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.).
The Town of Holland has challenged the Wisconsin Public Service Commission’s Badger-Coulee transmission project decision, where they issued a Final Order 05-ce-142 and permit for this transmission line.
1:45 p.m. on Monday, October 10, 2016
Town of Holland — Circuit Court Hearing
La Crosse Circuit Court
Branch 3 – Courthouse & Law Enforcement Center
333 Vine Street
La Crosse, WI
Here are the Town of Holland’s Briefs and PSC and utility responses:
Holland Initial Brief June 20, 2016 Court File: 15-cv-219
Lots to read to be able to make informed comments… so let’s get to it!
CapX 2020 at Highway 61 south of Wabasha
Monday, they had their CapX 2020 Love Fest at the Hampton substation, and I didn’t even get an engraved invitation. It’s a depressing point in time — 12 years on this project — and they got all they wanted, in some places not where they wanted it, but it’s up, and so many people affected. Having it routed somewhere, anywhere, is what they cared about, and supposedly it’s now “in-service,” though I wonder. Is it time to have a big bonfire of all the boxes of files?
This was about the Minnesota portions, but South Dakota, North Dakota, and Wisconsin is permitted as well, the superhighway from the coal fields of the Dakotas to Madison and beyond. Yeah, I could have camped out and crashed the party, but I had another commitment, so couldn’t spend the day hanging out waiting, watching. Maybe I should have…
Left-to-right: Mark Kotschevar, Rochester Public Utilities; Dave Geschwind, Southern MN Municipal Power Agency; Teresa Mogensen, Xcel Energy; Chris Kunkle, Wind on the Wires; Ben Porath, Dairyland Power Cooperative; Priti Patel, MISO; Tim Noeldner, WPPI Energy. From CapX Press Release
How much was “Wind on the Wires” (f/k/a Izaak Walton League) (and many other orgs?) paid for their promotion of transmission?
In the press:
STrib (is it really $2.1 billion? Any recent reports?):
From WKBT (video here):
And Wisconsin Public Radio:
It’s up and running — get out those gauss meters and check it out.
CapX 2020 at Hwy. 61 looking towards the Mississippi
The CapX 2020 project has been a part of my life for over 12 years… and now it’s mostly up and running. So I’ve spent the day digging through the dusty files. What a mess. Boxes and boxes and boxes.
That’s a map from 2007 or so with coal plants ID’d from the MISO queue, some up and running, many not (good!). The north/south line along the MN and ND/SD border is missing. The North Dakota, South Dakota and Wisconsin legs are all permitted too, much constructed. Well played, Xcel.
During the Certificate of Need proceeding, we were not able to address the bulk power transfer aspect of this, because after all, “it terminates in Wisconsin.”
Meanwhile, Xcel Energy’s rate case based on its e21 Initiative whines that the grid is only 55% utilized!
You’re not going to be efficient if you’re reliant on massive transmission lines, DOH! Oh well, we knew all this, and yet here we are, billions of dollars of “wires in the air” and the bills just now arriving. Xcel argued that No CapX 2020 should be excluded:
But CapX 2020’s Minnesota Brookings – Hampton transmission line is part of MISO’s MVP 17 project portfolio! DOH! And the judge apparently missed that Xcel brought up both CapX 2020 cost recovery and MISO MVP cost recovery in their direct testimony!
Oh, but it doesn’t end there…
No CapX 2020 was not allowed to intervene in the rate case and address transmission recovery, after all, the permits have been granted, so WHY DOES NO CAPX EVEN EXIST?!?!? So said the judge:
Remember their shindig on Tuesday:
September 26, 2016
Time? They’re not telling…
Highway 52 and 215th Street (N. of Hwy. 50)
CapX 2020/Xcel Energy is holding a PR shindig, firing up the Hampton – La Crosse leg of its transmission build-out. Their scheme, their scam, is nothing to celebrate. But yes, there’s an event coming up… and it should be appropriately observed… where did I put that “No CapX 2020” banner?
