DraftIt’s final… that is, the FINAL meeting notice was just issued, one more go round on these draft rules for Certificate of Need (Minn. R. Ch. 7849) and Power Plant Siting Act (siting and routing of utility infrastructure) (Minn. R. Ch. 7850).

We’ve been at this for about a year and a half, maybe more, and to some extent we’re going round and round and round.

Here are the September 2014 drafts, hot off the press:

September Draft 7849

September Draft 7850

Send your comments, meaning SPECIFIC comments, not “THIS SUCKS” but comments on the order of “because of _______, proposed language for 7950.xxxx should be amended to say_______.”  It’s a bit of work, but it’s important, for instance, the Advisory Task Force parts are important because we were just before the PUC on this last week, trying to reinforce that Task Force’s are necessary, despite Commerce efforts to eliminate and/or neuter them.  That despite ALJ orders otherwise, the Final EIS should be in the record BEFORE the Public Hearings and Evidentiary Hearings (just lost a Motion to require this last month).

How can you comment?  The best way is to fire off an email to the Commission’s staff person leading this group:

kate.kahlert@state.mn.us

If you’re up to it, sign up on the PUC’s eDockets, and file your Comment in Docket 12-1246.  If you’d like your comment filed there, and can’t figure it out, please send it to me and I’ll file it for you.  It’s important that these comments be made in a way that the Commission will SEE, in a way that they cannot ignore, when this comes up before them.

XmsnOldStyle

It’s a different kind of “Wild West” in transmission these days (the photo up above could well be the old 230 kV line through PA and New Jersey!).   But it gets pretty exciting reading through these applications and seeing what it is that these evil transmission promoters are doing.

I did send out a lot of Information Requests today on the ITC Midwest MN/IA transmission project:

IR 1 to ITC (sent a while ago, responses received)

ITCM Response to CETF-NoCapX2020 IR No. 1

IR 2 to ITCMidwest

IR3 to ITCMidwest

IR 4 to ITCMidwest

IR 5 to ITCMidwest

IR 6 to ITCMidwest

IR 7 to ITCMidwest

IR 8 to ITCMidwest

IR 9 to ITCMidwest

IR 10 to ITCMidwest

What I’m most concerned about is that they’re touting all these benefits resulting from this project, but the benefits are associated with not just this project, but the REST of MVP 3, which is this project PLUS the MidAmerican part of MVP 3 in Iowa, PLUS MVP 4 (heading eastward to the Mississippi, and MVP 5, which is heading up to the Madison 345 kV ring, not just the part connecting the MVP 3 and MVP 5, but also Badger Coulee connecting CapX from La Crosse to Madison.  IT’S ALL CONNECTED, and the benefits, as modeled by PROMOD, are economic benefits, where a fundamental assumption of the modeling which includes ALL of the MVP projects, and not just MVP 3, MVP 4 and MVP 5, but all 17 of them.  17.  OK, find, we’re including all those benefits…

… but what about costs?  Wellllllllllllll…

They’re only addressing costs for their teeny-tiny portion of MVP 3, about 1/2 of it in Minnesota and a little bit into Iowa, the red part on this map, and no other costs:

ITC MVP Study 3

The cost/benefit analysis of this project is a little unbalanced:

donkeycart

And it should come as no surprise that their lead witness, ITC Midwest’s David Grover, was behind the TRANSLink docket (oh my… for that docket, go to the PUC search page, and search for docket 02-2152 (NSP) and/or 02-2119 (IP&L) where both utilities were asking the PUC for permission to transfer transmission assets to TRANSLink, what was to be the first transmission only company in Minnesota.   It wasn’t exactly going well, and so they bought out the enviros who had intervened:

Settlement Agreement – ME3(Fresh Energy), Izaak Walton League, Minnesota Center for Environmental Advocacy, North American Water Office

Things went south in transmission from there, because even though the TRANSLink Petition was withdrawn, the utilities just did it another way, and got everything they wanted,  including legislation authorizing transmission only companies:

2005 Ch 97 – Transmission Omnibus Bill from Hell — Xcel’s transmission perks and C-BED

… plus perks like construction work in progress (CWIP) rate recovery, broadened definition of “need,” on and on, a transmission company or utility’s dream.

It’s all connected…