No CapX 2020

Clean Wisconsin has woken up, but why?  What got their attention sufficient to push a “Request to Intervene Out of Time” recently?

Clean Wisconsin Request to Intervene Out of Time

Their vacuous Request sure didn’t say anything, so I fired off an Objection, because I want to know what the “new information and issues have arisen” are that they’re claiming.

Objection to Request of Clean Wisconsin

So they filed this, which is as vacuous:

Response to NoCapX 2020 Objection

And so then I asked again for something of substance:

Reply to Response to No CapX 2020’s Objection to Clean Wisconsin’s Intervention Out of Time

We shall see…

And yes, we are seeing, the emails back and forth, to and fro, are interesting, and what’s missing is even more interesting… there has yet to be a simple disclosure of the “new information and issues” that “have arisen” spurring the intervention and identification of “good cause” why the intervention is late, two, nearly three months late!  Why is this so difficult?

Here’s what the PSC considers when there’s a late request to intervene:

PSC 2.21  Intervention.

(1)  Intervention by right. A person whose substantial interests may be affected by the commission’s action or inaction in a proceeding shall be admitted as an intervenor.

(2) Permissive intervention. A person not satisfying the criteria of sub. (1) may nevertheless intervene in a proceeding or docket if the person’s participation likely will promote the proper disposition of the issues to be determined in the proceeding or docket and if the person’s participation will not impede the timely completion of the proceeding or docket.

(3) Procedure. A person requesting intervention in a proceeding shall file a request no later than 60 days after the issuance of the notice of proceeding, or within a different time set by the administrative law judge at the final prehearing conference. A person requesting intervention in a docket shall file a request no later than 60 days after the opening of the docket, or within a different time set by the commission at the time it opens the docket.

(4) Intervention out of time.
(a) If a person fails to request intervention within the time prescribed in sub. (3), the person must request to intervene out of time. In acting on such a request, the commission or administrative law judge may consider all of the following:
1. Whether the requestor had good cause for failing to file the request within the prescribed time.
2. Whether any disruption of the proceeding or docket may result from permitting intervention.
3. If any prejudice to, or additional burdens upon, the existing parties may result from permitting the intervention.

And apparently they don’t like the “cartoons.”  Oh… OK… whatever…

There’s also been some things happening on the Fargo route.  The decision came down some time ago, June 23, 2011, with some additional time for Reconsideration because the state was shut down.  Route changes first.  Xcel filed a HUGE packet of minor route changes, minor in the cosmic realm of things, but awfully important to those affected:

Xcel Route Adjustments:

Cover Letter Requesting Amendment 20119-66518-01

2 – 3 20119-66518-02

4- 5 20119-66518-03

6 8 9W 20119-66518-04

9C 20119-66518-05

11-13 20119-66518-06

15 20119-66518-07 (at issue in Undersander filings below)

And here are the Motions for Amendment of Permit, PUC’s Rejection as untimely, and Undersander’s Response:

Undersander 20119-66344-01

Eikmeier 20119-66344-02

Undersander2 20119-66344-03

Weisbrich 20119-66344-04

Richert O’Neil 20119-66344-05

PUC Haar’s Letter- rejecting as untimely:

PUC Letter to Undersander, et al 20119-66560-01

And then the plot thickens:

Undersannder Reply to PUC’s Haar 20119-66620-01

Will keep you posted with any additional filings!  I want to see what that “AG investigation” means!

Whew, been too long since I’ve posted someting.  Had a computer crash and two briefs due, and trying to get the house done before fall, eeeeeeuw, snorting way too many woodwork stripper fumes these days!!!

One down, and the next room is almost done.

Briefs are in on the Hampton-LaCrosse line in Minnesota, and Reply Briefs are due soon:

NRG – Initial Brief

Oronoco – Initial Brief

Xcel – Initial Brief

Agency f/k/a MOES – Initial non-Brief

Demand is down, ja, we know that, you betcha… and it seems that words is finally getting out!

And we know those utilities and how badly they want to “prove” need, but hey, bullshit by any other name smells as sweet!

