Legalectric

It was a long, long day. Bottom line? Based on the record, and based on acknowledgement of Xcel’s peak demand history, we can shut down Sherco 1 & 2 now without missing it, and by 2025 or so, shut down Prairie Island and not have to pay for significant rehab to keep it running.

Here is the PUC webcast:

Here is my handout, noting the 700-788MW overstatement of peak demand forecast.

Legalectric_Handout_IRP

If you start with Xcel’s 2015 actual peak demand, and extrapolate using the 0.3% annual increase out to 2030, here’s what it looks like (click for larger view):

These are the charts that they’re using, starting with inflated forecasts of 9,409 and 9,442MW for 2016, note how far off the resulting 2030 “forecast” is — it’s 800 – 1,234 MW off!

With the “forecast” that much off, it’s as absurd as the CapX 2020 2.49% annual increase. Staff questioned the forecasts in the Briefing Papers, Commissioner Lange raised forecasts right off the bat, and Commissioner Schuerger claimed it was at least 300 MW off (don’t know where that 300 MW came from). These discrepancies havce been noted, and they should dig deeper, because the numbers used by Xcel do not add up. Were they lying in the SEC filings or are they lying now? Why isn’t Commerce challenging this, given admissions of the existing surplus? This forecast overstatement, plus admission of under-utilization of grid (meaning grid has been overbuilt, DOH, CapX 2020 and MVP projects are not “needed” in any sense) raises a few issues:

1) This misrepresentation is NOW equivalent to at least one coal plant, and by the end of 2030, or by the time presumed for shut down of Sherco 1 and 2, it’s much more than that.

2) This misrepresentation avoids consideration of shut down of Sherco 1 & 2 NOW, and shutdown of Prairie Island at the 2024-2026 time frame, and avoidance of $600-900 million in capital costs, or more, for Prairie Island.

3) This misrepresentation circumvents discussion of the admitted surplus now existing, even Dr. Rakow admitted to that at least twice in Thursday’s discussion. Where there is surplus, they can sell it elsewhere, and that is, after all, the purpose of CapX 2020 and MVP transmission.

Got that? We can shut down Sherco 1 & 2 now without missing it, and by 2025 or so, shut down Prairie Island and not have to pay for significant rehab to keep it running. This is not rocket science. It’s as simple as using actual peak demand as a starting point and not making up numbers as they have been doing.

Today was Deadline #1 for Comments on NDPC’s Petition for Withdrawal of the Sandpiper pipeline Certificate of Need and Route applications.  Here’s what was filed:

Sandpiper_Landowner Comments_Xmsn

Yup, that’s it.  My Sandpiper transmission clients weighed in.  I’ve been watching the docket, watching the inbox for service…. NO other comments, nothing, nada…

Just get to it.  Quick – take a few minutes and send a missive to the Public Utilities Commission encouraging them to allow Enbridge to withdraw their application for the Sandpiper pipeline WITH PREJUDICE so that they can’t refile it again.  Send to:

Daniel P. Wolf, Executive Secretary  (dan.wolf@state.mn.us)                        Minnesota Public Utilities Commission                                                           121 Seventh Place East, Suite 350                                                                    Saint Paul, MN  55101-2147

Ann O’Reilly and James La Fave, Administrative Law Judges
Office of Administrative Hearings
600 North Robert Street
P.O. Box 64620
St. Paul, MN 55164-0620

But it doesn’t end there, with zip comments… it gets weirder.  I’d saw there was no notice from the PUC about a comment period, nothing.  Here’s what they did with Hollydale, Notice, and there was a comment period and reply comments!  In that docket, Xcel Energy filed to withdraw its Hollydale applications on December 10, 2013, and this notice was issued on January 10, 2014:

20141-95340-02 Notice of Comment Period

Here’s what we got:

And when I asked:

Here’s the response:

Oh my… what do I do with that?  Guess I write a post about it!!!

The Department of Commerce has hit the brakes on Sandpiper Pipeline and Line 3 Replacement Projects “until such time as Enbridge makes clear its intentions about the projects, or until we receive further direction from the Commission.”

Here’s the letter from Bill Grant:

20168-124424-01_Commerce_EIS Scope Decision Document on HOLD

And the guts of it:

YES!!!  Now, about those transmission lines proposed for pumping stations related to these projects????

Word is out, confirming scuttlebutt, that Enbridge will pull the plug on the Sandpiper pipeline.  It’s not official yet, nothing has happened beyond an announcement, but if Enbridge is saying it, IN WRITING, then that means it’s highly likely, eh?

Enbridge Energy Partners, L.P. and Enbridge Inc. Announce Agreement to Acquire Equity Interest in the Bakken Pipeline System Establishing New Path to the U.S. Gulf Coast

Here’s the important part:

Upon successful closing of the transaction, EEP and Marathon Petroleum plan to terminate their transportation services and joint venture agreements for the Sandpiper Pipeline Project. EEP continues to believe the Bakken region is a highly productive and attractive basin, which has significant crude oil supply growth potential that will require additional pipeline capacity in the future. The scope and timing of the Sandpiper Pipeline Project will be evaluated during the quarter to ensure that it is positioned to meet the growing need for pipeline capacity while offering customers competitive tolls and strong netbacks. Additionally, in conjunction with a termination of the Sandpiper joint venture agreements with Marathon Petroleum, EEP will retain 100 percent ownership in our legacy North Dakota system, which is one of the most competitive outlets available to producers in the State.

(what’s a “netback?”).

Reuters has it right with the “OVERBUILD” characterization:

Enbridge’s Sandpiper looks to be latest victim of pipeline overbuild

For this to be “official,” Enbridge will need to file a request to withdraw their application with the Public Utilities Commission, there will be a comment period, then the Commission will decide whether to approve the request to withdraw.

Suffice it to say, this will/would also mean that the transmission for the Sandpiper tank farm NW of Clearbrook is not necessary because the tank farm will not be built there (or in an alternate site)!  And that’s good news for my clients next to that tank farm.

As happened with Hollydale, because the Sandpiper part is before OAH, Enbridge has to request a Withdrawal, which will be certified to the Commission for its blessing.  Here’s the Hollydale request:

Xcel/GRE Hollydale Withdrawal Petition

And for Clearbrook-Clearbrook West 115 kV transmission for Sandpiper’s Clearbrook tank farm, it’s time for Minnkota to withdraw their application!

So I fired off this missive to the PUC:

PUC Correspondence_Enbridge Press Release

Iit’s time to make sure the PUC knows of this Enbridge plan and the impact of this pullout on the need for transmission support!

Under a meme “Raise your voice… before they raise your rates” on a friend’s fb page, the Center of the American Experiment goes off the rails.  They’re fixated on renewable energy as the driver of the Xcel Energy rate case and rate increase, but don’t want to bother with the facts.  Well, it is the Center of the American Experiment, after all…

There’s no posting of the public hearing schedule, and no links to send comments, so what’s the point?  Guess they just want to rant.  I posted info on the schedule, and info about the transmission driver, and surprise, they deleted my comments!

Time to trot out this old favorite:

In Grist today: Transmission Lies

And here’s CAE‘s take:

Renewable Mandate Drives New Increase in Utility Bills

Posted by Tom Steward

on July 12, 2016

Minnesotans continue to pay through the nose for one of the nation’s most expensive renewable energy programs. Electric prices rose by 12.5 percent here from 2007 to 2014, versus a 1.6 percent decline in the average price nationwide.

Today the Minnesota Public Utilities Commission is taking public testimony in the Twin Cities on Xcel Energy’s latest request for permission to jack up ratepayers’ utility bills by another 9.8 percent over the next three years. The request follows five consecutive years of rate increases for Xcel ratepayers, which begs the question of why.

The liberal grassroots group American Association of Retired Persons is leading the charge against a rate hike that will cost average ratepayers an average of $132 more per year.  AARP took out an expensive ad in the Star Tribune this week urging members to show up in force and “raise your voice against another Xcel Energy rate increase” at the PUC hearings.

“AARP knows that when utility bills go up, it hurts Minnesota families, especially those on fixed incomes or struggling to make ends meet. That’s why we’re fighting make sure you only pay what’s fair and reasonable for reliable utility service.” (the quotes aren’t formatting correctly, hence “)

So far, so good. AARP’s website also offers an “easy online tool” to help seniors “share their comments and concerns directly with the PUC.” Of course, doing so automatically opts you in “to receive periodic text, picture and video messages” and “action alerts about the issues that matter the most to older Americans.”

But when it comes to educating AARP’s members on the root cause of the problem, the powerful senior citizens lobbying group gives its usually like-minded environmentalist allies and government supporters a pass.

There’s no mention of why its thousands of members’ utility bills have escalated higher and faster than in most other states, in line with the increase in Minnesota’s renewable energy mandate.

Yet Xcel Energy makes it clear that renewable energy costs are driving much of the rate hike on a website dedicated to the issue.

“We’re making improvements to our distribution and transmission systems for continued reliability, the ability to safely integrate new energy on our system and to continue to provide carbon-free nuclear energy. Those improvements require investments, so we’re also working with regulators to bring more predictability to your energy bills.”  (the quotes aren’t formatting correctly, hence “)

The predictability in our energy bills comes in the form of annual rate increases. And 28 percent of the increase can be directly attributed to “carbon-free energy generation” and “diverse energy,” according to the utility. Another 58 percent goes into the grid for transmission, distribution and technology upgrades, but it’s not clear exactly how much is directly tied to renewable energy development.

Minnesota residents might as well get used to it. If state regulators okay the proposed hike, Xcel customers will have seen their rates increase for eight straight years.

Above is the public hearing schedule for the Rate Case, which apparently CAE does not want published. IF YOU GO TO THE HEARING AND OFFER ORAL COMMENTS, ASK TO BE PUT UNDER OATH (swear or affirm) TO GIVE YOUR TESTIMONY EXTRA OOOOOOMPH!

And to send in written comments, here’s from the PUC blessed  Xcel Notice: