NO Grid North Partners – transmission f/k/a CapX 2020

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:  dennis.rankin@wdc.usda.gov

(I’d also cc DPC’s Chuck Thompson:  cat@dairynet.com)

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:

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.

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.

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.

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:

Etymology

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 sÄ“lian, 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…

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:

This 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!

Yesterday we went off for a picnic at Alma’s Buena Vista Park, with the beautiful “Buena Vista” overlook, a new picnic table right near the edge of the lookout, the buena vista over… well… over the new CapX 2020 line and the Alma John P. Madgett coal plant owned by Dairyland Power Cooperative.  CapX transmission has made it to the edge of the Mississippi, and no further.

What can I say… Little Sadie took one look, squatted, and promptly left her editorial and aesthetic opinion.

Here’s the uncropped view:

And from the other way, looking towards Alma:

We’ve had another tragedy on the construction of the CapX 2020 Brookings transmission line:

Worker electrocuted on CapX 2020 power line near Fairfax, MN

KMSP-TV

Last week the meetings were held on the Draft Environmental Impact Statement for the ITC Midwest MN/IA 345 kV transmission line.  Here are some reports:

Power line could be close to Blue  Earth

April 27, 2014

by Chuck Hunt – Register Editor (chunt@faribaultcountyregister.com) , Faribault County Register

Some residents of a housing development just north of Blue Earth received some shocking news last Thursday.

A large, new electrical transmission line could possibly be joining the neighborhood.

The Minnesota Department of Commerce held two information and listening sessions at Hamilton Hall in Blue Earth last Thursday to explain the project and gather any comments concerning it.

ITC Midwest is seeking a state permit to build a 73-mile long, 345 kilowatt electrical power line using 130 to 190 foot tall towers. The transmission line will start near Jackson, travel east to near Huntley, then turn south to the Iowa border.

The route from Huntley south to the Iowa border will be along the western edge of Faribault County.

There are multiple variations of the proposed route. One of those alternate routes brings the line very close to the Riverside Heights development just north of Interstate 90.

“That one alternate route would bring the line within 100 to 200 feet away from my home,” Riverside Heights homeowner Randy Anderson says. “And yet I was not notified about this meeting. I just heard about it two hours ago.”

Faribault County commissioner John Roper echoed those comments.

“I am very disappointed the county was not kept in the loop on all this,” Roper said. “And I think you needed to notify all of the landowners near the proposed routes, not just the ones where you need easements for right-of-way.”

A staff member of the Minnesota Department of Commerce, Ray Kirsch, replied he thought a copy of the environmental impact statement (EIS) had been sent to the county planning and zoning office.

“We are holding these meetings to allow everyone to make comments about the project,” Kirsch says. “We were here last July to gather information and comments and those have become part of the draft EIS.”

Besides the two meetings in Blue Earth, there also were listening sessions held in Jackson and Fairmont.

“People have until Friday, May 9, at 4:30 p.m. to make comments to my office,” Kirsch says. “We will incorporate all the comments into the final EIS.”

Then on May 13 and 14, an administrative law judge will hold comment sessions in Blue Earth, Fairmont and Jackson. Anyone can attend those sessions with questions, concerns and comment, Kirsch says.

On Thursday, approximately 50 people attended the afternoon comment session and about a dozen were at the evening one. Ten people made comments for the record, including several other residents of Riverside Heights.

Those giving comments included Tim Steier, Jeff Moore, Al Roesler, Carol Moore and Morris Hanson, as well as several persons from out side the local area.

And in the Lakefield Standard (part of it):

Transmission line study: Each route has its ups and its downs

By Justin R. Lessman (April 22, 2014)

Running a 345-kilovolt transmission line just north of Interstate 90 — or even along it in some places — would be better from an aesthetic and agricultural standpoint than a route farther north, but worse in that it could affect an area of historical importance.

That finding is included in the draft environmental impact statement prepared for the ITC Midwest 345kV Transmission Line Project by the Minnesota Department of Commerce. ITC Midwest is proposing to construct a 73-mile transmission line from Lakefield east to Huntley, between 15 and 20 miles of which will run across Jackson County.

ITC Midwest has proposed two primary route options through Jackson County, one running nearly straight east from Lakefield along County Road 14 and 820th Street, the other running along the south edge of Boot Lake, jumping north along County Road 19, heading east at the intersection of County Road 16 and stair-stepping its way up to County Road 22.

And from the Fairmont Sentinal Online:

Power line generates comments

April 23, 2014

Jenn Brookens – Staff Writer , Fairmont Sentinel

Save | Comments (1) | Post a comment |

FAIRMONT – Two meetings held in Fairmont on Tuesday offered information from a draft environmental impact statement for the proposed ITC Midwest 345-kV transmission line project.

The proposed line would run from Lakefield Junction in Jackson County, through Martin County, into Faribault County and then go south into Kossuth County in Iowa. The line would stretch 75 miles through southern Minnesota.

An original plan had the line running south of Interstate 90 on the north end of Sherburn, something that had many Sherburn residents concerned. But a modified route puts the transmission line north of the interstate instead.

While many in Sherburn may breathe a tentative sigh of relief, the original route will not be completely off the table until fall, when the state Public Utilities Commission decides on the certificate of need and route permit. To help, an administrative law judge is called in to review the project and issue a decision.

“The commission is not bound by the judge’s decision, but it holds a lot of sway, since they are the ones that hire him,” said Ray Kirsch, environmental review manager with the Minnesota Department of Commerce.

The judge is present at public hearings, comment periods and contested case hearings. Public hearings for the project will be held May 13-14.

Comments also are being accepted from now until May 9. Several people in attendance Tuesday at the Knights of Columbus Hall spoke on the record, many of them Sherburn residents who voiced concerns about the original route plan that took the lines into town.

“Route A, as it was proposed, would run 120 feet from our church building,” said Ron Mixer, pastor at Sherburn Regional Worship Center. “If that route is selected, it would make our church building unusable.”

Mixer went on to explain that the building is all metal, and the lines would likely interfere with the building’s P.A. system, low-level radio frequency that helps the hard of hearing and the church’s video transmission. But those problems pale in comparison to the potential dangers the line would pose to those who attend the church, he argued.

“If something were to fail with those lines, it would be catastrophic,” Mixer said.

Health concerns also were expressed by others in attendance.

“We have great concerns about Route A,” said Martin County West Superintendent Allison Schmidt. “About 500 of the 700 students in my school district attend schools in Sherburn. While we appreciate the modified Route A, I believe there still is a concern for the health of those 500 students and staff members, so we would like that clarified.”

“It has been shown that high-voltage exposure is harmful for children and unborn children,” said Sarah Jagodzinske Rohman, a Martin County West school board member. “We hope you will look into protecting us as rate-payers, but more importantly as humans and our children, who are our future.”

There also were concerns about property values.

“A business that planned to build on some property just south of the interstate said he wouldn’t if that power line went through,” said Helen Murphy. “He said, ‘This line will kill Sherburn.'”

Verbal comments at the meeting were recorded for the report to the PUC, and other comments will be accepted until May 9 by mail, fax or e-mail to Kirsch. Comments can be left online at mn.gov/commerce/energyfacilities

Mailing address: Ray Kirsch, Environmental Review Manager, Minnesota Department of Commerce, 85 Seventh Place East, Suite 500, St. Paul, MN 55101-2198

Fax: (651) 539-0109

E-mail:

raymond.kirsch@state.mn.us

As we say in transmission, “It’s all connected.”  This post is about the connections between what’s been proposed by ITC Midwest as the MN/IA 345 kV project, and its relation to other projects in the area and its place in the “package deal” Multi Value Project (MVP) Portfolio.  Remember in looking at these maps that in the Midwest, power flows roughly from the NW to the SE.

Once more with feeling, here’s the project map in Minnesota:

This project above, is the Minnesota part of MISO’s “MVP 3” which is in Minnesota and Iowa, and which connects directly to MISO’s “MVP 4” in Iowa, heading east:

So now, let’s look at the bigger picture, of which there are several.  First, the full MVP portfolio, 17 transmission projects in the Midwest:

This MVP Portfolio was modeled, studied, and sold as a “package deal.”

Now let’s take a look at how this all fits together, MVP 2, 3, 4, 5 and other recent 345 kV additions to the system, remember, “It’s all connected” in transmission:

MVP 1 in the NW corner of this map runs from the Big Stone coal plant to the Brookings substation.

MVP 2 is the CapX 2020 Brookings-Hampton transmission project.  No CapX 2020 and CETF intervened in the CapX 2020 Certificate of Need docket (06-1115) and No CapX 2020 and U-CAN intervened in the Routing docket (08-1474).

MVP 3 is in part, this ITC Midwest MN/IA line, in pink on the map, divided roughly 50/50 between Minnesota and Iowa, and 50/50 between ITC Midwest and Mid American.  MVP 3 surrounds the “3” in the map, above, like a tuning fork, with two forks running west to east, and then a connecting line running north/south.

MVP 4 runs eastward from MVP 3, and connects into existing 345 kV transmission, the blue dots.

MVP 5 is in part the Badger Coulee line, in blue on the map.  Note the connecting blue dots between MVP 2’s Hampton substation through SE Minnesota to La Crosse, WI.  As above, CapX 2020 and CETF intervened in the CapX 2020 Certificate of Need docket (06-1115), and No CapX was an intervenor in that routing docket, jointly with U-CAN and North Route Group.  The other part of MVP 5 is the part connecting MVP 3 and MVP 4, via existing transmission, into MVP 5 and running towards Madison.

Here’s a map from the MVP report, where you can graphically (in the “WOW” “DUH!” sense) see that the point of all these projects, the package, is to move power from the cheaper areas to the higher priced areas, from where electricity sells for $30-50 to $70-200:

The “benefit” of being able to sell power for so much more than is currently possible is one hell of a benefit!

It’s connected by benefits — the “benefits” claimed are the benefits achieved if, and only if, all 17 MVP projects are operating.  All the modeling was done with that assumption, that ALL of the 17 projects are operating.

Here’s the full MISO Business Case document, check it out:

20110919 MVP Proposed Portfolio Business Case

And even more, the full MVP Report:

MVP Portfolio Analysis Full Report

And while we’re talking about “benefits” it’s time to trot out that ICF Benefits report again:

ICF – MISO Benefits Analysis Study

More in a bit — up next is cost info — there’s additional MISO stuff I need to look up.

What’s so important about these ITC Midwest MN/IA line, and the Draft Environmental Impact Statement meetings that the Center for Rural Affairs would send someone show up in Jackson, Minnesota, but rather than join the discussion, get paid to sit through this afternoon’s meeting like a bump on a log?  Oh, that’s right, they get paid to do this, it’s part of the RE-AMP transmission promotion program.  Really… ya should’a been there.  It seems Lucas Nelsen, the Energy Policy Associate at Center for Rural Affairs was here in Jackson, sitting right next to Duane Ninneman of CURE!  Duane, the company you keep, and I’d guess this is part of your “new duties” as RE-AMP’s Clean Energy Working Group leader for the next three years:

“My job as RE-AMP’s Clean Energy Working Group leader is to facilitate interaction between top-level clean energy thinkers to keep us on target to reach our global warming pollution reduction goals,” Ninneman stated. 

No wonder it was so quiet back there — and hey, why’d y’all leave so quickly?

Lucas Nelson, Center for Rural Affairs, is the principal named as author on the “Energy From the Ground Up” report:

Energy From the Ground Up

This report is a review of media coverage of transmission projects, looking at how to handle objections to transmission:

100 discrete media pieces, examining a total of 14 different transmission projects. Each piece was then analyzed and organized based on the clear concerns identified within.  Those concerns were used to inform the common themes used in the review section, and to provide data that gives insight into the general views of stakeholders. 

why are you focused on handling objections?  Oh, that’s right, it’s part of the RE-AMP transmission promotion work.  What projects were you interested in?  “My” projects, and more:

Of these projects, I’ve worked on half of them — the only ones I’ve not worked on are the Reynolds-Topeka, Grain Belt Express, Rock Island Clean Line, Illinois Rivers, Plains and Eastern, Center-Grand Forks, and Gateway Power.

What conclusions did they draw?  Center for Rural Affairs takes the position in this report, for example,  ono p. 8, that “As transmission serves a public need, utilities and developers serve as agents of the government and can receive this power.“  NO!!!  Much transmission does NOT serve a public need, and in particular, this ITC Midwest serves a PRIVATE desire, not need, the desire for profit.

And in the section on “need” there is utter disregard for the statutory criteria for need!

Ahhh, yes, we know what complaint they’re talking about now, don’t we (haven’t read the article, but I’m a bettin’ it’s us):

Booted out of FERC

The bottom line of this “report” is an exercise in figuring out how to best handle objections, get these projects through, circumvent the obstacles, or as Beth Soholt says, “remove the impediments,” (I say, speaking as a proud impediment!),  inherently presuming that the projects should go through — and what should be disclosed in this “report,” and which is not, is full disclosure of the Center for Rural Affairs’ motivation for publishing this, i.e., did they get paid for this, and why would they take money to do this?  If they’re agriculturally focused, shouldn’t they be furthering landowners’ interests, helping explain eminent domain and helping landowners protect themselves from egregious developer/utility eminent domain practices?  I could go on and on, but you can see for yourself by reading this report that it’s a RE-AMP transmission promotion puff piece.  Nothing more.

Center for Rural Affairs has also weighed in specifically on this ITC Midwest MN/IA transmission line:

Two-State Transmission Project Takes Important Regulatory Step

It’s unfortunate that they don’t contribute to this need or routing process, don’t help landowners, farmers, and agricultural interests.  They’re the Center for Rural Affairs, but they’re not furthering their mission, and instead are working against it, and in favor of, and for, utilities and transmission developers.  What’s their mission?

Establish strong rural communities, social and economic justice, environmental stewardship, and genuine opportunity for all while engaging people in decisions that affect the quality of their lives and the future of their communities.

And then there’s this RE-AMP promotion of transmission and revenue generation – RE-AMP_Foundations_Master_Grant_List.  How does that fit in to their mission?   Center for Rural Affairs‘ budget is over $5 MILLION annually.  Do they “need” the money that badly?  I think the term “Affairs” is off point, and a little baser word would be more apt… we know what y’all are and we have an idea of your price!

So yesterday, as I’m on the way into the meeting hall, a guy’s coming out, and I offer a flyer, and he holds his hands up, “No, I’m not part of this, I’m part of the burn!”  … the BURN?  Yup, seems they had scheduled a burn of a little swale/prairie behind the K of C Hall.  Shortly thereafter, the fire trucks pull in, little torches are lit, and burn, baby, burn…