The Notice of Comment Period has been issued:

Here’s the plan to review:

2021 Biennial Xmsn Projects Report

Here’s the poop:

How to file comments? See below, and be sure to ask to be on the service list! If you want live links to make it easier, use link to Notice above.

It’s that time of the year, errrrrr, it’s that time of every other year… time for the Minnesota Transmission Owners:

It’s filed in Minnesota Public Utilities Commission Docket M-21-111.

The Biennial Transmission Projects Report is required by statute, but there are no longer public meetings, and I must admit, I had pushed and promoted a lot initially, but ran out of time and energy for such a … ahem… waste of time. See Minn. Stat. §216B.2425 for how it’s supposed to go.

If history is any guide, it seems Initial Comments are about a month and a half out, mid-January, with Reply Comments another month and a half out, so mid-March. I’ll put it on the calendar and send a reminder around.

There’s nothing really exciting that I see, at first glance, but I did enjoy seeing the NERC Report excerpts. Last time they included the NERC Reliability as a separate filing, this time they included excerpts at the tail end of the report, above.

Here’s the full NERC Report — it comes out every year, and has a great assortment of important info, about reliability margins, load forecasts, and predictions of generation mix for energy and peak demand. I LOVE THE NERC REPORT!! Here’s the most recent ones — they used to come out in October, now it’s December:

NERC 2020 Long-Term Reliability Assessment

This is how reliability was defined in the transmission world decades ago, circa 1999 NERC Long-Term Reliability Assessment:

Keep in mind that now transmission is no longer about reliability — it’s about economics, so it’s a very different type of evaluation.

Who cares about the NERC Report? Over the decades, the NERC reports have looked at the various areas of the country, based on the grid’s organization, and it evaluates the system’s ability to provide electricity. What I like about it, though, is that the charts, graphs, circles, and arrows belie the party line, like all the talk about decreasing coal and fossil fuel generation, but look at projections for MISO:

Here’s the chart for MISO — the devil is in the details — look at the predominance of fossil fuel:

Remember how the utilities were blathering about the NEED for transmission, and that the transmission build-out would decrease need and reliance on reserve margin — at that time, MISO reserve margin was 15%.

They got their billions in transmission and we’re paying them way too much for it, and look at the reserve margin, the last line in that chart:

18%

Oh, well… I must have misunderstood… SNORT!

And yeah, the purpose of that big transmission build-out morphed into “IT’S FOR WIND!” yet remember, the CapX 2020 lines start at the coal plants and head east:

And the MISO MVP 17 Portfolio of projects supporting coal:

It’s exhausting, dizzying, seeing these scams spinning through, and yet here we go with “Grid North Partners.” Just NO!

Again, there will be opportunity for Initial and Reply Comments, expect Notice in a couple weeks, with Initial Comments probably due in mid-January. So later… in the meantime, look at the NERC report and compare with all the blather you’re hearing, particularly with COP26 in the works.

I saw this today and it’s nauseating.

First there was CapX 2020 transmission (following Arrowhead transmission, which was supposed to be the be-all and end-all of transmission)(and the SW MN 345kV line, precursor to CapX 2020. CapX transmission was based on a forecasted 2.49% increase in demand, which as we know, didn’t happen.

And there was the MISO 17 project MVP Portfolio:

Tomorrow, the Wisconsin Public Service Commission is making its decision regarding the Cardinal-Hickory Creek project, the southern part of #5 above, and the LAST of the MVP projects to go through state administrative approval.

So today, this is in the STrib:

Minnesota utilities will study if the $2B CapX2020 grid improvements were enough

The study beginning in January will look at whether renewable energy goals and other factors will bolster need to build out more improvements on transmission grid. 

By Mike Hughlett Star Tribune AUGUST 19, 2019 — 3:05PM

Photo: DAVID JOLESA utility worker assesses electrical power lines in south Minneapolis.

Minnesota’s largest power companies and several other Upper Midwest utilities will study how their transmission network must be bolstered to meet increasingly aggressive renewable energy goals.

The study is being launched at a time when space on the region’s Midwest’s grid is already tight — even after a $2 billion transmission expansion that was completed just a couple of years ago.

That project, called CapX2020, was the work of Xcel Energy, Great River Energy, Minnesota Power, Otter Tail Power and seven other electricity providers in Minnesota, Wisconsin and the Dakotas. CapX2020 took over seven years to complete and included 800 miles of new high-voltage lines.

Ten of the 11 utilities involved in the earlier project Monday announced the “CapX2050” study, which they are aiming to complete in January. The study “will look at maintaining a safe, reliable and cost-effective electric grid as the system adds more carbon-free energy,” the utilities said in a statement.

CapX2020 was the largest transmission project in the Upper Midwest since the 1970s, and it was aimed partly at freeing up power line capacity for burgeoning renewable energy production.

The U.S. electrical grid was built to serve large centralized power plants, but wind and solar farms are more dispersed, often requiring transmission build outs. Xcel has stated plans to produce 100% carbon-free power by 2050, while other utilities also are planning for significantly more renewables.

Also, Minnesota’s DFL Party has strongly backed raising Minnesota’s overall carbon-free energy goal to 100% by 2050.

The CapX2020 project isn’t enough to meet those long-term needs and the grid is essentially “at capacity,” an energy analyst at the Union of Concerned Scientists told the Star Tribune last year.

Xcel’s latest long-term resource plan, filed this spring, came to a similar conclusion. “Many of these (CapX2020) lines planned in the early 2000s and completed over the recent past are already fully-or-nearly-fully subscribed,” the plan said.

So that said, here’s Xcel Energy’s Integrated Resource Plan’s Appendix on transmission:Xcel IRP – Appendix I – Transmission & Distribution – from 20197-154051-03Download

The schedule for IRP hearings was just released, it’s in October, so there’s time to make time for it:

We know Xcel Energy gets a “handsome” rate of return for transmission capital expenditures (hence “CapX transmission), so of course they want to build more. The IRP is our time to tell them how they should get the electricity they need, whether their plans are making any sense.

How about shutting down some of those coal plants, and freeing up some capacity? How about siting solar on every rooftop, over every parking lot, putting the generation at load so we don’t need transmission? Oh, but wait, that makes too much sense, especially where a utility wants to keep control of the generation, and the expenditures, and rake in the dough.

Time to pay attention to the IRP. URP!

Here it is, MTEP 11, the Midwest Transmission Expansion Plan for 2011 (CLICK HERE, look on lower right), and it’s in the news too.  The main report and some appendices:

MTEP 11 – Draft Report

MTEP Appendices A B & C

MTEP 11 Appendix A-1_2_3 – Cost Allocation

Page listing all the Appendices

MTEP Appendix e52 Detailed Proposed MVP Portfolio Business Case

Please take note that this includes not only the CapX 2020 Brookings-Hampton line (#2 on map), but also the LaCrosse-Madison line (#5 on map), the one they need to build or they’ve got a lot of system instability goin’ on.

From my perspective, the most important thing to be aware of is that MTEP 11, and the MTEPs that preceded it, are about the shift to economic dispatch and development of the electric market.  At the outset, MISO studied potential benefits of this shift, and found massive economic benefits, of which they speak in their press release.  The economic benefits are realized by optimizing use of lower production cost generation, and in their own words, to “displace natural gas with coal.”  Don’t believe it?  Read this study that ICF did for MISO:

ICF – Midwest ISO Benefits Analysis

This is the worst possible result for those of us who breathe, and means that tens of thousands of landowners will have very high voltage transmission lines on their land, taken from them by eminent domain.  These projects, almost all of the MTEP projects, are not about electric reliability, they’re “need” is to deliver market transactions of electric generation from any “point A” to any “point B,” and this is a private interest, a desire for market profits, and not a public interest.

