Legalectric

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:

Last night there was a hearing in Mankato on the Xcel Energy rate case (Docket E002/GR-15-826).  Public participation in Public Utilities Commission dockets is supposed to be a happenin’ thang…   But there were no witnesses to question yesterday at the public hearing, and the Xcel representative who was there could not answer questions.  Worse, there was no commitment to have witnesses available to the public at the public hearings, and only advice that the public could attend the evidentiary hearing.  ATTEND?!?  When might we be able to question witnesses?

Sent this Data Practices Act Request this morning to round up the Information Requests and Responses regarding transmission, transmission riders, MISO and FERC:

Data Practices Act Request

Xcel Energy wants to shift its transmission rate recovery from CWIP and AFUDC to general rates, but there was no one there to talk about it.  These are the MVP projects at issue, in Schedule 26A, below, which are worked into MISO tariff and FERC blessed:

And here’s the projects in Schedule 26, below, but hmmmm, no project costs shown (click for larger view):

I entered these exhibits:

Exhibit 1A – XcelCover_e21_Request for Planning Meeting and Dialogue – PUC Docket 14-1055

Exhibit 1B – e21_Initiative_Phase_I_Report_2014 – Xcel Filing PUC Docket 14-1055

Exhibit 2_MISO Schedule 26A Indicative Annual Charges_02262014

Exhibit 3 – FERC EL-14-12-002_ALJ Order – ROE on MISO Transmission

Next meeting I’ll have some more:

e21_MikeBull_Center for Energy and Environment

MISO Schedule 26 Indicative Annual Charges

1Q_Earnings Release Presentation_5-9-2016_1500085150

Investor Presentation – NYC-Boston_3-1-2=16_1001207698

Investor Presentation – NYInvestorMtgs_5-10-2016_1500085349

2015 10K – Xcel Energy

2015 10K – NSP

Back to last night’s hearing…

Check the rules about public participation:

1400.6200 INTERVENTION IN PROCEEDINGS AS PARTY.

Subp. 5.  Participation by public.

The judge may, in the absence of a petition to intervene, nevertheless hear the testimony and receive exhibits from any person at the hearing, or allow a person to note that person’s appearance, or allow a person to question witnesses, but no person shall become, or be deemed to have become, a party by reason of such participation. Persons offering testimony or exhibits may be questioned by parties to the proceeding.

Another, the PUC practice rules:

And yet another:

And this one (though they’ll say it isn’t applicable because a rate case isn’t part o the Power Plant Siting Act):

Really!  Xcel Energy has paid less than $1 million in federal income taxes in the 7 years from 2009 through 2015!

This is from the Direct Testimony of Nancy Campbell, Department of Commerce DER:

Campbell_DER_Direct Testimony_20166-122243-04

Here’s the Exhibit she refers to, scroll down to “NAC-20” at the very end, where you’ll find Xcel’s answer to IR 1171:

Campbell_Direct_Attachments1_20166-122249-01

I’m looking into whether any intervenor or state agency is looking at the Xcel Energy proposal to take transmission out of CWIP rate adjustments and put into general rates. What they’re asking is:

and:

(this paragraph is is repeated a few times).  This Transmission Cost Recovery plan can be found by searching the Xcel Energy Rate Case Application (PUC Docket 15-826):

1_Application_201511-115329-01

But this transmission cost recovery is at a rate that is FERC approved MISO rates, challenged at FERC, and greatly reduced in the FERC ALJ’s Order — note Xcel Energy’s “DCF result” is 8.40%, a long way from 12.38% (on the very last page):

FERC EL-14-12-002_ALJ Order

The issue, per the ALJ:

Here’s a more detailed look at the issues in the Complaint:

And cost apportionment for these projects is spread out in MISO Schedule 26A (updated every year).  This is how they’re apportioning costs among the utilities handling the many zones in MISO:

Yeah, it’s impossible to read — here’s the Excel spreadsheet (2014 version, this is updated annually):

Exhibit B_Schedule 26A Indicative Annual Charges_02262014

There’s lots of testimony in this rate case, including from the “Minnesota Large Industrial Group” (note Minnesota large industrial customers pay lower per kw cost than us regular residential customers!), and so digging through this is just the beginning…

And remember, this is the case where the ALJ denied Overland and No CapX 2020 intervention, saying:

Further, the Petition states that purposes for which No CapX 2020 was “specifically formed” (fn 22 omitted) was to participate in dockets which are now closed, raising the question of why No CapX 2020 continues to exist.

Really, that’s what the judge said!

Denial #2_Overland-NoCapX Intervention

Why No CapX 2020 continues to exist?  Perhaps to raise issues that no one else is raising?!?!  Oh, well, they can’t have that, can they…

Speaking of Xcel Energy, they’re in the news:

Large Outflow of Money Witnessed in Xcel Energy

Over 640 Xcel Energy customers (households, businesses) are without power here in Red Wing this morning after the storms came whipping through here yesterday afternoon.  Ours was out for a while, maybe an hour, and then back on.  Towards the west end of town, that’s another story, and they’re still without power.

Xcel Energy Outage Map

From the map, it looks like Eau Claire was very hard hit, with 2,300+ customers still without power.

The Dogometer predicted a bad storm about half an hour before it hit, evident when she firmly assumed the position under my desk.  Now she’s back to normal.

Remember Xcel Energy’s Hollydale Transmission Project that was derailed when it was clear it wasn’t needed, and so Xcel Energy withdrew the application with regular compliance reports on status of the project, and a promise of a need study so long ago???

Yeah, I’ve been forgetting too, it’s been so long.  Here’s Xcel Energy’s page on what’s now called the “Plymouth Project.”

But, here it is!!  Finally, it has arrived, the Hollydale System Assessment Report from Xcel Energy that we’ve all been waiting for:

Plymouth_and_Medina_Electrical_System_Assessment-Final_Complete

Pay particular attention to the map above of the “study area,” and note that it is the Interstate 494/694 ring and Hwy 55 to the east and north where the problems are, and the problems are yellow and orange, and not red.  The problems are not in the area of the Hollydale substation and not to the west, towards Medina.

When do we start seeing problems?  Looks like it’s in 2036, 20 years from now, double the usual 10 year transmission planning outlook (hint, that means it STILL is not needed) — and note, again, the problems are to the east and north, along the highways:

I’ve got to scour this report, but I do not think that they’ve considered select placement of distributed generation, i.e., solar panels on all the big boxes in the areas above in red!  Or residential solar on those in yellow.  What’s so difficult about that?

Here’s their choice:

On the plus side, there’s new substations planned in the red territory.  On the minus side, they still want to utilize the Hollydale substation.  On the plus side, they plan to expand transmission using 34.5 feeders, which is what I promoted as a solution.  On the minus side, they plan to keep the 69 kV line through Plymouth, with an eye on utilizing it in the future.  On the PLUS side, they claim that there’s no impact on the Hollydale – Medina section of the 69 kV line, claim that there’s no change from present use and non-use, and for my clients in Medina, that’s a good thing.  On the MINUS side, they don’t propose to tear that “unused” 69 kV line down.  On the MINUS side, they don’t propose to put all the transmission and distribution underground.  And remember, just yesterday, when there was a large distribution outage due to wind out in the western suburbs?

So now, it’s time to read this report!