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!
PUC CoN & Siting/Routing FINAL Rulemaking meeting
September 17th, 2014
It’s final… that is, the FINAL meeting notice was just issued, one more go round on these draft rules for Certificate of Need (Minn. R. Ch. 7849) and Power Plant Siting Act (siting and routing of utility infrastructure) (Minn. R. Ch. 7850).
We’ve been at this for about a year and a half, maybe more, and to some extent we’re going round and round and round.
Here are the September 2014 drafts, hot off the press:
Send your comments, meaning SPECIFIC comments, not “THIS SUCKS” but comments on the order of “because of _______, proposed language for 7950.xxxx should be amended to say_______.” It’s a bit of work, but it’s important, for instance, the Advisory Task Force parts are important because we were just before the PUC on this last week, trying to reinforce that Task Force’s are necessary, despite Commerce efforts to eliminate and/or neuter them. That despite ALJ orders otherwise, the Final EIS should be in the record BEFORE the Public Hearings and Evidentiary Hearings (just lost a Motion to require this last month).
How can you comment? The best way is to fire off an email to the Commission’s staff person leading this group:
kate.kahlert@state.mn.us
If you’re up to it, sign up on the PUC’s eDockets, and file your Comment in Docket 12-1246. If you’d like your comment filed there, and can’t figure it out, please send it to me and I’ll file it for you. It’s important that these comments be made in a way that the Commission will SEE, in a way that they cannot ignore, when this comes up before them.
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:
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: