I testified at, Chair Solon-Prettner was asking for, demanding, because it was way late?

This report was presented in all seriousness to the Legislative Energy Commission?  I would hope that I could hear them laughing all the way down here in Red Wing…

Here’s “Capital Costs” from page 19:


And further back, the Preliminary Capital Costs:


Oh, please… Commerce was part of the Mesaba Project, and Elion Amit did the economic analysis.  From that 2005 data, this is way way off, THERE IS NO EXCUSE FOR THIS WHATSOEVER.

IGCC in 2005 dollars was $3,595/kW and now it’s more.

IGCC w/ sequestration is, first, NOT POSSIBLE, and second, price would double just for capture, and the storage can’t be done.

Coal is more expensive that that and you know it.

Wake me up when you can deliver some meaningful numbers.

Look at “Generation by fuel source under selected scenarios” starting on p. 87.  In only one scenario does coal go down at all, and that’s for a “National RES” scenario, and it only goes down a teeny teeny bit.  Give me a break…nationalres


If you have questions or comments on this Minnesota Resource Assessment contact:

Marya White, Reliability Administrator

Minnesota Department of Commerce

85 7th Place East. Suite 500

St. Paul, MN 55101


marya.white [at] state.mn.us

If you want to tell Steve Rakow what you think of his “Forecast Comparison” and analysis:

Steve Rakow

Minnesota Department of Commerce

85 7th Place East. Suite 500

St. Paul, MN 55101

steve.rakow [at] state.mn.us

Once more with feeling…