Legalectric

A shindig has been announced, at which Xcel Energy will unveil its plans, the options it has deemed “alternatives” to the Hollydale Transmission Project.

Xcel Energy’s Hollydale “Open House”

May 25, 2016 from 12-2 p.m. and 4-7 p.m.

Medina Ballroom

500 Highway 55

Medina, Minnesota

Heard some time ago that this was in the works, and made a scheduling request, overtly received with intent to schedule around time I could not attend… well, so much for that.  Gee, thanks, folks!  PPPPPPPPPFFFFFFFFFFFFFFFFBT!

Now, on to the Hollydale Transmission Project.  This is the project that Xcel withdrew, because it was apparent that it wasn’t needed… well, Xcel would never admit that, but it was going down in flames:

Xcel and Great River pull the plug on Hollydale applications

This is a project that was first applied for in 2011, 5 years ago!  That project was a plan to run a 115 kV transmission line through Plymouth and Medina to a substation way to the west, when the “problem” was increased demand along 694 and Hwy. 55.  DOH!  What’s not to object to!  Here’s what they’d originally proposed:

So after the project was withdrawn, without prejudice (they can re apply), they embarked on a “study” to determine options.  That was so long ago…

For ages, they’ve been saying they’re working on this report, and have been saying “it’s not finalized” (this is NOT rocket science, it’s only engineering and transmission planning and PR spin, what takes so long?  I guess it takes this long to come up with justifications and twist the data to make it look reasonable and needed?).

Compliance Filing_July 2015_20157-112044-01

Compliance Filing_April2016_20164-119743-01

From that April Compliance Filing, here’s their plan for this meeting:

It would help to be able to review the “study.”  So I left a message with Xcel Energy at 612-330-6644, the number provided on the meeting notice (no name, but I presumed Tom Hillstrom is still in charge of this) asking for the study.  Because I got voicemail, I also called the attorney assigned to this:

No “little birdie” here, and something’s fishy — no “study” is forthcoming to study because “it is not finalized yet.”  Sent an email to Plymouth@xcelenergy.com with the same request.  Oh please… it has been YEARS!  Pretty tough to argue for any of your “options” when you don’t have anything to back it up!

My clients are on the Medina end of this, and each project blurb notes that “The existing 69 kV transmission line west of the Hollydale Substation will remain unchanged on all three of these alternatives”

Here’s the three they’re proposing:

View Alternative A Map (PDF)

View Alternative B Map (PDF)

View Alternative C Map (PDF)

Alternative C what looks to be the worst one of the three — to energize the existing 69 kV line through this Plymouth subdivision, much of which is directly over a walkway/bike path:

View Alternative C Map (PDF)

And once more with feeling, Xcel says that “The existing 69 kV transmission line west of the Hollydale Substation will remain unchanged on all three of these alternatives.”  GOOD!  But… will that hold true for the foreseeable future?  What’s the “Long Term Conceptual Plan” on the maps?  That’s why I want to see this study, because past experience with Xcel Energy is that once they propose something, they work it until they get it, one way or another.

From the Xcel “Plymouth Project” site:

The Public Utilities Commission has approved the Public Hearing Notice for the Xcel Energy Rate Case to be included in bills and publicized where ever.  We’ve got some notice to get prepared:

Lo and behold, there’s one scheduled for Red Wing!!  Thanks for small favors…

What are the issues in the rate case?  Check the docket by going HERE TO PUC SEARCH DOCUMENTS PAGE, and search for docket 15-826.

A couple of things you might find interesting, I did, are some of the Direct Testimony filings.

2A2_Multi-Year Rate Plan – Burdick_201511-115332-02

2C2_Xmsn_Benson_201511-115335-03

In addition to whining about the grid being only 55% utilized (ummm, yes, we knew it wasn’t needed, but you went ahead and built it and now want us to pay through the nose, or other orifices, for your transmission for market export?  ppppppbbbbbbft!), here’s the issue — prices have fallen, the market is down, down, down, and we’re conserving, using less, and so now they want us to pay more to make up for it, oh.  Recap:  Xcel Energy wants us to pay for the transmission over our land for their private profit, they want us to pay more because we’re using less, and they want us to make up for their poor business decisions… yeah, great idea.

This rate case and rate increase request is in large part transmission driven.  Xcel wants to move from cost based rates to formula rates, and they want to shift transmission costs from the Construction Work in Progress recovery that was part of the deal leading to the 2005 Ch 97 – Transmission Omnibus Bill from Hell, with transmission perks, CWIP and Transmission Only Companies.

And then there’s the e21 Initiative, Xcel Energy’s effort leading up to the 2015 legislative session, and it seems that with the exception of AARP, only those who signed on to the e21 “Consensus” are allowed to intervene.

e21_Initiative_Phase_I_Report_2014

Great…

Lo and behold, there’s a public hearing scheduled for Red Wing!!  Thanks for small favors…  Mark the hearings on your calendar and show up.  Before hand, do a little reading!

WOW… can you believe??  It’s not just me, it’s not just denial of Intervention of No CapX 2020.  See 20162-118122-01_Denial2_Overland-NoCapX Intervention.

Intervention as a party in this Rate Case is only open to those who sold out to Xcel Energy and it’s “business plan” agenda of e21.

This is the most recent Order in the Xcel Energy Rate Case:

Order Denying Intervention – SunShare & ILSR

Here are their Intervention Petitions:

ILSR_Intervention_20164-120145-01

SunShare_Intervention_20164-120144-01

To see the full Rate Case docket, go to the PUC’s Search Documents page, and search for Docket 15-826.

And the Order… Dig this, parroting Xcel’s objections:

And this, even worse, as if the interests of the “Clean Energy Organizations” who bought into, stumped for, and sat quietly during the legislative hearings about Xcel Energy‘s e21 Initiative are the same as the interests of SunShare and Institute for Local Self-Reliance – ILSR:

This is SO offensive.  There is no consideration that the perspectives are different, only statements that the issues, the concerns, are the same.

The late, great Myer Shark, rate case Intervenor extraordinaire, would spin in his grave at the limitations of participation in this rate case.

Myer Shark, Lawyer Who Fought Utility, Is Dead at 94

In the Matter of the Complaint by Myer Shark, et al …

It’s out, the report from U of M Humphrey School of Public Affairs about CapX 2020, headlining it as a “Model for addressing climate change.“

Transmission Planning and CapX 2020: Building Trust to Build Regional Transmission Systems

Oh, please, this is all about coal, and you know it.  This is all about enabling marketing of electricity.  In fact, Xcel’s Tim Carlsbad testified most honestly that CapX 2020 was not for wind!  That’s because electrical energy isn’t ID’d by generation source, as Jimbo Alders also testified, and under FERC, discrimination in generation sources is not allowed, transmission must serve whatever is there.  And the report early on, p. 4, notes:

Both North and South Dakota have strong wind resources and North Dakota also has low-BTU lignite
coal resources that it wants to continue to use. New high-voltage transmission lines are needed to
support the Dakotas’ ability to export electricity to neighboring states.

See also: ICF-Independent Assessment MISO Benefits

Anyway, here it is, and it’s much like Phyllis Reha’s puff piece promoting CapX 2020 years ago while she was on the Public Utilities Commission, that this is the model other states should use:

MN PUC Commissioner Reha’s Feb 15 2006 presentation promoting CapX 2020

So put on your waders and reading glasses and have at it.

Here’s the word on the 2005 Transmission Omnibus Bill from Hell – Chapter 97 – Revisor of Statutes that gave Xcel and Co. just what they wanted, transmission as a revenue stream:

And note how opposition is addressed, countered by an organization that received how much to promote transmission.  This is SO condescending:

… and opposition discounted because it’s so technical, what with load flow studies, energy consumption trends, how could we possibly understand?  We couldn’t possibly understand… nevermind that the decreased demand we warned of, and which demonstrated lack of need, was the reality that we were entering in 2008.

And remember Steve Rakow’s chart of demand, entered at the very end of the Certificate of Need hearing when demand was at issue???  In addition to NO identification of axis values, the trend he promoted, and which was adopted by the ALJ and Commission, has NOT happened, and instead Xcel is adjusting to the “new normal” and whining that the grid is only 55% utilized in its e21 and rate case filings.  Here’s Steve Rakow’s chart:

Reality peak demand trajectory was lower than Rakow’s “slow growth” line, in fact, it’s the opposite from 2007 to present.  Suffice it to say:

Before, Onalaska’s scenic overlook, gazebo, and “Sunny” the famous Onalaska fish:

After Xcel Energy’s chain saw workout:

What do you think of this clearcutting  for Xcel’s 69 kV line along Hwy. 35 as it goes through the heart of Onalaska, at the Mississippi overlook and “Sunny,” the Onalaska Fish?  Is that butt ugly, or what?

Xcel Energy’s Nancy Dotson and ___________, their engineer (where are my notes?) said the line would be moved to down below Sunny and the observation deck/gazebo, and that they would not clear cut the area.  I was skeptical because if they run the line through, trees come down, that’s the story of transmission.  When trees come down for transmission, it’s permanent impact, because you can’t grow trees under or near transmission lines.  Oh, but no, they said, it’s not going to be that bad.

Well, it is that bad.  It looks like shit.

And Joe Chilsen, the Mayor of Onalaska, knew this would be the result when he went before the La Crosse Board of Zoning Appeal to allow an exemption to the airport height restriction to get this project through.  He signed off on Xcel Energy’s application on January 21, 2016, a month before it went to the La Crosse Board of Zoning Appeal, and about two months before Xcel Energy took their chain saws to the trees.