Cardinal-Hickory Creek Xmsn to Federal Court

Filed under:Uncategorized — posted by admin on December 13, 2019 @ 11:54 am

Driftless Area Land Conservancy and Wisconsin Wildlife Federation have filed a Complaint in the Western Wisconsin District Federal Court!

Some press coverage:

Wis. power line opponents take fight to federal court

Environmental Groups Sue Wisconsin PSC Over Approval Of Transmission Line

Here are the filings:

19-cv-1007 DALC-WWF Complaint – Download 

19-cv-1007 Exhibit A – Download 

19-cv-1007 Exhibit B – Download 

19-cv-1007 Exhibit C – Download

19-cv-1007 Exhibit D – Download 

19-cv-1007 Exhibit E – Download 

19-cv-1007 Exhibit F – Download

Posted by Carol A. Overland

Rehearing for Cardinal-Hickory Creek?

Filed under:Uncategorized — posted by admin on October 17, 2019 @ 10:58 am

Just filed yesterday, the Jewell Jinkins Intervenors request that the Wisconsin Public Service Commission take another look at their decision approving the CPCN and routing for the Cardinal-Hickory Creek transmission line:

This is the final shot before the Commission at this PSC CPCN approval. The next possible step is Wisconsin’s Circuit Court, due 30 days after they (likely) reject this Petition. Other intervenors are planning on heading that way, ones with solid backing and resources.

345kV Wilmarth – Faribault – North Rochester (N of Pine Island)…

Filed under:Uncategorized — posted by admin on September 23, 2019 @ 6:12 pm

That’s the CapX 2020 345kV line crossing Minnesota’s Zumbro River at the White Bridge Road looking towards the “North Rochester” substation just north of Pine Island. Now they’re proposing yet ANOTHER 345kV line coming in from the west to “North Rochester.” It’s called the Wilmarth (Mankato, the garbage burner and gas plants there)-Faribault-North Rochester line, proposed for the “B” list (which typically moves up to the “A” list the following year) in the 2020 MTEP report.

Here’s the chart, sortable (very interesting by state and by “Geographic Location — meaning company), this line is on the bottom of the spreadsheet, highlighted in red, with no cost estimate:

Per the MISO spreadsheet:

Studied during the MN 44 exploratory analysis, this project adds a 345 kV line between Mankato and Rochester. The line will stop at a new 345 kV yard in Faribault to support the local 100 kV system.

Low voltages exist in the Owatonna and Faribault areas during P2 and P6 events. Load growth has brought the system to capacity. In addition to this, overloads due to future high wind scenarios occur throughout south central MN.

In the 2017 Biennial Electric Transmission Planning Report, the project was REJECTED as an “alternative” to the ongoing Wilmarth-Huntley 345kV line, but here it comes again?? From that Report:

Alternatives:  Several solutions such as rebuilding the South Bend to Blue Earth to Huntley 161 kV, a new Freeborn to West Owatonna 161 kV circuit, and a new Wilmarth to North Rochester 345 kV circuit were also studies to relieve the congestion observed.

This is absurd. It’s just like the WIREs-WRAO Report from 1998. The WRAO report rejected 20+ “alternatives” for the be-all and end-all of transmission, Alternative “3j,” the Arrowhead Transmission Project:

… and then slowly but surely they’ve been building each and every rejected “alternative” ever since. Here we go again, another transmission line that isn’t needed, but that will facilitate export.

We do NOT need another transmission line in southern Minnesota.

More transmission? CapX 2050? They’re NUTS!

Filed under:Uncategorized — posted by admin on August 19, 2019 @ 6:09 pm

First there was CapX 2020 transmission (following Arrowhead transmission, which was supposed to be the be-all and end-all of transmission)(and the SW MN 345kV line, precursor to CapX 2020. CapX transmission was based on a forecasted 2.49% increase in demand, which as we know, didn’t happen.

And there was the MISO 17 project MVP Portfolio:

Tomorrow, the Wisconsin Public Service Commission is making its decision regarding the Cardinal-Hickory Creek transmission project, the southern part of MVP #5 above, and the LAST of the MVP projects to go through state administrative approval.

So today, this press release:

FINAL-CapX 2020 Press Release

And this in the STrib:

Minnesota utilities will study if the $2B CapX2020 grid improvements were enough

The study beginning in January will look at whether renewable energy goals and other factors will bolster need to build out more improvements on transmission grid. 

By Mike Hughlett Star Tribune AUGUST 19, 2019 — 3:05PM

Photo: DAVID JOLESA utility worker assesses electrical power lines in south Minneapolis.

Minnesota’s largest power companies and several other Upper Midwest utilities will study how their transmission network must be bolstered to meet increasingly aggressive renewable energy goals.

The study is being launched at a time when space on the region’s Midwest’s grid is already tight — even after a $2 billion transmission expansion that was completed just a couple of years ago.

That project, called CapX2020, was the work of Xcel Energy, Great River Energy, Minnesota Power, Otter Tail Power and seven other electricity providers in Minnesota, Wisconsin and the Dakotas. CapX2020 took over seven years to complete and included 800 miles of new high-voltage lines.

