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

From the public meeting materials, here’s what they’re looking at, above.  These are significant additions to the transmission grid in Minnesota and Wisconsin.  Look at the number of double circuits they want to add, and look at the new transmission planned for Minnesota and WIsconsin.  And note how, as with CapX 2020, it’s starting in the coal fields of the Dakotas.

MISO’s Economic Planning Users Group is planning a “Regional Transmission Overlay Study” and they’re having another meeting tomorrow, May 25, 2017 down in Metatairie, Louisiana.

Here’s the call in info:

WebEx Information
Event Number: 966 575 350
WebEx Password: Ts824634

Participant Dial-In Number: 1-800-689-9374
Participant Code: 823713

Meeting Materials from the MISO site:

• 20170525 EPUG Item 01 Agenda 5/23/2017 05:24 PM
• 20170525 EPUG Item 02 Regional Transmission Overlay Study Overview 5/22/2017 05:47 PM
• 20170525 EPUG Item 03 Preliminary Overlay Indicative Concepts 5/23/2017 05:29 PM
• 20170527 EPUG Item 04 Explore New Benefit Metrics RECB Survey 5/22/2017 04:42 PM
• 20170525 EPUG Item 05 Michigan Exploratory Transmission Study Transmission_Ideas 5/22/2017 04:44 PM
• 20170525 EPUG Item 05 Michigan Exploratory Transmission Study Update 5/22/2017 04:44 PM
• 20170525 EPUG Item 06a Indicative Overlay Design Work Session West 5/24/2017 02:20 PM
• 20170525 EPUG Item 06b Indicative Overlay Design Work Session Central 5/24/2017 02:21 PM
• 20170525 EPUG Item 06c Indicative Overlay Design Session Sub-regional Connections 5/24/2017 02:22 PM
• 20170525 EPUG Item 06d Indicative Overlay Design Work Session South public 5/24/2017 02:23 PM
• 20170525 EPUG RTOS Issues List 5/23/2017 05:45 PM
• 20170525 EPUG RTOS Ideas Tracking Sheet 5/23/2017 05:44 PM

Here’s the problem — they close the meeting, and people like me aren’t allowed to attend.  First I was told, back in January when I tried to register:

Thank you for registering for the Economic Planning Users Group (EPUG) on Jan 31.  The afternoon portion of this meeting will be held in CLOSED session and reserved from MISO Members or Market Participants only.  Please feel free to attend the morning session from 11:00 am to 12:45 pm ET / 10:00 am to 11:45 CT.

I filled out their “CEII – Non-Disclosure Agreement” form and fired it off.  But noooooo…

So next I went to the PUC’s Quarterly MISO update, where I was assured that we could make arrangements so that I could attend.  I resent the “CEII – Non-Disclosure Agreement” and went back and forth and it came to this (click for larger version).  Note this “explanation” of options to be able to attend:

The reason that you were not permitted to attend the closed session is because the meeting involved discussion of Critical Energy Infrastructure Information (CEII) and CEII access requests by Non-Member Individuals requires FERC clearance.  Another access option is to be included on Appendix A of a MISO member or Market Participant.

So that says there are two ways to gain access, 1) get “FERC clearance” or 2) “Another access option is to be included on Appendix A of a MISO member or Market Participant.“  One or the other. Emphasis added.  Here’s the email (click for larger version) laying out those two options:

Oh, I says to myself, off to FERC.  I sent in the requisite paperwork to FERC, and got “FERC clearance” and they shipped me the CEII information, including but not limited to the map.  I let MISO know I’d obtained “FERC clearance,” and here’s the response (click for larger version):

ARRRRGH, they have my CEII NDA on file, have had it since January 23, 2017.  I resent it to the writer of these emails on March 4, 2017, and I sent it again today, and objected to yet another change in their “rules” (click for larger version):

So the plot thickens — from MISO (click or larger version):

And from moi (click for larger version):

It’s early, so now’s the time to get agitated, get activated!

As if CapX 2020 wasn’t enough, and during the CapX 2020 Certificate of Need proceeding, word of the “JCSP” overlay came out.  And we know that Xcel, in its e21 Initiative, is whining about the grid only being 55% utilized (DOH! Because CapX and other transmission expansion wasn’t needed, was built, and now they’re trying to make us pay for it!).

And as if Obama’s RRTT wasn’t enough, now there’s this, check out Executive Order 13766:

Expediting Environmental Reviews and Approvals for High Priority Infrastructure Projects

And so now the rest of the story — here’s what they’re planning:

Here’s the list, in a spreadsheet:

20170131 EPUG Preliminary Overlay Ideas List

The Minnesota Public Utilities Commission has scheduled the MISO Utilities Quarterly Update Meeting for the Second Quarter of 2017 for Friday, March 3, 2017 from 10:00 AM to Noon in the Commission’s Large Hearing Room, 121 7th Place East, Suite 350, St. Paul, MN 55101.

MISO Q letter 03-10-2014.bh.-1

Note this part, to be discussed at this meeting:

Laying the ground work now for this, a huge build-out that isn’t needed, an overlay on top of transmission that wasn’t needed either.  NO!

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?):

Last Minnesota leg of $2.1 billion electricity mega-project done

From WKBT (video here):

CapX2020 transmission line completed

And Wisconsin Public Radio:

Collaborative Utility Project Connects Electric Transmission From South Dakota To Wisconsin

Rochester Post-Bulletin:

Drone patrols the power line

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:

Oh well…

Remember their shindig on Tuesday:

September 26, 2016

Time?  They’re not telling…

Hampton Substation

Highway 52 and 215th Street (N. of Hwy. 50)

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:

Order Denying Intervention – SunShare & ILSR

Here are their Intervention Petitions:

ILSR_Intervention_20164-120145-01

SunShare_Intervention_20164-120144-01

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.

Myer Shark, Lawyer Who Fought Utility, Is Dead at 94

In the Matter of the Complaint by Myer Shark, et al …

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.“

Transmission Planning and CapX 2020: Building Trust to Build Regional Transmission Systems

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:

MN PUC Commissioner Reha’s Feb 15 2006 presentation promoting CapX 2020

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:

Remember Xcel’s CapX 2020 peak demand projections of 2.49% annual increase?  How wrong can they be?  And how unjustified was their basis for a Certificate of Need for CapX 2020?  And how are they held accountable for those gross misrepresentations?  But now it’s time to pay, and who will pay?  This is why the rate case in progress, PUC Docket 15-826, is so important.

On the other hand, I love it when this happens… Xcel Peak Demand is again DOWN!  There’s a trend, and it’s called decreased demand.  Demand has yet to exceed the 2007 peak, and now it’s 8 years…

Here’s the Xcel Energy SEC 10-K filed a couple days ago:

2015 – Xcel Energy 10-K

Is it any wonder they want to get away from a cost based rate a la their “e21 Initiative” scheme?  Particularly now that the bill for CapX 2020 is coming due and their newest rate case (PUC Docket GR-15-826) is now underway?

And the specifics, and note how they inexplicably forecast a 2016 peak of 9,327, which is based on a “normal weather conditions” assumption:

Today a FERC order came out addressing a Petition for Limited Intervention Out-of-Time made by No CapX 2020 and United Citizens Action Network, filed on May 20, 2010, nearly 6 years ago.

FERC Intervention-NoCapX & U-CAN  FERC Docket ER09-1431

This was SO far back, 2010, back when the CapX Applicants and the Minnesota Public Utilities Commission were ramming through CapX 2020 Certificate of Need BEFORE there was any cost allocation scheme solidified.

And it was at the time that MISO was hammering together the MISO MVP 17 project transmission Portfolio.

Now that CapX 2020 transmission rate recovery is before the Commission, the Minnesota PUC, FERC goes back into history to make sure that No CapX 2020 and United Citizens Action Network are not part of the discussion:

ER09-1431_Order Denying Reconsideration (denial of No CapX & U-CAN Petition on p. 8)

So this just happens to come up when cost allocation and recovery are at issue in the Minnesota PUC Rate case… and Xcel’s attorney is working so hard to keep us out of that docket.

Fresh Energy, Sierra Club (national?  Northstar Chapter?  ??), Wind on the Wires, NRDC, MCEA have joined together under MCEA to intervene in the Xcel Energy “transmission driven” rate case.

CEO+Petition+to+Intervene

So… are all of them in agreement on positions?  Some were e21 Initiative participants, some were not.  WOW openly is a supporter of transmission, so what position might they take in this rate case?

And then there’s their role in Xcel Energy’s e21 Initiative and their role in this:

Letter & e21 Initiative Report_201412-105629-01

I wonder what standards they’ll be held to…

Fresh Energy makes no mention of whether they’re rate payers and claims it “works in the public interest…”  Oh my…

Sierra Club gives no indication which branch, office, or what.  Is it Sierra national?  Is it the NorthStar office?  The Madison office?  Inquiring minds would like to know.

Wind on the Wires, the Waltons spin-off, doesn’t address whether they’re ratepayers — and they’re an industry special interest group, a trade organization, “focused on prioritizing the delivery of large amounts of all types of wind energy to markets in the Upper Midwest, and represents members who produce wind power and technology who have a direct interest in energy rates at issue in this case,” as RECIPIENTS!

NRDC — their interest in this is???  Not at all clear.

MCEA as Intervenor, as “attorney” and its interest is?  Again, not at all clear.

And are these entities setting up for a conflict of interest, or are they all in lockstep?  Some participated in e21 and some did not.  Some participated in transmission and some did not.

And this statement… “Without Petitioners’ continued participation in both dockets (the rate case and the alternate rate design, 15-662) it is more likely that the two proceedings will reach inconsistent outcomes due to divergent goals.”  Please explain what the heck that means, and please, let’s get specific about the “divergent goals.”

And here’s one admission that is important in this “transmission driven” rate case:

By the same token, Petitioners are interested in supporting renewable energy expansion from sources of all scales, including transmission infrastructure to support such projects.  To the extent that NSP is proposing grid modernization projects both in this rate case and in a parallel Commission docket, Petitioners will be able to add unique perspective on these proposals and their usefulness in meeting efficiency and clean energy goals.  Grid modernization and transmission funding under this rate have a direct bearing on the legal rights of Petitioners’ members, as well.

Yes, please explain.

Apparently Judge Oxley did not like the Overland and No CapX 2020 Petition for Intervention in the rate case, late Friday the Order came out.  It was denied, without prejudice.  And yet interventions for Commercial Group, Suburban Rate Authority, and City of Minneapolis were granted…

20161-117574-01_Order Denying Intervention

… sigh… OK… fine…

Just filed at 12:01 a.m. Monday, January 25, 2016:

Overland-NoCapX_Intervention2_FINAL

These transmission issues being raised about CapX 2020 and the MISO MVP 17 Project Portfolio are so important that I’m going to be persistent.

Here’s the schedule, from the First Prehearing Order: