Legalectric

It’s out, the USDA’s RUS EIS for Cardinal-Hickory Creek transmission project:

Draft Environmental Impact Statement – November 2018

• Volume 1: Chapter 1-3

• Volume 2: Chapters 4-8, Appendices

From the RUS Notice, how to send in comments and list of public meetings:

RUS page for Environmental Review for Cardinal – Hickory Creek Transmission Line Project – Iowa & Wisconsin

See the lower 1/2 of MISO’s MVP project 5, running from near Dubuque, IA to the northeast to the “Cardinal” substation near Madison?  That’s the Cardinal – Hickory Creek transmission line.

The Dodgeville Chronicle ran my Letter to the Editor, just in time for the meeting last night, held by Rural Utilities Service, about the Cardinal – Hickory Creek transmission project:

From 4-7 p.m. on Wednesday, December 7th, the Rural Utilities Service (RUS) is hosting a scoping meeting at the Deer Valley Lodge in Barneveld. RUS will again collect scoping comments for its Environmental Impact Study as it decides on a loan to Dairyland Power Cooperative for a share of project costs. RUS held scoping meetings October 31-November 3, 2016 – why more scoping meetings now?

The Cardinal-Hickory Creek transmission project stretches from a substation near Peosta, across the Mississippi River and Wisconsin, near Dodgeville, to a substation near Madison. Last April, as reported in this paper, American Transmission Company’s Jon Callaway reported that the project schedule had been pushed out to 2018 or beyond. The reasons weren’t clear, and should be specified and made part of the RUS record.

Cardinal-Hickory Creek and the under-construction Badger-Coulee transmission lines are MISO’s (Midcontinent Independent System Operator, Inc.) MVP project “five” revealed five years ago in MISO’s MTEEP 11 report. That was 2011, and it was “postponed” in 2016. Why the delay? MISO’s 12.38% rate of return for construction has been successfully challenged in federal court. There’s a glut of electricity where even marketing electricity cross country is not alleviating the industry’s overproduction. MISO’s MVP economic modeling no longer hold under current scenarios. And maybe the delay is that and more!

Now’s the time to tell RUS to consider the economics, need and causes of delay in its financing decision. If delay is right for the project developers, RUS should also delay, and put financing on hold.

Carol A. Overland, Esq.
Red Wing, MN

Time for a nap.  Just filed Comments on the USDA RUS’s Environmental Assessment for Dairyland’s Q-1 D South transmission line.  Here’s the EA:

Q1-South_Environmental Assessment

And here are the Comments I filed on behalf of No CapX 2020:

No CapX 2020 EA Comment_July 1, 2016

zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz

Oh, and the interesting thing is that just this morning, I got a copy of the “Briggs Road-La Crosse Tap 161 kV Rebuild Study”  Thank you, Chuck Thompson!

Dairyland Power Cooperative’s transmission through Onalaska and La Crosse is something to see…

Dairyland Power Cooperative and USDA’s Rural Utilities Service has released the “Q-1D South” Environmental Assessment, open for Comment until July 1, 2016:

Q1-South_Environmental Assessment (BIG FILE)

And from Dairyland’s site:

Briggs Road to La Crosse Tap (Q-1D South) – Environmental Assessment

Comments are due July 1, 2016 — send to:

USDA’s Dennis Rankin:  dennis.rankin@wdc.usda.gov

(I’d also cc DPC’s Chuck Thompson:  cat@dairynet.com)

By U.S. Mail:

Dennis Rankin

Environmental Protection Specialist

USDA Rural Utilities Service

1400 Independence Avenue S.W.

Mailstop 1571, Room 2242

Washington, DC  20250-1571

What’s to comment on?  I see two issues that should be sufficient to stop this project in its tracks — the debt load of Dairyland Power Cooperative and the physical setting of the project which too near and right over people’s homes.

Debt load — Dairyland Power Cooperative’s debt is excessive and should prohibit taking on more debt:

Dairyland Power Cooperative’s Annual Meeting was last week.  One purpose of an organization’s Annual Meeting is to discuss its financial status and approve plans going forward.

Dairyland depends on federal USDA/RUS loans to pay for its transmission expansion, such as the Q-1 transmission upgrades, including Marshland-Briggs Road and now the stretch from Briggs Road to North La Crosse south of I-90. Another USDA/RUS loan paid for Dairyland’s share of the CapX La Crosse line now blighting the bluffs. Dairyland will also be part owner of the MISO Hickory Creek to Cardinal line from Iowa to Madison. That’s a lot of transmission and loans.

Dairyland recognized this financial risk and lopsided debt/equity position, and in 2012 sought help from FERC_(DPC_Request4DeclaratoryOrder), requesting a hypothetical capital structure of 35 percent equity and 65 percent debt when its actual capital structure was 16.5 percent equity and 83.5 percent debt, and FERC did grant this relief in an Order for DPC for CapX 2020 (see FERC Docket, go HERE and plug in docket EL13-19-000).  That Order, and the 83.5/16.5% debt/equity ratio was prior to the present Q-1 D South project and the MISO MVP Hickory Creek to Cardinal transmission line.  Dairyland requested a “hypothetical” (bogus) debt/equity ratio to preserve its credit rating and enable low cost loans. The true debt level makes DPC a higher risk.

Are Dairyland members aware of the 83.5%/16.5 % debt/equity ratio and reliance on loans for major transmission projects? What’s the debt level where new projects are included? This new transmission enables increased power marketing and sales, a private purpose. Is this highly leveraged position for new transmission in the best interests of Cooperative members?

Physical setting of the project — it’s just too close!

The map way above is what the transmission system in the area looks like theoretically, according to the Wisconsin Public Service Commission, but here’s what Dairyland’s Q-1 South line looks like on the ground:

Really… Here’s what it looks like from a satellite with the lines drawn in, on the far south:

Here’s what it looks like further north — look at all those homes:

And here’s what the Wisconsin PSC Code says about clearances in PSCW 114.234:

(2) Transmission lines over dwelling units. [Follows NESC 234C1b, p. 119] (Addition) Add the following paragraph c:

c. Transmission lines over dwelling units.

No utility may construct conductors of supply lines designed to operate at voltages in excess of 35 kV over any portion of a dwelling unit. This provision also applies to line conductors in their wind-displaced position as defined in Rule 234A2.

Note: It is the intent under s. SPS 316.225(6) that the public not construct any portion of a dwelling unit under such lines.

Note: The term “dwelling unit” has the meaning given in ch. SPS 316, which adopts by reference the definitions in NEC-2008.

Note: See s. SPS 316.225(6) Clearance Over Buildings and Other Structures, which refers to ch. PSC 114 regarding clearance of conductors over 600 volts and the prohibition of dwellings under or near overhead lines.

Above is my view of La Veta, Colorado.  As I drove in, I saw two deer sauntering, yes, SAUNTERING across a farm field at the edge of town.  And in town, they were just walking around like they owned the place, fat and happy.  This one above was a buck escorting two of his does, maybe one and last year’s progeny, and they were walking down the streets, through yards, hanging out oh-so-casual.

There are some days, well, most days, I confess, when I really love my job… yesterday was another!

Yesterday was a forum held by TLC, Transmission Line Coalition, last night in La Veta and tonight in Alamosa:

TLC Forum Poster

Here’s some of what I had to say:

San Luis Valley Dog & Pony

Xcel, of course, was there, and I’m sure they’ll be there tonight!

Here’s the ALJ Recommendation, this will sound very familiar to those in Minnesota:

San Luis Valley ALJ Recommendation

As we say in transmission, “IT’S ALL CONNECTED.”

Xcel’s GI-2008-32 Feasibility Study Report

HPX Stakeholder 11-14-07 (9.3% line loss, export)

(Pretend there’s a link here to USDA’s RUS EIS page – it’s DOWN DOWN DOWN)  NEVERMIND, it’s now UP UP UP!  From RUS (note this San Luis project is about 4 months behind Dairyland/Capx:

Tri-State Generation and Transmission

Association, Inc.

San Luis Valley-Calumet-Comanche Transmission Project – Huerfona, Alamosa and Pueblo Counties, CO – The agency has decided to prepare an Environmental Impact Statement on this proposal; the original level-of-review was an Environmental Assessment.

• Federal Register Notice to hold Scoping Meeting and the intent to prepare an Environmental Assessment (August 3, 2009 – 47 KB)
• Calumet-Comanche Electric System Improvement Project – Macro Corridor Study (May  2009 – 24 MB MB)
• San Luis Valley-Calumet-Comanche Transmission Project – Alternatives Evaluation (June 2009 – 510 KB)
• San Luis Valley Electric System Improvement Project – Alternatives Evaluation and Macro Corridor Study (June 2008 – 14.2 MB)
• Public Scoping Report (November 16, 2009 – 28.6 MB)
  • Index of Public Comments

What I want to know is WHY they are using lower capacity ACSR conductor for these projects — and the claimed “need” is SO low, why aren’t they just reconductoring the whole system — ACSR, euwwww, that is SO 1960s:

SW MN 345kV Ex35, App. 7 – Conductor Spec

And demand forecasts?  Need a good laugh?  Here’s the sales forecast for Public Service of Colorado, our good friends at Xcel:

I’ve just learned that this area is mushroom country — methinks that this “forecaster” has been dabbling in some of the more exotic varieties to come up with this chart!