Legalectric

And yet another year where Xcel, errrrrr, NSP, had a lackluster peak demand.  That’s a good thing, verification that we can get along with a lot less coal and nuclear.  And it’s also good as proof that of those Certificates of Need, based on their bogus “modeling” predicting 2.49% annual increase, we could jettison how many of those projects?  How much infrastructure was built that clearly wasn’t needed, at least by their justifications? Billions, right?  How much will ratepayers be refunded given all these unnecessary projects based on bogus projections?

Here are the details:

And looking at it another way:

Here’s the primary doc — Xcel’s 2018 10-K, just search for “peak demand” and there it is:

Xcel 2018_10-K

So now can we get all that unneeded transmission yanked up and hauled to the salvage yard?

There’s been a lot of speculation about the low wind production during the low-low temps at the end of January.  Turns out there’s an issue not anticipated by MISO that they’re going to have to deal with.  I heard it first from a little birdie who heard it while in a flock…

And now from a bigger birdie with primary info from the horse itself: Turbines apparently have a -22F degree or so automatic shutoff, so when it was way cold, they shut off.

Unidentified temperature cutoff thresholds challenged
wind forecasting in morning of Jan 30. Unexpected
shutoffs led to a large deviation from planned output.

Ummmmm, that’s a problem.  Here’s the MISO update on that:

20190207 MSC Item 04 Jan 30 Max Gen Event317407

And from my “good friends” at Center of the American Experiment, who got it twisted again:

Bitter Cold Shows Reliable Energy Sources Are Critical

Twisted?  What’s wrong with that?  Well, their focus is that it was an intermittency issue, which it was not.  As above, it was that shut-off at -22!  And note the part in their post about “unforeseen.”  And THAT is the problem, because the -22 cut-off was not integrated into the MISO modeling, plans, and that was a surprise, and they’re going to have to figure that one out.  It’s possible, probable, and now apparently likely that we will have another -22 degree spell in the foreseeable future.  So get with it, MISO!

And natural gas.  I keep thinking about that CenterPoint natural gas underground storage dome.  7 billion cubic feet at least.  There’s a lot of gas in storage.  Are they relying on pipelines, and does that reliance take into account the many newer natural gas plants?  Does Xcel share/buy from CenterPoint, take advantage of the storage?  What is the impact of so many electric generators fueled by natural gas?  They did recently do a lot of natural gas pipeline work on that primary north/south line running north from Waseca, was that a capacity expansion… upgrades or maintenance ??

Read the STrib today?  Xcel has 9,500 record peak.

Xcel, how dare you… the 9,500MW peak you report is exaggerated… naughty, naughty.  You didn’t deduct for the interruptible service customers’ megawatts, and you’re including electricity you’ve generated and sold elsewhere, that the number represents the totals Xcel put on the grid, and not accounting for the demand that they’ve shed, not wholesale sales in other markets. THIS IS NOT PEAK DEMAND!!!  YOU’RE CHEATING, XCEL… sigh… what’s new…

Thanks for clearing that up, little birdie!

But even considering that sleight of hand, it’s no record, it’s not even up to the 2006 peak… and that was FIVE years ago.  Your CapX 2020 transmission is predicated on 2.43% (is that right, 2.4 something…) increase annually, but folks, we’re not even close to that.

Here’s the peak demand over the last 10 years:

And here’s what the STrib said today, what they said that Xcel said, blah blah blah, 9,500 my ass:

There’s a problem with not having a dog in the fight, and that is that I’ve not been tracking what’s going on in the Hiawatha Project Certificate of Need docket, or more correctly, what’s NOT going on.  OH MY!  Look what I just learned!

THE COMMENT PERIOD ON “NEED” ENDED 3/31/2011!!!

Yup, really, here’s the notice:

PUC’s Notice of Comment Period

That was sent out in early March, setting the deadline for Initial Comments as March 31, 2011, and Reply Comments for April 29, 2011.

This Certificate of Need is going through the “informal process,” something arbitrary set up by the PUC and MOES, with no rules, and oh, it is going weirdly.  Here’s the PUC Order authorizing the “informal process” that was issued in February:

Order of PUC establishing “informal process”

Let me see if I understand this.  The Environmental Report is not done, in fact it’s not yet begun, the Scoping Comments were due yesterday, April 6, 2011.   And the notice for the Scoping of the Environmental Report notes that there will be a public hearing on need, as required by the statute and rules, after the Environmental Report is released.

… but the initial Comment period is closed, the Reply comment period ends April 29, 2011, and all of that will be over before the Environmental Report is done and before the “Public Hearing.”  HUH?  This makes no sense.

Worse, the only party to file comments by the March 31, 2011 deadline was MOES!  There were how many intervenors in the Routing docket, and they raised such a stink about the need for a Certificate of Need proceeding that they rammed through a bill requiring it, and now that it’s begun (and now that their $90k was line-item vetoed by Pawlenty) they are all absent, not a one has bothered to show up and submit a single Comment.  Give me a break!  What does it take to put a comment in?  And not one… and a few have submitted letters saying they won’t be intervening, notably the large funded intervenors:

Letter from Hennepin County, City of Minneapolis and Midtown Greenway Coalition, stating they have no intention of intervening

…sigh… gee, I wonder why they’re not intervening…

Anyway, here’s what MOES has to say, and remember this is the beginning, not nearly the end:

MOES – Comments and Recommendation

So once again, let me see if I understand this.  MOES has submitted Initial Comments recommending that this Certificate of Need be approved, and is basing that on the Application, and to support that Recommendation, using demand data from 2006, and using the Chisago Project record from 2007 as the basis for saying that a determination regarding undergrounding should be made in the routing docket.  Really, that’s what it says, PLEASE read it!

MOES, CAN YOU SPELL “PREMATURE?”

Look what Xcel filed on January 6th, 2011, as a “Supplemental Filing” replacing their “Appendix B, Figure 7, Monthly Demand and Capability” chart (click to enlarge):

Compare that “Net Peak Demand” with the original chart — there’s a LOT more capability than demand… but hey, we knew that:

So can you believe this MOES Recommendation to grant the Certificate of Need?  Where are my waders…

MOES clearly has not taken this chart into account showing a 10-15% decrease in demand.  Plus MOES is not taking into account any Comments because theirs were filed on the first deadline!  They’re taking everything Xcel says in its application and presuming it’s fact!  Even the 55MW need claim based on 2006 data.  HELLO?!?!

A Recommendation should come at the end of the process, not the beginning.  DUH!

Well, here we go… Reply Comments due April 29, 2011.

Duck and cover!

.

Comments for the scope of Environmental Review for Xcel’s Hiawatha Transmission Project through the Phillips neighborhood of Minneapolis are due TODAY at 4:30 p.m.  These Comments must address the “scope” of issues to be addressed in the Environmental Report – not that you don’t like it (who would?) but raise all the issues, each and every one, each subtle variation and nuance, of the things they need to consider.   Because this is a Certificate of Need docket, they need to include things like “consider system alternative of an upgrade of the distribution system” and “consider system alternative of solar panels on large buildings in area to follow peak” and so forth.  TELL THEM TO INCORPORATE THE HIAWATHA PROJECT ROUTING DOCKET DEIS AND EIS INTO THE ENVIRONMENTAL REPORT. Be painstakingly specific.  Send Scoping Comments by 4:30 p.m. today, be sure to label as “Scoping Comments for Hiawatha Project” and put the docket number on it, “Docket 10-694.”   If you’re so inclined, file them on eDockets at the PUC.

SEND SCOPING COMMENTS TO: bill.storm@state.mn.us

AS “SUBJECT” STATE “HIAWATHA SCOPING COMMENTS – 10-694” SO THEY WON’T GET LOST

Why does this matter?  Because so far they’ve gotten away with claims that this transmission project is “needed” to address a distribution system problem.  The Certificate of Need docket is where we can demonstrate it’s not needed.  This “Environmental Report” is a part of that.  And these “Scoping Comments” are the only public input into an “Environmental Report,” because unlike a Draft Environmental Impact Statement,” there will be no public comments on its adequacy, what’s included, what’s missing, that doesn’t happen with an Environmental Report.”  And that’s a problem.  Someone needs to enter the DEIS and the FEIS from the Hiawatha routing docket (PUC Docket 09-38) into the record as a Scoping Comment and the entire DEIS and FEIS need to be incorporated into the environmental report.

Here’s an important example.  Remember the furor over the “high” magnetic field levels in the Routing Docket, and that the ALJ recommended it be underground?  Well, those levels are not even close to what those lines could produce. Forever, I’ve been saying, commenting, testifying in the routing docket that the magnetic field levels for the Hiawatha Project are a lot higher than they are claiming(click to enlarge) and nobody cared… sigh…  Here’s what they claim:

And sure enough, if you take the conductors specified, the potential levels are a LOT higher than they disclose.  Here’s a chart of calculated magnetic fields for Route Options A, B and C (click to enlarge):

This chart is from a Scoping Comment Affidavit just filed: by Bruce McKay, the same engineer who filed a similar Affidavit in the CapX Brookings remand that got the Applicants to admit to those levels, which acknowledges the accuracy of McKay’s Affidavit and calculations, in Darren Lahr’s testimony in the Fargo-St. Cloud case.  Well DUH!

So to get some accuracy going here, Bruce McKay filed a Scoping Comment with the above chart:

McKay Scoping Comment Affidavit- Hiawatha Project

Again, Scoping Comments are due at 4:30 p.m. today.  Send “Scoping Comments, Hiawatha Project 10-694” to:

bill.storm@state.mn.us