Rulemaking Ch. 7829 at PUC tomorrow
November 18th, 2015
Tomorrow, the Chapter 7829 Rulemaking is going to the Commission, for approval of the FINAL rules. This rulemaking has been going on formally for over two years now in Docket 13-24 (go to NEW SEARCH and search for this docket).
Overland 7829 Comment Nov 18 2015
And some history… I’ve been concerned about this chapter for a long while, and submitted a Petition for Rulemaking over FOUR YEARS ago. Apparently that was filed in the trash:
And prior posts:
Ch. 7829 Rulemaking Comments July 20th, 2015
Stealth rulemaking — PUC’s Minn. R. Ch. 7829 July 10th, 2014
PUC’s Stealth 7829 Rulemaking Docket June 4th, 2013
PUC requests Comments on 7829 rules August 8th, 2013
Minn. R. 7829 marches on… September 9th, 2013
Onward with PUC Certificate of Need and Routing Rulemaking
August 19th, 2015
We’ve been working on the rules for the Minnesota Public Utilities Commission’s chapters covering Certificate of Need and Siting/Routing of electric utility infrastructure, ranging from transmission to power plants. WHEW! It takes forever, and thus far it’s been over two and a half years, just for the “pre-Commission-sends-it-out-for-comments” rulemaking advisory group part.
Who cares about rules? Well I do, as to many others who have been dealing with Certificate of Need and Routing/Siting issues over the years. It’s important because so many things are wrong with the process, from awkward to just plain wrong/unfair, even in light of the enabling statutes for these rules (rules need to operate within some pretty restrictive statutory framing).
This is, again, still informal, and PUC is open to any and all comments, ones on point, that is, and so comment on specific language, and suggest specific language! Here’s the latest (and I’ve filed them on the PUC site):
To see the versions and comments thus far, go to the PUC’s SEARCH PAGE HERE, and search for PUC Docket 12-1246.
To file comments, go HERE and file. If you’re not registered to file, go HERE and register and file! It’s that easy, almost instantaneous!
JCSP Big Picture – who pays? WE DO!
July 2nd, 2013
Transmission — it’s all connected. In looking at the Minnesota rulemaking, and the existing and proposed rules that utilize the word “regional,” I’m thinking about big picture stuff, the big proposals in the wings, and that Joint Coordinated System Plan (JCSP) map sure presents a big picture. For some reason, I’ve not been able to find the full JCSP report until recently:
Who cares about JCSP? Well, WE’D better care, because look who’s paying for the transmission build-out (p. 68 of Vol. 1):
Look at the numbers for Midwest ISO, a $-10,293, or for MAPP, a $12,292, that’s a COST, not a savings. MISO and MAPP get nominal production cost savings and massive load COSTS. This is not news, but is worth repeating as we discuss “regional.” And another take with the same take-away of big costs for MISO and MAPP customers, used by our good friends at AWEA to promote this transmission buildout in their flyer called “Green Power Transmission and Consumer Savings” (flyer below):
Read the whole thing:
What a deal, eh?
Look what AWEA has been advocating to make this happen:
PUC Rules Comments due Tomorrow
January 23rd, 2013
Comments due TOMORROW!!! If you want to be a part of the Rulemaking Advisory Committee, this is the time to let them know that you want to be included. After you’ve written your comments, file in PUC Docket 12-1246 or email to: kate.kahlert@state.mn.us
The Minnesota Public Utilities Commission has opened a docket for… get this:
Possible Amendments to Rules Governing Certificates of Need and Site and Route Permits for Large Electric Power Plants and High-Voltage Transmission Lines, Minnesota Rules, Chapters 7849 and 7850; and to Rules Governing Notice Plan Requirements for High-Voltage Transmission Lines, Minnesota Rules, part 7829.2550; Revisor’s ID Number R-04151; PUC Docket No. E,ET,IP-999/R-12-1246.
This is similar to the OAH “Possible” rulemaking, where they’re on a fishing expedition, for what I have not a clue, whether it’s to get ideas, or find out what not to include or identify the usual suspects, very hard to tell, and I couldn’t get any information out of Bret Eknes at the PPSA Annual Hearing. The notice states “The Commission has not yet drafted the possible rule amendments.”
Here’s the notice — note they do say that part of this is to “maximize citizen participation” so let’s hold them to it:
Request for Comments – “Possible” Amendments to Rules PUC Docket 12-1246
Possible? Ummmmm, right… well, it’s about time. Here’s the PUC’s Rulemaking site (you can also go to eDockets, search for 12-1246):
I’d put in a rulemaking Petition two years ago tomorrow…
Overland Petition 2010 PPSA Annual Hearing, filed January 2011
…and they said they wanted it broken down. OK, sure, whatever, so I did. Thus far I’ve filed the OAH ones, and haven’t gotten around to doing that yet. SO, got to work today and ground out these comments based on the previously filed ones, you can use these for ideas, steal away!
NoCapX & U-CAN Comments – Jan 23, 2013
Once more with feeling, they’re due tomorrow.
Comments – Rulemaking at Public Utilities Commission
December 13th, 2012
There’s the ongoing rulemaking at Office of Administrative Hearings, and now there’s a notice from the Public Utilities Commission requesting comments.
‘Bout time — here we go, the preamble to rulemaking notice:
At this point, there’s nothing to comment on, it’s a free form free-for-all about what needs to be changed and how in Minnesota Rules Chapters 7849 and 7850. Ch. 7849 doesn’t exist now, but they’re going to move the Certificate of Need Notice Plan rules in 7829 to 7849. But 7828.7849 is Certificate of Need and 7850 is Siting/Routing. EH?
Here’s what they say:
Subject of Rules. The Minnesota Public Utilities Commission requests comments on
possible amendments to two rule chapters governing large electric power plants and high-voltage transmission lines: Chapter 7849 and Chapter 7850. The Commission also intends to move the notice plan requirements for high-voltage transmission lines contained in Minn. R., part 7829.2550 into Chapter 7849. The Commission is considering rule amendments to streamline and enhance the effectiveness and efficiency of both processes. The Commission aims to align the procedures of both rule chapters to the extent feasible, to clarify the structural framework of the processes, to resolve inherent timing conflicts, to maximize citizen participation, and to
incorporate new statutory criteria required for demonstrating that a project is needed.
Links to the rules they’re looking at:
Minn. R. 7829.2550 Notice Plan when seeking certification of high voltage transmission lines
Go figure… Does this mean they’re looking at applying Notice Plan rules to both Certificate of Need and Siting/Routing?
Comments are due by 4:30 p.m. January 24, 2012.
Kate Kahlert, Staff Attorney Public Utilities Commission 121 Seventh Place East, Suite 350 Saint Paul, Minnesota 55101-2147
Telephone: 651-201-2239, FAX: 651-297-7073
email kate.kahlert(a).state.mn.us
TTY users may call the Commission at 1-800-627-3529
Anyway, now we have yet another opportunity to propose specific changes, as I’ve done over the years at the PPSA in filing rulemaking Petitions: