Dodge County Wind info presentation
July 29th, 2018
Dodge County Concerned Citizens asked me to do an information presentation on NextEra’s Dodge County Wind project, which was recently applied for at the Public Utilities Commission. Here’s my presentation:
Turbine and Transmission Neighbors?
Completeness comments are due August 10, 2018, with reply comments due August 17, 2018.
20187-144854-01_PUC Notice_Completeness Comments_ALL dockets
How to file?
Here’s a form you could use for guidance — yes, its a test, and an essay test at that. Your original words are what count, because you know your community best, what impacts on the ground might be. You can best identify the material issues.
It was interesting that Beth Soholt, is concerned enough to show up on a Saturday morning! She’s the ED of wind industry association Wind on the Wires (f/k/a program of Izaak Walton League Midwest until Bill Grant was appointed Deputy Commissioner – Energy – Dept. of Commerce) But her being there was not much of a surprise, because NextEra’s Julie Voeck is Chair of the WOW Board. And don’t forget that PUC Commissioner Matt Schuerger’s “Energy Systems Consulting Services” was a primary recipient of Waltons/WOW consulting funds. As we say in transmission, “It’s all connected.”
Can’t find a Dodge County Wind, LLC website (it is a Delaware LLC registered with Minnesota Secretary of State), and NextEra has nothing on its website about the LLC, nor about the Dodge County project, that I can find, ALL Press Releases are about MONEY, not a one about “Dodge County.” There is a separate transmission page with “project info” but no project specific info there either.
This project was really difficult to dig through, because there are THREE dockets: Certificate of Need (17-306); Wind Siting (17-307); and Transmission Routing (17-308). WHEW! This would be overwhelming to anyone, and to try to explain what’s proposed, the process (UGH!), and issues, that’s a couple of books… whether fiction or non-fiction remains to be determined.
Post Bulletin – Proposed Dodge County wind farm raises questions
KTTC – Dodge County Concerned Citizens holds informational meeting on proposed wind turbine project
KIMT – Wind project proposed in Dodge County
This project has been brewing for a while, because there’s a Certificate of Need requirement of a Notice Plan before anything is applied for, and then notice goes out as laid out in the Notice Plan.
I’m on the general service list for all projects, pretty much everything, so I have an idea what’s new and exciting at the PUC, but it’s pretty hard to track it all. For this project, the initial “notice” filings for 17-306 (Certificate of Need) & 17-308 (345kV transmission line) were in April, 2017, and the transmission route app and wind site permit app were not filed until 6/29. The wind site permit is most significant in terms of cost and geographic spread, and nothing was filed until June 29, 2018, less than a month ago. The wind site permit filings contain an affidavit of mailing of notice but NO ADDRESSES, and the transmission affidavit of mailing of notice DOES have addresses. Why are no addresses included?
Three dockets, all those filings, at least 1,000 pages, and I confess haven’t read all of it! What jumps out at me is that this is another scattered site project, with a large footprint. It’s a 170MW project, not unusual in that way, but the turbines proposed are 2.5 MW turbines. That’s BIG! The reported hub height is 291 feet, and from ground to tip of blade, 485.5 feet. That’s BIG!
How to look at the dockets:
So now, quick because Completeness Comments are due, it’s time for people to take a look at this project, what’s proposed for the wind project, the big honkin’ transmission line, and whether all this is needed.
Oh, and about that big honkin’ transmission line, here’s a cut and paste from their application:
Characterizing this bundled 345kV line as “generation inter-tie?” Oh, please…
PROCEDURE ALERT: PUC going off in the weeds with “modifications”
June 28th, 2018
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.
Exceptions to ALJ’s Freeborn Recommendation
June 9th, 2018
Here’s the Recommendation of the Administrative Law Judge.
In short:
Exceptions of parties to the Freeborn Wind siting permit proceeding:
Freeborn_Exceptions_20186-143678-02
Exceptions of “affected parties”
Cookie cutter cut and paste form letters with minor modifications:
Here’s a late filed one, another form letter:
Bent Tree Order filed by PUC
June 5th, 2018
The settlement agreements for Minnesota’s first landowner buyouts were approved by the Public Utilities Commission at its agenda meeting on May 17, 2018. Today, it’s REAL, the written order has been filed.
Thanks to Alliant/Wisconsin Power & Light for their work in getting this done. Now, time for a couple of closings!
And at the same time, let’s whip this wind siting process into shape!
Freeborn Wind transmission hearing TONIGHT!
May 31st, 2018
Tonight is the public hearing, using the “Alternative Review Process,” for the transmission for the Freeborn Wind Project, the very same project that has been recommended be denied by the Administrative Law Judge:
WE WON!!! ALJ Recommend Freeborn Permit be DENIED, or…
Be there or be square:
What’s at issue? Most important is “need” and lack thereof. Under Minesota Rules, need may not be addressed in the environmental review:
BUT, where there is no Certificate of Need, issues of size, type and timing MAY be addressed — the prohibition of addressing need only applies where a Certificate of Need has been issued:
7850.4200 FACTORS EXCLUDED.
When the Public Utilities Commission has issued a Certificate of Need for a large electric power generating plant or a high voltage transmission line or placed a high voltage transmission line on the certified HVTL list maintained by the commission, questions of need, including size, type, and timing, questions of alternative system configurations, and questions of voltage shall not be factors considered by the commission in deciding whether to issue a permit for a proposed facility.
There is no Certificate of Need required or issued for this project, and so “questions of need, including size, type, and timing, questions of alternative system configurations, and questions of voltage” are fair game.
In this case, it’s particularly relevant where the ALJ has recommended the project site permit be denied! No project, no transmission needed.
Off to Albert Lea!