Another issue looming is “what does MISO ‘approval’ mean?”  Transmission lines are regulated by states, individually, and there is a movement to strip states of their regulatory authority and transfer that to federal entities.  Look no further than Obama’s transmission “fast track” proposal, naming one of the CapX 2020 projects!  States must make their energy regulatory decisions in an open, transparent process and based their decisions on ratepayer and public interest.  That focus is not present in federal top-down edicts.  States’ rights are at issue and we need to keep on our toes so this power shift doesn’t slide through.

And it’s not “just” the ICF report above, that’s it’s all about coal is clear from prior press.  Here’s an important sentence, quoting GRE’s spin-guy Randy Fordice — explaining what we all know, that the MISO effort to get the “benefits” of displacing natural gas with coal:

They now consider the line to be a multi-value project since system reliability- and service to existing substations and existing fossil fuel plants- are also benefited, he said.

Coal with benefits, yesiree…  Gotta hand it to Fordice for being honest!

You may remember prior posts about that but I’ll start from the beginning and try to make it quick.  There’s a pattern at the Office of Administrative Hearings that is disturbing…

Way back on the MinnCan pipeline, members of U-CAN had tried to intervene and were refused.  They got late notice and were not represented, stumbling through the administrative process pro se.  MPIRG showed an interest and started working on it, among other things, submitting a Petition for Intervention:

MPIRG Petition for Intervention – MinnCan Pipeline

Despite the late notice and their attempts to “work within the system,” the Petition of MPRIG individual U-CAN members was denied:

OAH – Denial of Intervention

And when they appealed, they were tossed out, as if they had not even tried to intervene:

MinnCan Appellate Decision

So when CapX 2020 hit, and they filed a Certificate of Need and landowners learned it wasn’t just the pipeline, but now transmission TOO (how much can a landowner stand?) they got right to it, and intervened as United Citizens Action Network (U-CAN), participating pro se as they had no resources to hire an attorney and were in condemnation and appellate court at the time.  They Petition, and were admitted as full parties.  So what happens?

Judge Heydinger, the same ALJ in the CapX Certificate of Need case as in the MinnCan pipeline case, files sua sponte (on her own initiative, not a Motion brought by parties) a demand that they explain why they, and the Prairie Island Indian Community,  should remain intervenors:

Order to Show Cause – U-CAN

Order to Show Cause – Prairie Island Indian Community

This had been done before in the Excelsior Energy Mesaba Project siting docket, where ALJ Steve Mihalchick booted out Xcel Energy, Minnesota Power, and my client, Public Energy – Mesaba, because no testimony had been provided:

5th Prehearing Order

This docket went forward, there were two days of hearings, first in Taconite, where ALJ Mihalchick rammed through 4 witnesses and where we weren’t provided adequate opportunity for questioning, and, I swear, when I tried to get a table, he said, “Whatever would you need a table for?”  Really… after much hassle, Bill Storm of Commerce found one (thank you!!).  Since that day, I bring my own.  Anyway, the second day, it was -30 in Hoyt Lakes and the hearing was in the unheated gym next to the hockey rink.

That day, Judge Mihalchick rammed through … what… 16 witnesses?…  in one day, and left saying, “I’m not coming back here.”

Travesty doesn’t begin to characterize that hearing.  And worse, Excelsior Energy got a permit for a vaporware project:

Excelsior Energy Mesaba Project siting hearing

Fast forward to 2011, where ALJ Heydinger has now again issued a similar Order to Show Cause regarding two intervenors, Energy Cents and Verso Paper:

Order to Show Cause

Here’s Verso Paper’s response:

Response to Order to Show Cause – Verso Paper

Just filed:   Order Confirming Party Status – Verso Paper

Where’s the Energy Cents Coalition?

Anyway, I’ve submitted a Rulemaking Petition to OAH about Minn. R. Ch. 1400 & 1405 to try to address some of this.  We shall see…