September 26, 2016
Time? They’re not telling…
Highway 52 and 215th Street (N. of Hwy. 50)
This project has been 12 years of my life… first got wind of it in 2004 at a MAPP NM-SPG meeting, though really, it was apparent with the release of the WIREs-WRAO Report from 1998. That was 18 years ago. Transmission is not rocket science! As we say, “It’s all connected!” Oh, but wait… for the purposes of the Minnesota Certificate of Need proceeding, we couldn’t connected all the dots, and the CapX folks insisted that it only went to La Crosse!!! Oh, please…
Anyway, the planed shindig was reported in the Rochester Post Bulletin:
Have messages in to both Tim Carlsbad and Grant Stevenson, but the timing is top secret, no invitation is forthcoming, so I guess I’ll just have to crash. Tom Hillstrom quit, went to Met Council, and is now back with Xcel as contractor, is he in on this? Better check with “Hilly” too!
Where’s the Hampton substation? As you approach from the south on Hwy. 52, north of Hwy. 50, there’s this ugly Corten steel “Gateway to the Metro” of transmission towers, with the Hampton on the west side, at 215th Street — can’t miss it:
Next week, the Xcel Energy rate case public hearings are in St. Cloud and Red Wing, both in areas hard hit by CapX 2020. Southern Minnesota was also hit with the ITC MN/IA project, which is the northern part of MVP 3, and the Badger-Coulee line from La Crosse to Madison was the northern part of MVP 5. Xcel ratepayers will be hit with a portion of the full MISO MVP 17 project portfolio.
This rate case is driven by Xcel’s desire to recover costs of transmission, that is openly admitted by Xcel Energy, and transmission cost shifting is a part of Xcel’s request. What about the MISO MVP portfolio and what we’re going to pay for that under the FERC approved MISO tariff?
For some odd reason (e21_Initiative “consensus”) the “environmental” and “policy” groups that work hard on turnout for hearings are absent… I guess abdicating on the rate case is part of the consensus, eh? Very few people are turning out for these hearings. And without a strong public outcry, what will happen?
Show up at the hearings! To file written comments, eFile them in PUC docket 15-826 or….
And you should also know that two PUC Commissioners were fundamental in pulling that e21_Initiative and e21 “consensus” together, Matt Schuerger and Nancy Lange. From Mike Bull, who reports on how it began:
So I reached out from Xcel to Rolf Nordstrom at the Great Plains Institute and Nancy Lange then at CEE (now a Minnesota PUC commissioner), to start putting the e21 project together. Rolf and I worked to put a strong core project team together – CEE, Great Plains, Xcel Energy, Minnesota Power, George Washington University Law School and consultant Matt Schuerger.
Again, this rate case is transmission driven. At issue in this rate case are considerations of what costs will be foisted on ratepayers, i.e., should Minnesota ratepayers have to pay for transmission THROUGH Minnesota, to points elsewhere, should Xcel ratepayers pay for transmission THROUGH Xcel territory to other service areas, should Xcel ratepayers pay for transmission for market access, for market transactions, which is a private purpose not having anything to do with serving Xcel customers. And Xcel is specifically asking that transmission cost recovery be shifted from current Construction Work in Progress (CWIP) and AFUDC. Those of you affected by CapX 2020 know the price you’ve already paid, and this rate case is adding insult to injury.
CapX 2020 is specifically named in testimony in this docket, for example, in Ian R. Benson’s testimony, n p. 8, 14-15, 17, 23-30, 39, 55-60, and discussed thoroughly throughout:
And from the Application, these two snippets, and note that the Brookings and Fargo projects are key “Minnesota pass-through” transmission lines — and why these and not the Bemidji-Grand Rapids and/or the Hampton-La Crosse lines?
