No CapX 2020

The MPV3 line they’re referring to below is the red line above. The MVP projects were, at the time, estimated to cost $5.24 BILLION, to be divided between states.  This MVP project was one where NoCapX was a limited intervenor, and one where the Dept. of Commerce inexplicably did a 180 in its testimony, from saying “no need” to claiming need.  Yeah, right… And then there’s the matter of testimony under oath — the ALJ refused. WHAT?!?!  No excuse for that, it’s a part of the ALJ’s job.  Minn. R. 1400.5500(F).  Here’s a contemporaneous rehash of that mess:

ITC Midwest transmission hearing OVER!!??!!

And today, an announcement that Line 3 has been energized.  It’s in the Albert Lea Tribune, note the byline “By Submitted.”  That means that ITC sent them a press release, right?  This isn’t news, it’s an unpaid advertisement.

ITC Midwest energizes new electric transmission line in southern Minnesota

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!

See the lower 1/2 of MISO’s MVP project 5, running from near Dubuque, IA to the northeast to the “Cardinal” substation near Madison?  That’s the Cardinal – Hickory Creek transmission line.

The Dodgeville Chronicle ran my Letter to the Editor, just in time for the meeting last night, held by Rural Utilities Service, about the Cardinal – Hickory Creek transmission project:

From 4-7 p.m. on Wednesday, December 7th, the Rural Utilities Service (RUS) is hosting a scoping meeting at the Deer Valley Lodge in Barneveld. RUS will again collect scoping comments for its Environmental Impact Study as it decides on a loan to Dairyland Power Cooperative for a share of project costs. RUS held scoping meetings October 31-November 3, 2016 – why more scoping meetings now?

The Cardinal-Hickory Creek transmission project stretches from a substation near Peosta, across the Mississippi River and Wisconsin, near Dodgeville, to a substation near Madison. Last April, as reported in this paper, American Transmission Company’s Jon Callaway reported that the project schedule had been pushed out to 2018 or beyond. The reasons weren’t clear, and should be specified and made part of the RUS record.

Cardinal-Hickory Creek and the under-construction Badger-Coulee transmission lines are MISO’s (Midcontinent Independent System Operator, Inc.) MVP project “five” revealed five years ago in MISO’s MTEEP 11 report. That was 2011, and it was “postponed” in 2016. Why the delay? MISO’s 12.38% rate of return for construction has been successfully challenged in federal court. There’s a glut of electricity where even marketing electricity cross country is not alleviating the industry’s overproduction. MISO’s MVP economic modeling no longer hold under current scenarios. And maybe the delay is that and more!

Now’s the time to tell RUS to consider the economics, need and causes of delay in its financing decision. If delay is right for the project developers, RUS should also delay, and put financing on hold.

Carol A. Overland, Esq.
Red Wing, MN

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

Yup, the southern part of MVP 5 through Iowa and Wisconsin is in the news today:

Dubuque, Cassville or Guttenberg? Transmisison line routes considered.

A while back, the City of Dubuque stood up for its residents and viewshed and all its economic development along the riverfront and said NO to MVP 5 through their riverfront!

From No CapX 2020:

Dubuque says NO to MVP 5 Cardinal-Hickory?

ATC has been gearing up in Wisconsin:

Transmission line proposed

… and from the Dubuque Telegraph Herald, City staff weighed in against MVP 5:

Dubuque: No to Powerline

And then, yes, indeed, in June they DID vote NO, unanimously, 7-0.  Here’s the full story, short and very clear:

Council members back city staff in opposition to transmission line

I’m having one of those “D’OH!” moments…

Remember at the tail end of the ITC case where there was suddenly a claim that the Geronimo wind project in SW Minnesota wouldn’t go on line without the ITC MVP 3 transmission project?  And as suddenly, Dr. Rakow of Commerce reversed his testimony on Sunday night before the hearing started Monday?

Here’s a post about their claim at the public hearing that the Odell wind project couldn’t go online:

ITC Midwest transmission hearing OVER!!??!!

From that post:

Not only were these two Geronimo representatives present, but Gerinomo attorney Christie Brusven was present at the ITC Midwest DEIS Hearings and the Public Hearings. Here she is just after having posed for a photo in front of the tractors:

If this is a concern, is there some reason Odell Wind Project representatives did not raise this earlier?  Is there some reason that ITC Midwest did not raise this in their application or voluminous responses to voluminous Information Requests?

Well,I tried to bring this up at the “Evidentiary” hearing, in quotes because it was such a farce.

The ALJ deems this not relevant.

And now I see that not only is Brusven counsel for Geronimo, but she’s a lobbyist for ITC:

Association data for:

ITC Holdings Corp (Intl Transmission Co)
Krista Tanner, President
100 East Grand Ste 230
Des Moines, IA 50309
Website:www.itc-holdings.com
Association Number: 6092

Lobbyists Registered	Registration Number	Registration Date	Termination Date	Designated Lobbyist
Lisa M Agrimonti	3967	6/11/2012
Frances E Brown	2368	5/22/2009
Christina K Brusven	2685	9/14/2012
Matthew Carstens	2859	9/14/2012
Timothy Iannettoni	3177	3/20/2014
Michael C Krikava	547	6/8/2012
Molly B Murphy	2755	1/12/2012
Thomas R Murphy	999	5/8/2009	Yes
Todd W Schulz	3006	3/20/2013
Kodi Jean Verhalen	2548	6/8/2012

DOH!  And this “new information” about Odell suddenly pops up at the public hearing at the last minute?  Right…

Would it have been any different had it been on the record that the Odell Wind Project attorney was also attorney/lobbyist for ITC?  I doubt it, but… this is yet another example of …

Mystery solved???  I think so… deep breathe… looks like MidAmerican is OK, in compliance.  I’d checked the IUB’s E-22099 docket, and it looked like MidAmerican hadn’t been granted the franchise, briefs had just been filed, but no order.  So I contacted the Office of the Consumer Advocate, and in talking to the Consumer Advocate’s attorney, he explained that the E-22099 docket had been split into two parts.  It’s hard to tell from the docket, everything’s a jumble, but in short, the leg to the east of the Black Hawk substation, which had been granted, is the one they’re building, and the other is to the west of the Black Hawk substation, which has not been granted… yet.  They’ve just finished briefing, earlier this month, and are now waiting for the decision of the ALJ.  WHEW!  They’re checking with the utility to assure they’re only working on the eastern part, but from what I saw, that would be correct — all the brand new transmission towers, and the work in the fields that I saw, was on the eastern side, and on the west, old H-frame structures that have clearly been there a LONG time (and from the filings in E-22099, what the fight is about, whether they can enlarge the easement to double circuit with that existing line).  OK, now I’m satisfied… so moving on to FERC and their transmission adder docket!

This photo is from the road just to the immediate north east of the line, showing the new structures and wires to the east connecting into the substation.

Curiouser and curiouser… Coming up 63 today, just north of Waterloo, I found the MVP 3 and MVP 4 substation… or so it says:

Here’s the map of MPV 3 and MVP 4, and this is the “Blackhawk” substation in Black Hawk County:

To look at the Iowa Utilities Board (IUB) docket for this project (it’s the MidAmerican part of MVP 4) in Black Hawk County, GO HERE TO IUB SEARCH PAGE and search for docket E-22099.

In that docket, MidAmerican argues that the two are not necessarily connected, are not dependent, and yet I’d say the sign at the substation says otherwise.

Here’s what it looks like from above — that’s Hwy. 63, the divided 4 lane to the east, and the gravel roads are Bennington (E/W) and Burton (N/S), this is on Burton, just south of Bennington — and now it’s a lot more built up, one of the larger substations I’ve seen:

From the west, it looks like an old 230k V line on H-frames, but it could be higher voltage.  Straight east from this substation, built after this photo, is a big new 345 kV transmission line, all ready for a second circuit:

Is this depressing or what… sigh…

Remember this map?  The ITC Midwest MN/IA  line is the ITC Midwest part of MISO’s “MVP 3” which on the above map is the red part.  The other part of MISO’s “MVP 3” is to be built and owned by Warren Buffet’s Mid-American Energy, and that’s the green line above.  MISO’s MVP 3 is one of those touted and promoted by our “friends” at Center for Rural Affairs (oh, what people will do for money!)  The tan/orange and blue are what’s known as MISO’s “MVP 4.”  And yes, it’s all connected, moving east to MISO’s MVP 5, the northern part of which is Badger Coulee, from La Crosse to Madison, and the southern part of which is the Cardinal-Hickory Creek (Spring Green?) that runs from MVP 4 to Madison.

The biggest thing at issue here is whether ITC Midwest is a “public service corporation” in the state of Minnesota.  That designation gives it special status, specifically, the door to use of eminent domain, to condemn land for the transmission line.

The second most important issue in his case is the Minnesota assessment for the 17-20 MISO MVP Projects, not just this one little piece of MVP 3.  That assessment is in a MISO tariff that was “approved” by FERC:

Exhibit B_Schedule 26A Indicative Annual Charges_02262014

Here’s the PUC Order for Certificate of Need and for the Route Permit, where they’re ducking the major issues:

Order_Certificate of Need_201411-104931-01

Order_Route Permit_14-0120_12-1337

PUC Staff Briefing Papers have been filed:

Staff Briefing Papers – Motion For Reconsideration_20151-106480-01

Here are the Motions for Reconsideration that were filed:

No CapX 2020 Motion for Reconsideration – Certificate of Need

Jagodozinski_Reconsideration – Route

Responses of Applicant and Commerce DER in Certificate of Need docket (12-1053):

Reconsideration_CoN_Applicant’s Reply_201412-105705-01

Commerce DER Response_201412-105704-01

Response of Applicant in Routing Docket (13-1337):

Reconsideration_Route_Reply_201412-105706-01

The ITC Midwest MN/IA 345 kV line is the pink one above “3” in the map above.

In the Certificate of Need docket, both ITC Midwest and DoC-DER filed Responses, and in the Routing docket, ITC Midwest filed a response.  The Commission will digest it for a while and then there will be a Notice of Commission Meeting at least 10 days prior to the meeting.

Certificate of Need docket (12-1053):

Reconsideration_CoN_Applicant’s Reply_201412-105705-01

Commerce_Response_201412-105704-01

Routing Docket (13-1337):

Reconsideration_Route_Reply_201412-105706-01

Here are the Motions for Reconsideration that were filed:

No CapX 2020 Motion for Reconsideration – Certificate of Need

Jagodozinski_Reconsideration – Route