Reserve margins are at an all time high and projected to get higher, from the 2010 NERC Long Term Reliability Assessment:

And then there’s the MISO State of the Market Report agreeing:

Including all demand response capability, we estimate a planning reserve margin in the range of 28 percent to 37 percent depending on the summer capability of the resources that are assumed.  These margins substantially exceed MISO’s planning reserve requirements that have recently increased from 15 percent to 17 percent.

p. iii, Ex. Summary, 2010 MISO State of the Market Report.    Increased required reserve margins?  Hmmmmm, part of their hype on transmission build-out was that it would DECREASE reserve margins… but hey, they said “competition would decrease prices” didn’t they… and they ARE, but not for US, cost of electricity is only lower for those elsewhere, and not for those of us in a “low cost” state.  Consider Xcel’s request to raise electric rates 37.5% over the next 5 years…

And here is Associated Press saying what we already know…

Shocker: Power demand from US homes is falling

By JONATHAN FAHEY, AP Energy Writer – 23 hours ago

NEW YORK (AP) — American homes are more cluttered than ever with devices, and they all need power: Cellphones and iPads that have to be charged, DVRs that run all hours, TVs that light up in high definition.

But something shocking is happening to demand for electricity in the Age of the Gadget: It’s leveling off.

Over the next decade, experts expect residential power use to fall, reversing an upward trend that has been almost uninterrupted since Thomas Edison invented the modern light bulb.

In part it’s because Edison’s light bulb is being replaced by more efficient types of lighting, and electric devices of all kinds are getting much more efficient. But there are other factors.

New homes are being built to use less juice, and government subsidies for home energy savings programs are helping older homes use less power. In the short term, the tough economy and a weak housing market are prompting people to cut their usage.

(more…)

The new “need” report is out, Xcel Energy filed it yesterday, in WISCONSIN, and it’s a doozy, reverse engineering, shifting nuts in the shell game, and pinning the tail on the moving donkey..

Xcel Supplemental Need Study – August 2011

When I got to p. 34, well, I pert near blew a gasket, because it’s more made up numbers, and if you look at just a few simple documents for LaCrosse “need” that THEY filed:

• MN Certificate of Need Application, Vol. 2, Appendix C-1; then the
• (for Rochester) MN Certificate of Need, Testimony of Amanda King, Direct Sched 2, filed May 15, 2008; and then the
• Wisconsin CPCN Revised numbers (redlined application, p. 2-40 & 2-41), June 2011; and top it off with yesterday’s
• Xcel Supplemental Need Study – August 2011, p. 34-35

Here’s what it looks like on a spreadsheet (I’ve not added in the King Direct Sched 2 for Rochester yet):

Comparison of Certificate of Need and CPCN substation peaks

And this filing is not just about LaCrosse “need” that doesn’t hold up under scrutiny.  A lot of this, in my view the more important pat, is about a shift in rationale/justification to market desires, laid out in the MISO “Benefits” report (check “Conclusions” on p. 14 and at end):

ICF – MISO Benefits Analysis Study

It’s also clear here, found googling the “new” MVP transmission cost allocation absurdity:

MISO – MVP transmission powerpoint – August 2011

What struck me was this succinct description of what’s happening in transmission – take a look at slide 4 f the powerpoint:

Conditions Precedent to Increased Transmission Build

Before transmission is built a number of conditions must be met

– Increased consensus on energy policies (current and future)

– A robust business case that demonstrates value sufficient to support the construction of the transmission project

– A regional tariff that matches who benefits with who pays over time

– Cost recovery mechanisms that reduce financial risk

It’s all about market, it’s all about transfer capability/capacity.  Well DUH, but they’re out and out saying it here.  And an important part is also connected here on the first page:

As outlined below, the presence of a 345kV line from Minnesota into LaCrosse compbined with the expected LaCrosse to Madison 345kV line will provide significant regional benefits that will not be achievable with the completion of an alternate project.

DUH!  On to p. 4:

Transfer study analysis indicates the additional capacity, depending on the eastern termination, could be as high as 1200 MW over current system levels… This 1200 MW increase is not realized if a lower voltage alternative is constructed initially.

DUH! And it gets even more hilarious on p. 25:

For 2019, CapX 2020 additions, including the Hampton-Rochester-LaCrosse 345kV transmission project and the Brookings County-win Cities 345kV project, relieve the Minnesota trapped generation identified in the 2010 and 2014 models.  Congestion in SE Wisconsin expands geographically to all of eastern Wisconsin and the Upper Peninsula of Michigan.

DUH!

This filing refers to the “State of the Market Report for the MISO Electricity Markets” published in June 2011.  Here it is, have fun:

2010 MISO State of the Market Report – FINAL

And as you’re reading it, ask what precisely congestion has to do with reliability, and why we’re using market concepts to drive build-out of transmission.  There’s no relation between FERC economic policy and NERC reliability criteria, the economic market drivers are not related to state need and routing criteria — market wants are not “need.”  Makes me want to puke!