Legalectric

RIGHT NOW! It’s the PPSA Annual Hearing… sigh… here we go again.

Go to webex, Event # 146 311 2620. The powerpoint slides will be here (and will also be filed on eDockets).

To be able to comment, you have to get on the phone 866-609-6127, Conference ID: 4449079, and to comment, you need to press #1 and get in queue.

Here is the Commerce info about this year’s projects:

And for the record, folks, note that wind is not exempt from many of the parts of the PPSA:

The June 25, 1998 blackout report needs to be on the interwebs available to the world.

June 25, 1998? That’s the night of the transmission fail that disconnected the Midwest from the Eastern Interconnect. That question was asked by Minnesota Power’s attorney of each and every witness, I think other than MP, but maybe MP witnesses too, in the Arrowhead transmission project hearing, circa 1999-2000. There were cries of “Hospitals will go dark without the Arrowhead project,” “We’re going to freeze in the dark in an incubator” which became “We’re going to freeze in the dark on a respirator without a job” — it was so histrionic.

The Arrowhead transmission project was project 13J of the WRAO Report, and the WIREs Report, which presented many transmission lines, but chose the Arrowhead transmission project as the “be all and end all” of transmission in the Midwest, that it would fix all the transmission problems:

The hearing went forward, 2 weeks in Minnesota, where MP got an exemption from Minnesota Power Plant siting law, and for TWO MONTHS in Wisconsin, for Round 1, then 2 weeks after the cost went way up, and another 3-5 days of hearing later when cost went up again. They got their permit, it’s up…

But in that first hearing, I did get to introduce the report that showed that the June 25, 1998, blackout was NOT caused by too little capacity, it was not caused by an unreliable transmission system. It was caused by corporate greed, transmission operators running the Prairie Island-Byron 345kV’s TCEX flow over the limit, disregarding operating guides, and disregarding requests and demands to ramp the power down, violating MAPP Operating Standards and NERC Operating Policies. SHAME, NSP, SHAME!!! And MP was so tacky, trying to attribute their desire for bulk power transfer to the blackout, that the Arrowhead project would save us. Yeah, right…

Here’s the report, below, it’s a gem, I’m posting this today because I’m shoveling off my desk and there are a lot of gems here, so posting them will get them out into the world in perpetuity — can’t disappear something from the internet! Scanning them in is taking a while, a royal and dusty pain in the patoot, but just for you inquiring minds, HERE IT IS:

Here are a couple snippets, starting with p. 2:

Bottom line?

OPERATE WITHIN OPERATING GUIDE LIMITS!!

DOH!

The report goes on and on with stupid human tricks – the flow was NOT reduced by NSP System Operators:

From pps 10-11:

So if the operators had been doing the job, not focused on keeping that line operating with all that power flowing through it, selling that power, the blackout may not have happened. Great…

And for some reason, NSP operators were not communicating:

300 MW above the operating guide limits:

OPERATE WITHIN OPERATING GUIDE LIMITS!! DOH!

Operator error is a too-generous way to put it — but for the efforts to NOT reduce power flows, the inadequate response of system operators and their failure to communicate the degree of the problem, the blackout may not have happened. And then utilities have the nerve to say that because of the June 25, 1998 blackout, we need the 13j Arrowhead transmission project?

How many years have I been saying that the purpose of this massive transmission build-out is to market coal elsewhere? Decades, folks, it’s been decades… And this latest from Xcel Energy, Notice of Comment period just out today, is demonstration that they plan to keep running those coal plants and selling it. Will the Public Utilities Commission care?

Here’s the newly released Xcel Energy plan, and a comment period:

The plan?

Here’s the Notice:

What to comment about? From the Commission’s Notice:

Bulk power transfer was the whole point of the transmission build-out, to be able to sell anything generated at any Point A to any Point B. And then coal generated here could be sold elsewhere, eastward via transmission, while we use generation that isn’t quite so dirty (but that’s dirty in its own way). We’re so clean here in Minnesota… NOT! We’ve been a pass through for Dakotas’ coal for a while, and now, they’re asking permission to keep burning coal here and send that energy eastward.

They built all that transmission, no Commission I’ve seen has ever found a transmission plan they didn’t like and roll over for, and now we’re paying for it. Rate increases anyone? Are you paying attention to what’s pushing those rates up?

Why ever would I say that it’s all about selling coal? Well… there’s a bit of a pattern going here. There was the Chisago project, starting in 1996 and three iterations in Minnesota and Wisconsin, not to mention the WRAO report:

WRAO laid out many transmission lines and the Arrowhead transmission project, circa 1999, was selected as the be all and end all of transmission after many hearings were held, one hearing in Minnesota and THREE before Wisconsin PSC, the price kept going UP, UP, UP!

But then on September 8, 2001, a meeting with likely intervenors to see if they could be convinced to “approve” of the SW Minnesota 345kV line, remember that, Commissioner Matt Schuerger? I pointed out all that coal lined up in the SW MN 345kV study… and from there on to the SW MN 345kV line, part of ABB plan for coal:

Don’t ya just love that name? It says it all. Why the ABB Lignite Vision 21 Transmission Study? The opening paragraph, linked above, DOH! says:

The SW MN 345kV line was the part that’s running east to west on the lower part of that yellow map, from Split Rock sub to Lakefield Junction. Some claimed it was an “It’s for WIND!” line, but that’s a lie, just read that ABB study again. The powerflows showed that it wasn’t to carry energy off of Buffalo Ridge, there was just 213-302 MVA coming off Buffalo Ridge into the over 2,000 MVA capacity line:

How stupid do they think we are? Well, money talked, and that money ruled the day. That SW MN 345kV line and the TRANSLink Settlement Agreement and 2005 Transmission Omnibus Bill from Hell (and changes to Minn. Stat. 117.189) laid the groundwork to bring us $2+ BILLION of CapX 2020:

And then the MISO MVP 17 project portfolio, now over $6 BILLION:

And then they have the audacity to suggest we need MORE transmission?

Upper Midwest utilities to study transmission grid in light of ambitious carbon reduction goals

CapX 2050 Vision Study

So please explain how selling coal generated electricity on the MISO market is consistent with carbon reduction goals?

What a crock…

The Minnesota Department of Commerce issued the Draft EIS for the Dodge County wind project, and about the “C” and “D” route proposals for a 345kV line through the heart of Dodge Center, they had this to say:

Here’s the full DEIS Narrative:

This is an example of why it’s crucial to get involved early, that comments must be made at the outset before they have moved into evaluating a proposed route, so that they can consider the input of people on the ground in the initial evaluation. Here, at least 14 people weighed in on the impacts of the C and D routes on their homes and their lives, and that message was heard.

Now’s the time for the City of Dodge Center to acknowledge that it was Tom Applegate’s efforts, alerting the City of Dodge Center and the residents effected by this project’s Route C and D possibility, helping generate the many comments that were filed, that made Commerce’s rejection of these routes a reality.

And I sure hope Commissioner Tuma acknowledges what a bad idea routes C and D were and that next time he has a routing idea, that he commits to spend at least an hour on google earth along the route to know what he’s proposing. These two proposed routes were the worst I’ve seen for a 345kV line.

The Dept. of Commerce was instructed by the Minnesota Public Utilities Commission to include routes for the Dodge County Wind project to include existing transmission corridors. Commerce didn’t haul out a transmission map at the time to say “WHAT WOULD YOU SUGGEST” and instead chose “routes” that run right through the heart of Dodge Center, and which would, with a 150′ easement, not only tower over residential neighborhood but would displace rows of homes because the easement edge would run right through the houses!

CLICK HERE for Dept. of Commerce Dodge County transmission site.

CLICK HERE for Commerce’s INTERACTIVE WEB MAP

Here’s what it looks like from the sky:

CLICK HERE for City of Dodge Center page on this transmission proposal.

City of Dodge Center is missing the boat in suggesting people wait to let Commerce know how bizarre, unconstructable, and most importantly, how many people would be displaced, how many homes would be bulldozed, to build a 345kV transmission line with 150 foot rights of way through town. The time to send WRITTEN comments to Commerce is NOW, because when the DEIS is released at the end of June (probably, though maybe later), it should say that those routes through town should not be further considered as they just won’t work.

Send comments, with photos showing existing transmission in relation to your home, your neighbors’ homes, to:

suzanne.steinhauer@state.mn.us

The sooner you weigh in the easier it is to alter the outcome. In the case of administrative proceedings, you snooze, you lose.

The City of Dodge Center needs to get on this too, NOW. Why? It’s in the City’s interest to have routes through town and through these neighborhoods stopped, to assure that they don’t go forward in the environmental review. If you’re in Dodge Center and are concerned, contact your City Council representative:

DODGE CENTER COUNCIL MEMBERS CONTACT INFO HERE

Comments must be in writing, phone calls don’t count (though you can get more information that way, by calling Suzanne Steinhauer: (651) 201-2251).

DODGE THIS TRANSMISSION LINE!