Here’s the gory details of Lange and Schuerger’s involvement (from e21_MikeBull_Center for Energy and Environment) — as noted above. Schuerger was a conslutant on this, so his involvement is even more damning…
The e21 Initiative started as little more than a glimmer in my eye a couple of years ago, when I was a Manager of Policy and Strategy for Xcel Energy. I’d just come back from a meeting at the Edison Electric Institute about the impact of various dynamics – low load growth, increasing infrastructure investments, deeper penetrations of distributed resources – on the current utility business model. In general, rates were going to rise under the current model far faster as a result of those forces, and utility revenues become more uncertain.
Those dynamics were later chronicled in the Disruptive Challenges report issued by the Edison Electric Institute in January 2013. I realized that it was important for Xcel to try and get out ahead of the curve.
So I reached out from Xcel to Rolf Nordstrom at the Great Plains Institute and Nancy Lange then at CEE (now a Minnesota PUC commissioner), to start putting the e21 project together. Rolf and I worked to put a strong core project team together – CEE, Great Plains, Xcel Energy, Minnesota Power, George Washington University Law School and consultant Matt Schuerger. We then compiled a terrific group of stakeholders who together represent much of what constitutes the public interest – low income customer advocates, small and large business representatives, utilities, environmental organization, cities and other public entities, and regulators. Beginning last February, this group of 25-30 stakeholders met monthly for day-long sessions that were wonderfully facilitated by Rolf and Jennifer Christenson, his colleague at GPI, toiling together deep in the weeds of utility regulation.
It was an honor to work with all of them, as we coalesced around the set of consensus recommendations detailed in the report.
And what about the limited interventions in this matter, regular intervenors being tossed out:
That second denial of Intervention is a little over the top!
Further, the Petition states that purposes for which No CapX 2020 was “specifically formed”22 was to participate in dockets which are now closed, raising the question of why No CapX 2020 continues to exist.
In the Certificate of Need CapX proceeding, we were repeatedly told that rate recovery for the transmission projects were only an issue for a rate case, and as above, in the rate case, CapX 2020 is specifically named in testimony in this docket, for example, in Ian R. Benson’s testimony, n p. 8, 14-15, 17, 23-30, 39, 55-60, and discussed thoroughly throughout:
… sigh… and I can’t find that any party has filed testimony regarding CapX 2020 and the MISO MVP 17 project portfolio other than Xcel!!! But maybe that’s also a part of the e21 consensus, eh?
And here are the Comments I filed on behalf of No CapX 2020:
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!
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:Dennis Rankin Environmental Protection Specialist USDA Rural Utilities Service 1400 Independence Avenue S.W. Mailstop 1571, Room 2242 Washington, DC 20250-1571
In today’s La Crosse Tribune! This is about as detailed an article as there is in today’s news — thanks for the digging, Chris Hubbuch:
Dairyland Power Cooperative has completed an environmental study of its planned replacement of a high-voltage power line that runs through densely developed areas between Holmen and La Crosse.
Originally constructed in 1950 through farmland, the 161-kilovolt line known as Q-1D South now cuts through back yards and in some cases directly over homes that were built around and under the line as development pushed north along the Hwy. 35 and later Hwy. 53 corridors.
In an environmental assessment filed with the U.S. Department of Agriculture, the La Crosse-based utility argues the line has become unreliable — it’s blamed for two sustained and five momentary outages between 2009 and 2014 — and is critical to serving La Crosse.
Dairyland plans to replace the existing H-frame wood structures with 95- to 115-foot steel poles and a larger conductor that will be capable of carrying more electricity.
The rebuilt line would cross as many as 14 dwellings that were constructed underneath the existing line. There are 42 dwellings and four businesses within the 80-foot right of way.
Despite the concerns of residents who fear negative health and safety impacts from the high-capacity lines, Dairyland argues that alternative routes would be too costly and problematic, and that state codes prohibiting the construction of high-voltage lines over dwellings don’t apply to its rebuild plans.
“In this case on our existing right of way we’re exempt,” said Chuck Thompson, who is in charge of siting and regulation for Dairyland. “We can stay over those structures.”
The nine-mile segment is part of Dairyland’s 70-mile Q-1 line, which connects its coal-fired generators in Alma and Genoa to La Crosse. Dairyland has rebuilt the other segments during the past decade.
Dairyland plans to begin reconstruction of the final segment in September and have the new line electrified in early 2017. It’s expected to cost about $11.9 million.
The project has generated strong opposition from residents who live along the line. Dairyland received 45 public comments when the plans were revealed last summer.
Ann Kathan and her family live in homes built within the right-of-way and have led the charge against the project. She argues the lines expose residents to harmful electronic and magnetic fields, which she fears will be worse with the new conductors.
Kathan also contends that with coal-fired generators making up nearly 90 percent of Dairyland’s generation assets, the company’s long-term viability may be shaky.
“Why would our community support the building of a line that will far outlive us when Dairyland will not?” she asks.
Thompson said the rebuilt line should have lower EMF readings “under normal load” but concedes the new conductors will be capable of carrying more electricity, which would increase EMF.
Dairyland minimizes the health risks of EMF.
“Epidemiological and toxicological studies have shown no statistically significant association or weak associations between EMF exposure and health risks,” the company wrote in its environmental assessment. “While the general consensus is that EFs pose no risk to humans, the question of whether exposure to MFs can cause biological responses or health effects continues to be debated.”
Residents along the line have called on Dairyland to consider an alternate route, but Dairyland argues that is impractical.
The company decided against using one of its own 69-kv routes, arguing that would cost more than twice as much money, create new conflicts with residences and businesses, and result in an additional 17 structures exceeding airport height restrictions.
Dairyland also ruled out using nearby Xcel Energy towers because running lines on the same poles would increase the chances of both going down at the same time and because the cooperative might be forced to buy out residences under the Xcel route.
Burying the line would cost more than $100 million, according to Dairyland’s estimates.
Dairyland also notes that rerouting its line would require permission from the state’s Public Service Commission, which could take up to five years and add to the project costs.
Carol Overland, a Minnesota attorney who fought against two recent high-voltage transmission projects — CapX2020 and Badger-Coulee — says Dairyland is offering conflicting readings of the law in order to “have it both ways,” saying it is exempt from PSC regulations in some cases but subject to them in others.
“It’s questionable,” she said. “(But) who’s going to question it?”
She also contends Dairyland broke the Q1 project into segments — in violation of the National Environmental Protection Act — in order to avoid having to do a more in-depth environmental impact study.
Because Dairyland is replacing an existing line, the utility does not need state or federal approval for the project.
But in order to receive low-interest financing through the USDA, Dairyland must submit an application to the Rural Utilities Service, which requires the environmental assessment. Public comments on that document are being accepted through Wednesday.
The only other hurdle for the project is height restrictions around the La Crosse Regional Airport.
The existing ordinance limits the height of structures within three miles of the airport using a grid of 40- to 160-acre squares that climb like steps away from the runways. An aeronautical study is required for any proposed structure that would exceed that limit.
With more detailed geographical data provided by Dairyland, the new ordinance establishes higher height limits in a contour pattern — more like a ramp.
Airport Director Clinton Torp said the new height restrictions more accurately follow FAA guidelines and will cut down on the number of permits and variances the city must consider for structures that exceed the height limit.
Under the new ordinance, Dairyland estimates it will need variances for only three — rather than 24 — of its towers.
Torp said once the city incorporates Dairyland’s data into its GIS system, landowners and developers will be able to use an online map to see the exact height limit for any spot within the airport zoning district.
A committee of the La Crosse Common Council is scheduled to consider the ordinance change July 5.
Kathan said Dairyland has used its financial power to “side step” local ordinances.
“How is it fair to the people of the city of La Crosse that the people with the most money and political influence don’t have to comply with the laws. It changes the rules,” she said. “Shouldn’t Dairyland have to demonstrate a need and balance that against the public safety purpose of the ordinance?”
And a prior article on the Dairyland Q-1 D South line:
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: