Donate!!! Yes, you!! See that “PayPal” button up to the right? Join the challenge to transmission that they don’t need and we don’t want! No CapX 2020 has Intervened in the ITC Midwest MN/IA Certificate of Need, a public interest intervention focused on showing up to weigh in on the big picture issues (Important note, No CapX 2020 is aiding public participation, but not taking a position on route.).
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:
And from Dairyland’s site:
Comments are due July 1, 2016 — send to:
USDA’s Dennis Rankin: email@example.com
(I’d also cc DPC’s Chuck Thompson: firstname.lastname@example.org)
By U.S. Mail:
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.
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:
Here are their Intervention Petitions:
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.
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.“
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:
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:
American Transmission Company (ATC) is holding a “Construction Meeting” about the Badger Coulee transmission project on April 14, an open house from 3 to 6 p.m. at the Town of Springfield Town Hall, 6157 County Highway P, Dane County, Wisconsin.
ATC is also holding a round or two of planning meetings, and the next “Customer and Stakeholder” Meeting is planned for April 19, 2016, from 1-3 p.m. at ATC HQ in Pewaukee.
What’s important about this is that in addition to the annual “10 Year Assessment,” they’re also doing “Economic Planning.”
What goes on at these ATC “stakeholder” meetings?
Here are materials for that 2-24-2016 meeting:
Here’s ATC’s Annual Report: ATC releases 2015 Annual Report
They have an entire page on “Economic Planning” and the entire notion of “Economic Planning” goes to the private purpose of transmission, moving bulk power for profit. That’s very different than the regulated utilities’ need to supply their native (captive) load with electricity. The wholesale market was deregulated, electricity is now on economic dispatch, and the basis of electric generation, transmission, distribution, and use, is fundamentally changed. As a society, we’ve not yet grasped this concept, and what it means to us as ratepayers, landowners, and humans.
In light of this, Comments made at a recent Transmission Confab and captured by RTO Insider are enlightening (though note the questioning is from Allohina, a witness and proponent in the CapX 2020 buildout, it’s questionable, because they’ve already got their project!):
Economic benefits have been sketchy at best for some projects, and so grossly overstated as to be hilarious in others, where it’s clear that the benefits go to the generators as decreased production costs:
As above, ATC is hosting another “Customer and Stakeholder” Meeting on April 19, 2016, from 1-3 p.m. The ATC page says it’s at ATC HQ in Pewaukee, WI, but ATC HQ address is not listed on the ATC site, and there are two ATC offices on Ridgeview Parkway, close, but which? Message sent, will report back.
A little birdie just sent this graphic photo.
How’s this for a scenic view overlooking the Mississippi, at the Onalaska scenic overlook, no less?!?!?!
Onalaska, what are you thinking? Did you consider the impact of this transmission line on the City’s observation area? Are you thinking of $$$$? Was there a payment to the City to allow this? Did the City review the plan? Did anyone go out and walk the line? Did the City know this was Xcel’s intent? Did the City’s Planning Commission understand this was in the works as it approved its Comprehensive Plan update that addressed transmission impacts and planning?
La Crosse approved this move and issued a variance under their Airport Overlay Ordinance, and Xcel Energy told me after the meeting that there would not be clear cutting — but you know how Xcel Energy operates.
Worse, Onalaska Mayor Joe Chilsen testified IN FAVOR of La Crosse granting the variance for this project! You might want to tell him what you think of Sunny’s new friend!
Joe Chilsen (2016)
500 10th Avenue North
Onalaska, WI 54650
City: (608) 781-9530
Home: (608) 783-2422
It was such a beautiful day today. Got a good share of garden work in, pulled and raked out the back 40″, well, half of it anyway, and cut down all the big milkweed stalks. We grabbed a sub and went out for a picnic. The river had crested last week or earlier, but it was still very “spring brown” though there were a lot of fishing boats out, and people fishing from shore too.
Next stop, a look at CapX 2020 transmission now that it’s strung. It is so depressing. These are photos just south of us here in Red Wing, north of Rochester, by Oronoco, along the White Bridge Road.
And here’s that “boat landing” that was brought up the last day or so of the hearing, the one that’s now permanently closed and now a locked gate at the road going down to the river:
Before, Onalaska’s scenic overlook, gazebo, and “Sunny” the famous Onalaska fish:
After Xcel Energy’s chain saw workout to “relocate” its 69 kV line away from Hwy. 35:
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.