Ten of the 11 utilities involved in the earlier project Monday announced the “CapX2050” study, which they are aiming to complete in January. The study “will look at maintaining a safe, reliable and cost-effective electric grid as the system adds more carbon-free energy,” the utilities said in a statement.

CapX2020 was the largest transmission project in the Upper Midwest since the 1970s, and it was aimed partly at freeing up power line capacity for burgeoning renewable energy production.

The U.S. electrical grid was built to serve large centralized power plants, but wind and solar farms are more dispersed, often requiring transmission build outs. Xcel has stated plans to produce 100% carbon-free power by 2050, while other utilities also are planning for significantly more renewables.

Also, Minnesota’s DFL Party has strongly backed raising Minnesota’s overall carbon-free energy goal to 100% by 2050.

The CapX2020 project isn’t enough to meet those long-term needs and the grid is essentially “at capacity,” an energy analyst at the Union of Concerned Scientists told the Star Tribune last year.

Xcel’s latest long-term resource plan, filed this spring, came to a similar conclusion. “Many of these (CapX2020) lines planned in the early 2000s and completed over the recent past are already fully-or-nearly-fully subscribed,” the plan said.

So that said, here’s Xcel Energy’s Integrated Resource Plan’s Appendix on transmission:

The schedule for IRP hearings was just released, it’s in October, so there’s time to make time for it:

We know Xcel Energy gets a “handsome” rate of return for transmission capital expenditures (hence “CapX transmission), so of course they want to build more.

How about shutting down some of those coal plants, and freeing up some capacity? How about siting solar on every rooftop, over every parking lot, putting the generation at load so we don’t need transmission? Oh, but wait, that makes too much sense, especially where a utility wants to keep control of the generation, and the expenditures, and rake in the dough.

Time to pay attention to the IRP. URP!

Transmission Costs

Filed under:Uncategorized — posted by admin on July 6, 2019 @ 9:24 am

I’ve been noticing that in the transmission applications for… at least a decade now… that they don’t provide the costs estimates as they did previously. For example, for the Arrowhead Project, there was a detailed estimate of everything down to the cost of the structures, the wires, salvage value of removed lines, land cost, etc., and now, it’s just one number, plus contingency (at a much higher percentage that earlier) and AFUDC. They say they use MISO cost numbers, but don’t provide that info.

Well, lookie what I found:

Soooooo…. back to looking up info on claim that this Dodge County Wind 345kV is part of the “regional grid.”

Haven’t seen anything in this area since the utility pipedream of WRAO, most of which is already built.

See that red dotted line running east along I-90?  Split Rock (S. Falls) to Lakefield Junction was the 01-1958 “SW 345kV lines” way back when.

It’s my belief that ITC’s MVP lines 3 and 4 connecting from Lakefield Jct., and heading into the northern part of Iowa was the rest of the “I-90” line, but perhaps not? Time will tell… as will the MTEP!

NOTICE – Annual Hearing – Power Plant Siting Act

Filed under:Uncategorized — posted by admin on December 5, 2016 @ 9:44 am


Here we go again, the Annual Hearing for the Power Plant Siting Act.


The full Notice:

16-0433 Notice of the Power Plant Siting Act Annual Hearing

Now’s the time to dig back into the cobwebs of memory of all the dockets over the last year, and the last 20+ years, and let them know how the Power Plant Siting Act is working, and more importantly, how it’s not working.

Comments are open until January 20, 2017.  To file in eDockets (highly recommended), go here, and log in.  If you don’t have an account, register (it’s simple, and fast) and then file in docket 16-18.

Note something different, this year they’re going to go over pipeline projects:

iiid2Recently, I’ve been involved in a project working toward increased meaningful and effective public participation in a pipeline docket, and what’s going through my head as I attend meetings, conference calls, and read very long intense emails, is that this is exactly what we’ve been talking about at these Power Plant Siting Act hearings for TWENTY YEARS!  This is exactly what we’ve been working to deal with in the Certificate of Need Minn. Ch. 7849 rulemaking for THREE YEARS!  These are exactly the same issues I’ve been raising in docket after docket, gaining a remand in one, some “adjustments” in others, and even to the appellate court a couple of times — MCEA had more success in this (see the EIS decision here).  And so little changes.

OK, folks, time to saddle up for another cattle drive!  Let’s get to it!

And on December 20th again… sigh…

Dairyland’s Q-1D South Environmental Assessment

Filed under:Q-1 Upgrade,Uncategorized,Wisconsin — posted by admin on June 19, 2016 @ 3:37 pm


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:

Q1-South_Environmental Assessment (BIG FILE)

And from Dairyland’s site:

Briggs Road to La Crosse Tap (Q-1D South) – Environmental Assessment

Comments are due July 1, 2016 — send to:

USDA’s Dennis Rankin:

(I’d also cc DPC’s Chuck Thompson:

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

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:

End of the Line

Here’s what it looks like further north — look at all those homes:

Sheet Map 3

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.
Note: See s. SPS 316.225(6) Clearance Over Buildings and Other Structures, which refers to ch. PSC 114 regarding clearance of conductors over 600 volts and the prohibition of dwellings under or near overhead lines.
So look what Dairyland says about these clearance problems, first on page 3-3 of the Q1-South_Environmental Assessment in its discussion of alternatives, specifically joining with Xcel Energy, which has a similar line right through the community over homes and through yards on the other side of the highway:
Though there’s no case law about this, Dairyland states, “This provision likely applies to Xcel as a public utility but not DPC as a cooperative.”  That’s pretty presumptive, with no basis for the presumption, DPC!  And they wiggle around again, claiming the code doesn’t apply to them 10 pages later:
Do you buy that argument???  First, they don’t even cite the correct PSCW section, using “PSCW 114.234(a)(4)” rather than PSCW 114.234(a)(2).  Note they state that “public utilities may seek waivers of any rule expanding upon NESC requirements…”  But if they’re saying the code doesn’t apply to them, why would this apply to them and they can seek a waiver?  Under their argument that the PSC Code doesn’t apply to them because they’re a cooperative, then if that applied, then this would not apply to them either.  Or is it the opposite, that the Code does apply to them, they cannot rebuild the line under  and have to apply for a waiver to the PSC?  Which is it, Dairyland?  Oh, but wait, I thought part of why you’re doing it the way you are, applying to local governments, in this short segmented version of your Q-1 line, was that you don’t want to have to go to the PSC, that you’re trying to get around it…
Segmenting, particularly segmenting to avoid environmental review, is not OK, Dairyland…

ITC tariff adder cut, just as costs are showing up!

Filed under:Uncategorized — posted by admin on May 5, 2015 @ 3:50 pm


In an interesting twist that will take some digging to fully understand, ITC got smacked upside the head recently at FERC.  Well, a little, but they should have been sent packing altogether.

They’d requested a tariff adder, in addition to the 12.38% that they’re getting as return on equity.  WHAT?!?!?!  MORE?!?!?! They didn’t get the full 100 basis points, but did get 50… so if I understand this correctly, the interest rate now will rise by 0.50% to 12.88%.  Why?  And their objection is that FERC always has given the adder requests to transmission only companies, and so now, why didn’t they get it.  Whine, whine, whine…

To read about this, check the FERC docket.   Go HERE and search for docket ER15-945.  Here’s their original Petition from January 2015:

Initial Filing_20150130-5273(30113346)-1

And surprise, here’s what FERC said (hint: they only got half of their request!):

Order Conditionally Accepting & Suspending Tariff Filing _20150331-3061(30452072)

Regarded as so extreme that the two Dissenters felt a press release was in order:

Moeller & Clark PressRelease_Dissent_20150401-3044(30455217)

I love it when they don’t get their way, but there’s also no justification for the 50% adder, no way, no how, not in this day of low, low prime rate interest.




Filed under:Uncategorized — posted by admin on April 6, 2015 @ 2:01 pm

Why am I on this mailing list?


Let’s see… they got $75k from the PSC (PSC REF#: 212767, PSC REF#: 212769), $37,500 to CETF directly attributable to the IC Request I drafted…

CETF – SOUL $75,000 Intervenor Compensation Award

And look at the numbers presented above… oh my…

And about “soul” from the Wiki link:


The Modern English word “soul“, derived from Old Englishsáwol, sáwel, was first attested to in the 8th-century poem Beowulf v. 2820 and in the Vespasian Psalter 77.50—it is cognate with other Germanic and Baltic terms for the same idea, including Gothicsaiwala, Old High Germansêula, sêla, Old Saxonsêola, Old Low Franconiansêla, sîla, Old Norsesála and Lithuaniansiela. Further etymology of the Germanic word is uncertain. A more recent suggestion[4] connects the word with a root for “binding”, Germanic *sailian (OE sēlian, OHG seilen), related to the notion of being “bound” in death, and the practice of ritually binding or restraining the corpse of the deceased in the grave to prevent their return as a ghost.

Yup, shoulda, woulda… that “practice of ritually binding or restraining the corpse of the deceased in the grave to prevent their return as a ghost” just might have been what was called for…

ITC Midwest – ALJ’s Recommendation due tomorrow!

Filed under:ITC MN & IA 345 kV,Uncategorized — posted by admin on September 7, 2014 @ 10:23 am



Monday, September 8, 2014, the ALJ’s Recommendation on the ITC Midwest MN/IA Transmission line is due — for the Certificate of Need and the Routing dockets.

To see the full docket, go to the PUC SEARCH PAGE and search for dockets 12-1053 (CoN) and 12-1337 (Routing).

Then, after the ALJ’s Recommendation is out, we’ve got until September 23rd (15 days) to file exceptions to the ALJ’s Recommendation.  I can’t copy the rule because the state’s site is down (for updating, I presume), so here’s a cut and paste of the explanation from a prior decision:

ExceptionsThis is important because it’s the opportunity for not just parties, but for “any party adversely affected” to address the specific parts of the ALJ’s Recommendation that are a problem.

No CapX 2020 will be filing Exceptions.

Questions?  Let me know!




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image: detail of installation by Bronwyn Lace