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

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!

Time for a nap.  Just filed Comments on the USDA RUS’s Environmental Assessment for Dairyland’s Q-1 D South transmission line.  Here’s the EA:

Q1-South_Environmental Assessment

And here are the Comments I filed on behalf of No CapX 2020:

No CapX 2020 EA Comment_July 1, 2016

zzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzzz

Oh, and the interesting thing is that just this morning, I got a copy of the “Briggs Road-La Crosse Tap 161 kV Rebuild Study“  Thank you, Chuck Thompson!

Dairyland’s 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

In today’s La Crosse Tribune!  This is about as detailed an article as there is in today’s news — thanks for the digging, Chris Hubbuch:

Originally constructed in 1950 through farmland, the 161-kilovolt line known as Q-1D South now cuts through back yards and in some cases directly over homes that were built around and under the line as development pushed north along the Hwy. 35 and later Hwy. 53 corridors.

In an environmental assessment filed with the U.S. Department of Agriculture, the La Crosse-based utility argues the line has become unreliable — it’s blamed for two sustained and five momentary outages between 2009 and 2014 — and is critical to serving La Crosse.

Dairyland plans to replace the existing H-frame wood structures with 95- to 115-foot steel poles and a larger conductor that will be capable of carrying more electricity.

The rebuilt line would cross as many as 14 dwellings that were constructed underneath the existing line. There are 42 dwellings and four businesses within the 80-foot right of way.

Despite the concerns of residents who fear negative health and safety impacts from the high-capacity lines, Dairyland argues that alternative routes would be too costly and problematic, and that state codes prohibiting the construction of high-voltage lines over dwellings don’t apply to its rebuild plans.

“In this case on our existing right of way we’re exempt,” said Chuck Thompson, who is in charge of siting and regulation for Dairyland. “We can stay over those structures.”

The nine-mile segment is part of Dairyland’s 70-mile Q-1 line, which connects its coal-fired generators in Alma and Genoa to La Crosse. Dairyland has rebuilt the other segments during the past decade.

Dairyland plans to begin reconstruction of the final segment in September and have the new line electrified in early 2017. It’s expected to cost about $11.9 million.

The project has generated strong opposition from residents who live along the line. Dairyland received 45 public comments when the plans were revealed last summer.

Ann Kathan and her family live in homes built within the right-of-way and have led the charge against the project. She argues the lines expose residents to harmful electronic and magnetic fields, which she fears will be worse with the new conductors.

Kathan also contends that with coal-fired generators making up nearly 90 percent of Dairyland’s generation assets, the company’s long-term viability may be shaky.

“Why would our community support the building of a line that will far outlive us when Dairyland will not?” she asks.

Thompson said the rebuilt line should have lower EMF readings “under normal load” but concedes the new conductors will be capable of carrying more electricity, which would increase EMF.

Dairyland minimizes the health risks of EMF.

“Epidemiological and toxicological studies have shown no statistically significant association or weak associations between EMF exposure and health risks,” the company wrote in its environmental assessment. “While the general consensus is that EFs pose no risk to humans, the question of whether exposure to MFs can cause biological responses or health effects continues to be debated.”

No alternatives

Residents along the line have called on Dairyland to consider an alternate route, but Dairyland argues that is impractical.

The company decided against using one of its own 69-kv routes, arguing that would cost more than twice as much money, create new conflicts with residences and businesses, and result in an additional 17 structures exceeding airport height restrictions.

Dairyland also ruled out using nearby Xcel Energy towers because running lines on the same poles would increase the chances of both going down at the same time and because the cooperative might be forced to buy out residences under the Xcel route.

Burying the line would cost more than $100 million, according to Dairyland’s estimates.

Dairyland also notes that rerouting its line would require permission from the state’s Public Service Commission, which could take up to five years and add to the project costs.

Carol Overland, a Minnesota attorney who fought against two recent high-voltage transmission projects — CapX2020 and Badger-Coulee — says Dairyland is offering conflicting readings of the law in order to “have it both ways,” saying it is exempt from PSC regulations in some cases but subject to them in others.

“It’s questionable,” she said. “(But) who’s going to question it?”

She also contends Dairyland broke the Q1 project into segments — in violation of the National Environmental Protection Act — in order to avoid having to do a more in-depth environmental impact study.

Because Dairyland is replacing an existing line, the utility does not need state or federal approval for the project.

But in order to receive low-interest financing through the USDA, Dairyland must submit an application to the Rural Utilities Service, which requires the environmental assessment. Public comments on that document are being accepted through Wednesday.

Zoning changes

The only other hurdle for the project is height restrictions around the La Crosse Regional Airport.

The existing ordinance limits the height of structures within three miles of the airport using a grid of 40- to 160-acre squares that climb like steps away from the runways. An aeronautical study is required for any proposed structure that would exceed that limit.

With more detailed geographical data provided by Dairyland, the new ordinance establishes higher height limits in a contour pattern — more like a ramp.

Airport Director Clinton Torp said the new height restrictions more accurately follow FAA guidelines and will cut down on the number of permits and variances the city must consider for structures that exceed the height limit.

Under the new ordinance, Dairyland estimates it will need variances for only three — rather than 24 — of its towers.

Torp said once the city incorporates Dairyland’s data into its GIS system, landowners and developers will be able to use an online map to see the exact height limit for any spot within the airport zoning district.

A committee of the La Crosse Common Council is scheduled to consider the ordinance change July 5.

Kathan said Dairyland has used its financial power to “side step” local ordinances.

And a prior article on the Dairyland Q-1 D South line:

Residents worried by plans to rebuild transmission line, amp up capacity

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.

AS you scroll down, keep in mind the tremendous job that the City of Onalaska did presenting their case in the Badger Coulee transmission docket (go HERE and search for docket 05-CE-142, and look for Onalaska filings).

Grace – Direct Testimony

Tuesday night, the Onalaska Plan Commission took up the revised Comprehensive Plan.

Onalaska Comprehensive Plan Final Draft – 12-07-2015

Here’s where you can check out the new Comprehensive Plan (search for “transmission” and you’ll find not much):

City of Onalaska 2015 Comprehensive Plan Page

The current Zoning map (click for larger version):

Future:

Do you see any transmission lines on that map?  Any pipelines on that map?  The City doesn’t have a map of transmission lines, or pipelines, yet it’s a prominent feature of Onalaska, just drive up Hwy 35 or Hwy 53 and you’ll see what I mean.  The City Land Use & Development Director said in the meeting that they don’t have one, it would be very difficult to put together and that this info can be regarded as “proprietary.”  Not quite, it could be “CEII” information, but when you see it driving down the road, when you look at google and there it is, there’s no reason the City can’t draw a line on the map!

There’s a lot of transmission through Onalaska, lining both sides of the highways, in the middle of the city bottlenecked in-between the river and the bluffs (like Red Wing), and it runs right through the heart of the city.  Here’s ATC’s “map” of transmission:

Here’s WI-PSC’s map:

As you can see, it’s not rocket science to put a map together of transmission through Onalaska and its potential expansion areas.

Dairyland is wanting to tear down its old line on the west side of Highways 53 and 35 and virtually double the height of the towers and the capacity.  That’s not updating or maintenance, that’s “tear down the old line and build a new one” construction.

NOW is the time, because there’s not yet a Dairyland application, and because Xcel’s line on the east side of Highways 35 and 53 is also old, they’re going to want to “upgrade” soon too.  The routing of transmission through Onalaska in light of Wisconsin’s adoption of its Electrical Code which prohibits construction under a line, means that new construction should be carefully reviewed.  And right now, rebuilding, tearing down and new construction of something much bigger, shouldn’t be allowed over and next to homes and businesses.  What to do?  It’s a narrow area with a lot of transmission!  But this is what “planning” is all about.  Looking into the future and figuring out what they want the City to look like, how they can address the extreme impacts of transmission, and if they can minimize or mitigate these impacts.  Here’s an example of it running through people’s back yards, stars indicate pole placement in people’s back yards, and the white/red lines are access roads through people’s back yards!

On behalf of No CapX 2020, I sent the Planning Commission and City Council these comments:

NoCapX2020 Comment_OnalaskaCompPlan

At Tuesday’s meeting, there were few commenters, and they quickly wrestled with the issues raised, and sent it back to the Committee for consideration of transmission issues and impacts.

THANK YOU, ONALASKA PLAN COMMISSION!

wow… ohh my.. that’s the complete public notice.

And what they provided for information, some new maps and a “fact sheet.”

• Briggs Road to La Crosse Tap (Q-1D South) 161 kV Rebuild Project – Fact Sheet
• Briggs Road to La Crosse Tap (Q-1D South) 161 kV Rebuild Project – Corridor Map

Send your comments in today to:

• Chuck Thompson, Manager, Siting & Regulatory Affairs, Dairyland Power Cooperative, 3200 East Avenue South, La Crosse, WI  54602-0617, or via email at cat@dairynet.com  (608) 787-1432.

• Dennis Rankin, Engineering and Environmental Analyst,  USDA RUS, 1400 Independence SW, Mailstop 1571, Washington D.C., 20250-1571, or via email at dennis.rankin@wdc.usda.gov    (202) 720-1953

FYI, here’s what I sent in:

NoCapX2020_Comment_October 12 2015

And previously:

NoCapX2020_Q-1D South_Comment_9-25-2015

For more info, just scroll through or search No CapX 2020 for the recent “Q-1” and/or “Dairyland” posts.

SUCCESS!!!  But… but… but only extended by 10 days…  HUH?  We still don’t have much to go on here, and major details like the capacity of this project, well, they’re still leaving us in the dark.

Here’s the new info posted on the Dairyland Power Cooperative site:

• Briggs Road to La Crosse Tap (Q-1D South) 161 kV Rebuild Project – Fact Sheet
• Briggs Road to La Crosse Tap (Q-1D South) 161 kV Rebuild Project – Corridor Map

Compare the posted Corridor Map with the ones I’d received a couple weeks ago, note how much is M-I-S-S-I-N-G!

Appendix_A_Q1D_South_Sheetmap_150616_June 2015

The most obvious thing missing is the access roads, every single one of them.  What else?

And look what’s added.  I think the big difference is that this is “environmental” information, based on the subjects they listed in their first notice, like prime farmland, wetlands, etc.  It’s not the construction/technical layer.  So by looking at these new maps, we get the picture of what they think impacts are, and we can at least get a feel for that.

On the first map, there’s a brown area along the river/creek, but I can’t tell what color that would be on the legend… yellow?  On the third map, there’s a huge section with many different markings, covering the Wildlife Refuge.  H How would 95 – 115 foot tall towers this close to the ledge of the drop off into the Wildlife Refuge not have an impact on the protected (and unprotected!) migratory birds in this corridor?  What does the greatly increased tower height do to the viewshed from below on the Missisisppi?  They’re lowering towers and configuring horizontally for the La Crosse River Floodplain, so doesn’t this mean there are avian considerations?  And what about the Airport Overlay that limits structure height?

And check out this “Fact Sheet.”  Briggs Road to La Crosse Tap (Q-1D South) 161 kV Rebuild Project – Fact Sheet

Dairyland Power Cooperative says:

“Can you tell me about the Project?”  Well, not much, this is a two pager.  Focus is on using existing RoW.  Note they do point out existing and temporary access routes.  I would guess that this is something they’d have to have easements for… do they have easements?

“Why is the Project needed?”  They raise reliability problems, but these were addressed in the Badger Coulee, and the record there says Badger Coulee addresses these problems.  Oh, but it’s also impacting the fiber optic service on these structures.  Hmmmm, fiber optic.  Leased to who and for how much?  I don’t see any information on the fiber optic upgrade that would logically occur with upgrade of the electrical part of this line.  DISCLOSE PLEASE!

“What if the line is not rebuilt?”  This isn’t a rebuild, this is an upgrade.  Higher towers, from 45 – 85 feet now to 95-115 feet.  BIG DIFFERENCE!  Capacity?  Who knows, they’re not telling me, but folks, I have some ideas, based on the MISO disclosure of use of 795 ACSS conductor.  This is conjecture, because I’m still waiting for information from Dairyland, with the 437 MVA Peak taken from prior docket info, and the 84 MVA Average as a low-ball number (because they always understate capacity).  Click on table for a larger version that’s not cut up by the sidebar on the right:

“How are environmental impacts considered?”  As they state, this is a financial project, they’re doing this for financing.  Financing approval is a “major governmental action.”  Think not, Dairyland?  RUS?  Let’s discuss it in the alley!  Dairyland’s blurb states that “RUS has determined that the project would require the preparation of an Environmental Report (ER) to analyze potential impacts to the natural and human environments.”  ER?  How does this not require an EIS?  How is an ER compliant with NEPA?  How is it that Dairyland is allowed to segment these Q-1 projects out and that Marshland – Briggs Road required a full blown EIS and this doesn’t?  IT’S ALL ONE PROJECT, this upgrading the Q-1 line!

Read their new documents carefully, and take a good look at the new maps, comparing with the other ones.  What’s your take?

As always in this, take a few seconds and ask for more information, and when you’ve reviewed this stuff disclosed today, send comments to:

• Chuck Thompson, Manager, Siting & Regulatory Affairs, Dairyland Power Cooperative, 3200 East Avenue South, La Crosse, WI  54602-0617, or via email at cat@dairynet.com  (608) 787-1432.

• Dennis Rankin, Engineering and Environmental Analyst,  USDA RUS, 1400 Independence SW, Mailstop 1571, Washington D.C., 20250-1571, or via email at dennis.rankin@wdc.usda.gov    (202) 720-1953

++++++++++++++++++++++++

Here’s the full blurb from Dairyland’s Chuck Thompson, hot off the press this morning:

Dairyland Power Cooperative is hereby extending the 30-day comment period related to prime farmlands, farmland of statewide importance, 100-year floodplains, wetlands, and other comments for the Q-1D South 161 kV rebuild.  Under this expanded period, comments should be submitted in writing to Dairyland Power Cooperative within 10 days of the publication of this notice.

Dairyland Power Cooperative, 3200 East Avenue South, La Crosse, WI 54602-0817, is planning to rebuild approximately nine miles of 161 kilovolt transmission line in La Crosse County (Q-1D South Project).  The Q-1D South Project begins just south of the Briggs Road Substation near the Village of Holmen and ends at the La Crosse Tap south of the La Crosse River near Keil Coulee Road. Constructed in the 1950s, the line is now in poor condition and reaching the end of its service life.  The rebuild will occur along the existing 161 kV alignment within the existing right-of-way.  It has been determined that the Project, as proposed, will be located in a prime farmlands, 100-year floodplain, and wetlands. The Project will occupy 126 square feet of prime farmland, 12.6 square feet of farmland of statewide importance, 63 square feet of 100-year floodplain, and 50.4 square feet of wetlands.

Dairyland Power Cooperative believes that there is no practicable alternative that will avoid locating the Project in prime farmlands, farmland of statewide importance, 100-year floodplains, and wetlands.  Additional information on the project can be found at:  http://www.dairynet.com/power_delivery/project_updates.php for sheet maps and a fact sheet.

Copies of all comments received will be forwarded to the U.S. Department of Agriculture Rural Utilities Service for consideration prior to approval of financing assistance or taking other Federal action related to the Project.

Send your comments to:  Chuck Thompson, Dairyland Power Cooperative, 3200 East Ave South,
La Crosse WI 54602 or email your comments to cat@dairynet.com.