There’s an editorial by Deb Severson in today’s La Crosse Tribune about the Badger Coulee Transmission Line Circuit Court Decision regarding the PSC’s grant of the permit, and here’s the Decision and Order — check it out:
This decision grants the Town of Holland’s Petition for Consolidation of the two Holland Petitions for Review in La Crosse County (two filed due to procedural weirdnesses of Wisconsin law); denies the PSC’s Motion to Dismiss Holland’s Petition; denies the PSC’s Motion to Consolidate Michael J. Kauper’s Petition for Review into the La Crosse County proceeding allowing it to proceed separately in Dane County; and allows the Town of Holland to amend one of its Petitions. Sort of confusing with all the Petitions and Motions flying around, but bottom line, PSC was not successful in booting these cases out of court.
Tomorrow it’s a meeting or two about a pipeline, but that’s not all… it’s about a gas plant at the beginning of this pipeline route!
First the pipeline — Minnesota Energy Resources Corporation is the applicant, and it’s PUC Docket 15-8858, a docket for a pipeline route on the west and southern edges of Rochester, Minnesota, starting at the “Westside” substation on the west side of town, along the big gas transmission pipeline that runs parallel with Hwy. 14. From there it goes a section west, and then south and around to the east.
And lo and behold, last week, Rochester Public Utilities announced its long planned natural gas generating plant for that same location as this pipeline starts, at 19th St. NW and 60th Ave. N. W. This proposed plant was at issue during the CapX 2020 Transmission Certificate of Need docket, where RPU discussed building a natural gas plant in its RPU_34945_Report_June_2005. Here’s the 2015_update_rpu_infrastructure_study. During the CapX 2020 CoN hearing, that notion was pooh-poohed, but we knew better. And voila, here it is!
First they brought it up at RPU Board meetings over the summer:
And finally, last week, RPU made it’s plans to add new natural gas generation VERY public:
Back in that CapX 2020 Certificate of Need proceeding (PUC Docket 06-1115) it was an issue because the “need” used to justify CapX 2020 transmission to Rochester was so very small that it could be met with this RPU planned natural gas plant. Here’s what I wrote in the 2008 No CapX 2020 Initial Brief:
Most importantly, the need is overstated. In addition to modeling performed with all local generation off line, infrastructure planned was not considered. For example, in Rochester, there are FOUR 161kV lines planned that were not taken into consideration, and which could well serve Rochester’s needs. In addition, RPU, the Rochester utility, has planned for new generation at the West Side substation (Ex. 100, lower left corner), where two of those four lines will be connection to serve Rochester. Ex. 157, Report on the Electric Utility Baseline Strategy for 2005-2030 Electric Infrastructure, June 2005, Summary p. S-21-S-22. Specifically, this report recommends actions that have been taken by RPU, resulting in the Westside Substation and transmission from it to serve the city:
Consider taking options on approximately 100 acres of land within the RPU service territory near a high pressure gas line and transmission facilities under RPU control for installation of future combustion turbine capacity.
…Around 2014, assuming that new generation is required in accordance with the long range plan and that generation has not been installed in connection with the transmission issue, begin the process for installation of approximately 50-100MW of natural gas-fired generation for an inservice date of 2018. The generation should be low capital cost with as low an operating cost as is consistent with expected operating capacity factors.
Local load as a reason for CapX is not supported by the evidence. The need, even if assumed, can be met in other ways, and these small amounts, if assumed in its entirety, cannot justify a project of this size.
And here we are, deja vu all over again. Guess we need to make sure that phased and connected actions are considered in this pipeline environmental review.
And another thing, this pipeline environmental review — the PUC, despite that Sandpiper case, ordered a “comparative environmental analysis.”
Nope, that “environmental review lite” is NOT sufficient…
Remember Xcel’s CapX 2020 peak demand projections of 2.49% annual increase? How wrong can they be? And how unjustified was their basis for a Certificate of Need for CapX 2020? And how are they held accountable for those gross misrepresentations? But now it’s time to pay, and who will pay? This is why the rate case in progress, PUC Docket 15-826, is so important.
On the other hand, I love it when this happens… Xcel Peak Demand is again DOWN! There’s a trend, and it’s called decreased demand. Demand has yet to exceed the 2007 peak, and now it’s 8 years…
Here’s the Xcel Energy SEC 10-K filed a couple days ago:
Is it any wonder they want to get away from a cost based rate a la their “e21 Initiative” scheme? Particularly now that the bill for CapX 2020 is coming due and their newest rate case (PUC Docket GR-15-826) is now underway?
And the specifics, and note how they inexplicably forecast a 2016 peak of 9,327, which is based on a “normal weather conditions” assumption: