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.).
Today, the Minnesota Public Utilities Commission approved the Certificate of Need and the Route Permit for the ITC Midwest transmission project. The good news is that the route was modified and isn’t going to run right through the city of Sherburn, but the Commission did not direct ITC to remove the transmission lines from Fox Lake and Lake Charlotte and double circuit that line with the ITC project.
The ITC Midwest MN/IA 345 kV project is the pink highlighted part of the map above, and as you can see, it’s all connected. This project enables connection of the Dakotas transmisison into the Split Rock – Lakefield Jct. line to Madison, via existing transmission and MVP projects 3, 4 and 5. Not to mention all the other MVP projects — this is a BIG web of transmission:
Commissioner Boyd, acting as Chair in the absence of Chair Heydinger, did acknowledge the importance of addressing the macro picture of cost apportionment of this group of projects to Minnesota, that we have this specific project to address, but we do have to deal with this larger cost issue, but in a different venue. That validation helps, but when are we going to deal with it and how? The FERC docket has long since passed, what position did Commission take during that MVP tariff and cost apportionment review? It’s a bit late, because they’ve decided and now Minnesota has to live with it… or do we? What options are there?
The thing that concerns me the most is that the Commission adopted the ALJ’s Findings without discussion of the meaning and impact of the de facto declaration that ITC Midwest is a “public service corporation.” I’d asked that the “public service corporation” portion of Finding of Fact #1 be deleted:
Also, I’d asked that Chair Boyd recuse himself due to his having been Co-Chair of UMTDI, cited again today by ITC Midwest as a foundational part of development of the MVP projects:
Upper Midwest Transmission Development Initiative
Commissioner Boyd was gracious about not recusing, went over his involvement with UMTDI over the years, and noted that raising this was legitimate, I think he said “the right thing” or some such. But he didn’t recuse.
I’d also asked Commissioner Lange to recuse herself, due to her long time employment with Izaak Walton League, intervenors in SUPPORT of this project, and all their transmission promotion and advocacy agreements and funding. She said that she’d discussed it with PUC counsel during the break and they decided that her involvement with the Waltons did not rise to the level requiring recusal. At least she talked about it, but given her position, and that of Bill Grant, her former boss at the Waltons who is now the Commerce Deputy Commissioner in charge of Energy, that’s pretty much cornering the market, and an issue that the Commission should tackle directly.
Oh well… waiting for the written order to come out, and it will probably be soon because there wasn’t much at issue.
And I should mention that Jeff Small, attorney for MISO, was not at all happy with my statements about the hearing and my characterization of MISO witness Chaterjee’s testimony, saying I’d misrepresented it. To the extent that I said that I’d been able to ask “only 3 questions,” he’s technically right in that I was allowed to ask questions in three AREAS, and to which he objected to at the time, and I was able to ask a grand total of 8 questions, one of which was in response to a request for clarification by the witness, so really SEVEN questions. The issue is unreasonable limitation of questioning, and the importance of the testimony elicited, limited as it was. Small, however, believes I misrepresented Chatterjee’s testimony before the Commission, and the number of questions. In my statements to the Commission, I asked them to refer to the transcript for the specifics, knowing that it was a representation and not a direct quote. I’d copied the transcript at the library, cited it in our brief, and here is the ENTIRE session of question and answer, all 7 or 8 questions, depending on how you count, and Chatterjee’s response. This was one of the most dreadful dockets I’ve participated in, between the limitations as a “limited’ Intervenor, the “Clean Energy Intervenors” advocacy for the project, and this was it for cross-examination — an Evidentiary Hearing short circuited and essentially tried on the pleadings, despite a last second change in position of Commerce-DER. Check the transcript for questions to Dr. Rakow regarding is last minute change of position. The public interest was pushed out of the mix, oh-so-relevant questions were not asked, and important issues were not reviewed. Where the ALJ does a verbatim cut & paste of the Applicant’s proposed Findings of Fact, that is NOT thoughtful consideration, no way, no how.
Misrepresentations, Mr. Small? Readers, you be the judge. Here’s a copy of the testimony at issue, the FULL cross-examination. Note the part in red:
12 JUDGE LAFAVE: Ms. Overland.
13 MS. OVERLAND: Thank you.
15 BY MS. OVERLAND:
16 Q Good afternoon, Mr. Chatterjee.
17 A Good afternoon.
18 Q My questions are pretty narrow in scope and it
19 relates to your introductory comments this morning,
20 or this afternoon.
21 MR. SMALL: Your Honor, before we get too
22 far, the introductory statement is not one of the
23 three items that Ms. Overland said that her
24 cross-examination would deal with.
25 MS. OVERLAND: Your Honor, I wrote them
1 as he was making them, and they’re highlighted in
2 red right here, and those are the three. They were
3 related to statements that he made. I can repeat
4 them, if you would like?
5 JUDGE LAFAVE: Please. What were the
7 MS. OVERLAND: The three were first the
8 need to protect against 345 kV contingency. Second
9 was have any of the MVP projects been disapproved.
10 And third was the MISO planning process regarding
11 transfer capability, needs to consider what capacity
12 transfer, why, and how much.
13 Those were the three that I laid out.
14 JUDGE LAFAVE: Please proceed.
15 MS. OVERLAND: Thank you.
16 BY MS. OVERLAND:
17 Q Okay. First, I’d like some clarification about you
18 were discussing SPSs and why it would have to be
19 reconfigured if the 161 were used. And you stated
20 that there was a need to reconfigure to protect
21 against 345 contingency. Does that mean a fault of
22 the 345 system?
23 A It could mean a number of things, but basically
24 referring to an outage of any of the 345 kV sections
25 that the SPS is protecting against.
1 Q Thank you. That’s what I needed to know there.
2 And you were asked whether any of the MVP
3 projects have been disapproved.
4 Do you know how many MVP projects have
5 been approved at this point?
6 A So the MVP project, the thumb loop in Michigan did
7 receive approval in Michigan. The Illinois project
8 in Illinois, ATXI project, did receive approval.
9 Those are the two. Oh, and Brookings to Twin Cities
10 project also did receive approval in this Commission
11 here. Other than that, I’m not aware of any other
12 MVPs at this point that have received approval.
13 Q And are you aware if the Brookings project received
14 approval by this Commission — first, are you aware
15 that our Commission here in our state laws divide
16 siting and routing and need determinations? Are you
17 aware of that?
18 A Yes, I am.
19 Q Okay. Well, was the certificate of need for the
20 Brookings project approved before or after there was
21 such a thing as an MVP project?
22 A So I believe the Brookings project was an Appendix B
23 project at the time that it received approval.
24 Appendix B refers to an MTEP appendix, which refers
25 to projects that are under evaluation in a MISO
1 planning process. So, yes, I believe the Brookings
2 project was approved prior to the approval of
3 Brookings by MISO or the directors when it moved
4 from Appendix B to Appendix A.
5 Q So then at the time that it was approved, it did not
6 have MVP status; is that correct?
7 A That’s right, because the MVP status is given only
8 after the project is approved as an MVP, which is an
9 MTEP line.
10 Q Thank you.
11 You were also asked questions about costs
12 per megawatt of transfer capability and how the
13 planning process works. And you stated that the
14 planning process needs to consider what capacity or
15 transfer and why and how much. Is it possible to
16 make a short little statement about — well, in this
17 case, what capacity you’re transferring, why, and
18 how much?
19 A In what context?
20 Q In the context of MVP 3.
21 A Sure. So different transferring analyses that MISO
22 performs and different planning processes have
23 different context, right. That’s why transfer
24 capability is important. Because you’re
25 transferring power from A to B. What are you
1 transferring, why are you transferring, how much is
2 the quantity that is good enough? Is the transfer
3 capability of 2,000 megawatts good enough, or 5,000
4 or 6,000? Where do you stop?
5 So as pointed out in my direct testimony,
6 the transfer analysis that MISO did run is run in a
7 different planning context, but is impacted by
8 MVP 3, and that is in the context of capacity export
9 limits and import limits. As you know, in MISO’s
10 resource adequacy auction, local resource zone one,
11 which is where Minnesota is located, was limited by
12 transmission and therefore had a capacity export
13 limit, a very small capacity export limit, in the
14 range of 200 to 300 megawatts.
15 That was significantly mitigated by the
16 Mid-MISO MVP and the out-year analysis MISO
17 identified an increase as stated in my direct
18 testimony of over 2,000 megawatts of transfer
19 capability. Again, that is important because that
20 is a transfer capability analysis where an objective
21 function is defined. You’re trying to move capacity
22 resources or, capital P, capital R, planning
23 resources. These are baseload units that you’re
24 moving from local resource zone one for utilization
25 in all of the other MISO local resource zones for
1 every load to meet their local — to meet their
2 planning reserve margin requirement.
3 So you know how much you need and you
4 know what you’re transferring, you’re transferring
5 capacity resources, baseload units, and wind also,
6 but wind has a very small capacity credit value.
7 And we identified a significant benefit there. So
8 that is an important context.
9 In the context of MVP analysis where
10 you’re transferring renewables, you’re looking at an
11 off-peak scenario, which is, in the 8,760 hour
12 simulation you’re looking at the big bulk, the
13 majority of the time you’re actually transferring
14 low cost generation. And that kind of transfer
15 analysis, if you could do 8,760 transfer capability
16 analyses with 8,760 snapshot simulations, that is
17 very good, if you can actually estimate based on
18 your price of your generation and price of your load
19 where are you transferring how much, as we all know,
20 it’s impractical to do that.
21 And that’s why MISO uses PROMOD analysis,
22 which is a production cost modeling with a
23 transmission system in it where real-time LMPs are a
24 consequence of generation prices and load prices.
25 And that is the PROMOD study in the MVP analysis.
1 Q And then to clarify, the PROMOD studies are strictly
2 an economic analysis?
3 A When you say economic analysis, it can be construed
4 as, well, it ignores reliability constraints, so
5 that is not the case because a PROMOD analysis
6 respects all the transmission limitations that are
7 modeled in the case as well. So — and that is how
8 it values congestion. Because when it sees that
9 you’ve gone over transmission limits, it will do an
10 efficient redispatch around that just as the market
11 would and it would curtail transfers or have a
12 negative impact on the most efficient set of units.
13 And, therefore, when you mitigate that transmission
14 constraint through a transmission project, you would
15 see a savings in your adjustment production cost.
16 MS. OVERLAND: I think that answers it
17 really well.
18 Thank you. That’s all I have.
19 THE WITNESS: Thank you.
20 JUDGE LAFAVE: Thank you very much.
21 Ms. Anderson?
22 MS. ANDERSON: Nothing further. Thank
24 JUDGE LAFAVE: Ms. Currie?
25 MS. CURRIE: No questions.
1 JUDGE LAFAVE: Mr. Small?
2 MR. SMALL: Yes, Your Honor, I have maybe
3 a couple of questions for Mr. Chatterjee.
4 FURTHER DIRECT EXAMINATION
5 BY MR. SMALL:
6 Q In your response to Ms. Overland’s questions about
7 the approval of MVP projects, you mentioned a few
8 examples of projects that were at various stages of
9 development; is that correct?
10 A That is correct.
11 Q And you mentioned one in particular, which was the
12 Illinois Rivers Project. Do you remember that?
13 A Yes, I do.
14 Q And is the Illinois Rivers Project a single MVP?
15 A No, it’s not. It’s — it is comprised of different
16 MVPs, I forget, but it goes from Palmyra to
17 Meredosia to Pawnee to Pana, from Pana to Sugar
18 Creek. I believe it was broken down into two maybe
19 three separate MVPs.
20 Q And that description of the number of MVPs, can that
21 be found in the MVP study that was entered into the
22 record today?
23 A It can be.
24 Q Okay. So your description was not that there was
25 just approval of one MVP, but the entire Illinois
1 Rivers Project; is that correct?
2 A That is correct.
3 MR. SMALL: Thank you, Your Honor.
4 JUDGE LAFAVE: Thank you.
5 Ms. Jensen?
6 MS. JENSEN: Nothing, Your Honor.
7 JUDGE LAFAVE: Ms. Agrimonti?
8 MS. AGRIMONTI: Nothing, Your Honor.
9 Thank you.
10 JUDGE LAFAVE: Ms. Overland, based on the
11 question of Mr. Small, anything further to follow up
12 on that point?
13 MS. OVERLAND: Nothing, thank you.
14 JUDGE LAFAVE: Thank you very much.
15 (Witness excused.)
16 JUDGE LAFAVE: Thank you, Ms. Overland.
Motions for Reconsideration are due 20 days after the Commission’s written Order is filed.
October 23, 2014 @ 9:30 a.m.
Minnesota Public Utilities Commission
121 – 7th Place East, 3rd Floor Meeting Room
St. Paul, Minnesota
Thursday, the ITC Midwest, LLC application for its MN/IA Transmission Project is before the Public Utilities Commission.
WATCH Live Webcast
PUC Staff filed Staff Briefing Papers which gives us some idea what PUC staff is thinking about it:
From these Staff Briefing Papers, it’s clear staff is discounting the importance of the judge’s “Finding of Fact” that ITC Midwest is a public service corporation. The judge started out his Recommendation with this finding, the erroneous part highlighted:
PUC Staff, however, glossed over this in the narrative, and then used the summary which did not highlight the erroneous part. So today I filed a letter of clarification:
This is the most important part, a big deal, yet so simple:
Minn. Stat. Ch. 322B does not equal Minn. Stat. 301B.01 (or Ch. 301B).
301B PUBLIC SERVICE CORPORATIONS
322B LIMITED LIABILITY COMPANIES
Will the Public Utilities Commission care? We shall see.
The PUC staff has filed its “Staff Briefing Papers” for the October 23, 2014 meeting:
Once more with feeling, the meeting is October 23, beginning at 9:30:
MN Public Utilities Commission
121 – 7th Place East, 3rd Floor Large Hearing Room
St. Paul, MN
Here’s the part that’s particularly disturbing, and which should be changed — the first Finding of Fact — ITC is NOT a public service corporation:
One small step… and a giant leap! A tCapX 2020 related ransmission easement settled, and at more than twice the original offer. Yeah, we can live with that.
The troubling thing is that the appraisal didn’t really make sense, and they way they came to the appraisal amount didn’t add up. But despite that, the bottom line was good, so we’re not going to quibble.
Onward, heading up north for transmission hearings for the Not-so-Great Northern Transmission Line.
Stop everything — FREEZE — mark your calendar for October 23 at the PUC!
The ITC Midwest MN/IA 345 kV Transmission Project Certificate of Need (12-1053) and the Routing Permit(12-1337) will come before the Minnesota Public Utilities Commission on October 23, 2014.
Thursday, October 23, 2014 @ 9:30 a.m.
Minnesota Public Utilities Commission
121 – 7th Place East, 3rd Floor
St. Paul, Minnesota
It’s #2 on the agenda, so it will begin at a little after 9:30, but get there by 9:30 because these things sometimes go FAST!
In the No-CapX-2020-Exceptions-to-ALJ-Recommendation, I’d requested Oral Argument for the parties. Will there be a public comment option? If you’re interested in making your comment directly to the Commission at that meeting, email email@example.com and firstname.lastname@example.org and request time for public comment. They don’t always allow public comment, so it would be best to ask for it ASAP.
Some time before October 23, staff will post their “staff briefing papers,” one for the Certificate of Need, and one for the Route Permit, and also DoC-EERA (the routing side of Commerce) will have their recommendations too focused on the route. I’ll send them around before the meeting, but do keep an eye on the dockets over the next week! The Briefing Papers will give you an idea where staff is on this, if they have a recommendation.
They’ll be looking at the ALJ’s Recommendation and Exceptions filed by the parties. Here’s the ALJ’s Recommendation:
And here are the DNR, No CapX, DOC DER and ITC Comments and Exceptions filed:
Well this is getting interesting. Mayo Clinic has weighed in, opposing the Badger Coulee transmission project because it wants to build more revenue generating options in Onalaska! Cheaper power, they claim… how many rate increases, how often, for Minnesota and Wisconsin ratepayers?
Mayo — if you’d just direct your resources to challenging need for this project, it’s vulnerable, and you could make a difference! Put your money where your clinics are and just say no!
Today in the Post Bulletin:
LA CROSSE, Wis. — Mayo Clinic Health System-Franciscan Healthcare objects to one of the routes for the Badger-Coulee power transmission line because it could stymie development on its new 187-acre property in Onalaska or its 8-year-old clinic a few miles away.
Although the La Crosse-based system has not determined its plans for the parcel it bought in February, chief administrative officer Joe Kruse said Monday that he and CEO Tim Johnson have filed an objection with the Wisconsin Public Service Commission to the southern route of two proposed pathways.
Noting that Mayo-Franciscan traces its roots to the first hospital in western Wisconsin, the letter from Johnson and Kruse says, “Our future site at 1240 Sand Lake Road will continue the evolution of Mayo in the Midwest.”
Mayo-Franciscan is not alone in its objections. About 100 units of government, including La Crosse County and the city of Onalaska, as well as hundreds of residents, have filed objections to the Badger-Coulee project.
More than 1,600 Onalaska residents have sent dissenting letters, said Brea Grace, the city’s land use and development director, adding that city officials also will be able to speak at public hearings.
ATC and Xcel say the line would improve system reliability, deliver cheaper power for Wisconsin consumers and provide a pipeline for wind energy from Minnesota and Iowa to population centers to the east.
The three-member PSC will determine whether the project is necessary and serves the public interest. The commission can approve, deny or modify the proposal and will select the route if the project is approved.
CapX 2020 construction is marching on. The other day I went down to Rochester and saw the structures coming out of the “North Rochester” substation heading east.
Here’s the CapX 2020 page on youtube!
In the inbox today, this well produced video from GRE, if only the subject matter wasn’t so depressing — it’s construction of the CapX 2020 Brookings-Hampton 345 kV transmission line, now almost complete:
I’ve been saying this for so many years, that electric demand is down, down, down, and instead, Xcel Energy (and all the others) have been saying it’s going UP, UP, UP (even though Mikey Bull said years ago that they wouldn’t need power for a while), and they’re applying for and getting Certificates of Need for all these permits for utility infrastructure that are obviously designed to market and sell the surplus, and the Public Utilities pretends to be oblivious (I say “pretends” because I cannot believe they’re that unaware and uninformed.).
This is a must read:
Here’s the short version from Xcel:
2024 is expected to be about what it was back in 2007, the industry peak year. DOH! But note this — there’s a “small capacity surplus in 2016.” DOH!
And given the surplus which we’ve known has been present and looming larger, that’s why they then ask for withdrawal of the Certificate of Need for the Prairie Island uprate because it isn’t needed (and really, that was just what, 80 MW or so? Or 80 MW x 2 reactors, 160 MW?). If they don’t need that small uprate, why on earth would they need so much more?
But what do I know…
Hollydale Transmission Line was clearly not needed, and they withdrew that application…
CapX 2020 transmission was based on a 2.49% annual increase in demand, and for Hampton-La Crosse in part supposedly based on Rochester and La Crosse demand numbers, yeah right, we know better, but that was their party line. Again, DOH, it didn’t add up to needing a big honkin’ 345 kV transmission line stretching from the coal plants in the Dakotas to Madison and further east, but who cares, let’s just build it…
ITC MN/IA 345 kV line — the state said the 161 kV should be sufficient to address transmission deficiencies in the area, but noooooo, DOH, that wouldn’t address the “need” for bulk power transfer (the real desire for the line).
Here’s a bigger picture of the bottom line (I’m accepting this as a more accurate depiction, not necessarily the TRUTH, but close enough for electricity), keeping in mind that these are PROJECTIONS, and that they’re adding a “Coincident Peak adjustment” which should be included in the “peak” calculations):
Notice the only slight reduction in coal capacity, just 19 MW, nuclear stays the same, a 320 MW decrease in gas, a 128 MW reduction in Wind, Hydro, Biomass, which I hope includes garbage burners and the Benson turkey shit plant , slight increase in solar of 18 MW, and Load Management also a slight increase of only 80 MW. This is Xcel Energy with its business as usual plan, which has to go. We can do it different, and now is the time.
Will someone explain why we paid so much to uprate Monticello, and paid to rebuild Sherco 3?
From the archives:
October 20th, 2009
May 7th, 2013
Tomorrow is the last PUC Rulemaking Advisory Committee meeting.
9:30 – 11:30 a.m.
Public Utilities Commission
121 – 7th Place East, Lower Level Meeting Room
St. Paul, MN
For the docket, go to PUC’s “SEARCH DOCKETS” and search for 12-1246.
Here are the No CapX 2020 and United Citizen Action Network comments filed earlier today (whew, busy day today!)
And the North Route Group:
And from Marie McNamara, Goodhue Wind Truth:
Also heard from, Deb Pile, Dept. of Commerce:
See that pink highlighted transmission line? That’s the ITC Midwest part of MISO MVP 3, and Exceptions to the ALJ’s Recommendation are due at 4:30 p.m. today. Look, made it under the wire by 30 minutes!!!
Here’s the ALJ’s Recommendation, for your reading displeasure:
And here are the DNR Comments and Exceptions filed after I’d posted the others:
And here are the rest posted earlier:
A major issue with that Recommendation is that it’s a cut and paste of ITC Midwest’s dream, it’s wish list, and what a wish list it was. ITC Midwest got exactly what it wanted, so is it any surprise they’d file this letter today — oh, please…