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

A number of Comments have been filed regarding the Draft Environmental Impact Statement prepared by the Wisconsin Public Service Commission for the CapX 2020 Hampton-Rochester-LaCrosse transmission project:

Applicant Comments November 28, 2011

Applicants Supplemental Comments

NoCapX 2020 DEIS Comments

U-CAN – Mississippi River Crossing Comments

US Fish & Wildlife DEIS Comments

WisDOT DEIS Comments

Public Comments 1 (ERF filed in batch)

That’s all I have found specifically ID’d as DEIS Comments, will dig through ERF filed comments to see if there’s more.  There are a lot deemed “Public Comments” and to see these, go to www.psc.wi.gov and scroll down to the place to search for a docket, and search for 05-CE-136.

An  eagle has been injured at the transmission line crossing the Minnesota River — where CapX 2020’s Brookings-Hampton routing permit said it could cross.

Just in, from the Belle Plaine Police Department’s Facebook page:

Thank you to City Council member Cary Coop for notifying us of an injured eagle that had struck some power lines, by the Minnesota River about 1/4 mile west of the Highway 25 bridge. We were able to respond with him and locate the eagle which appeared to be breathing, but seriously injured. Critter Getters was called to respond and we assisted in transporting the eagle through the woods and to awaiting transport. The eagle was brought to the Raptor Center for care. I just received word that they will be able to rehabilitate the eagle and it will make a full recovery. To us this is important, as we wear the symbol of the eagles wings on all our badges which stand for freedom and justice and the readiness to defend it for all.

Thursday, December 29, 2011 at 1:00 p.m.

PUC – 3rd Floor Large Hearing Room

121 – 7th Place East

St. Paul, MN

Got that?  Now QUICK!  QUICK – put together your comments and let the PUC know just what you think of the Power Plant Siting Act.

Minn. Stat. Chapter 216E – Power Plant Siting Act

Here’s what they suggested for last year, because this year, no suggestions, so let’s recycle and reuse:

l. In Chapter 216E, the Legislature directs the Commission to locate large electric power facilities so that any siting is orderly, efficient and compatible with environmental preservation. How well do the Commission’s procedures and practices meet these mandates?

2. How well do the regulations found in Minnesota Rules Part 7850 meet the mandates of Chapter 2l6E? Which rules, if any, should the Commission consider revising?

3. How well do the regulations found in Minnesota Rules Part 1405 meet the mandates of Chapter 216E? Which rules, if any, should the Commission consider revising?

Comments are invited through presentation of oral or written statements.

Written comments are due 4:30 p.m. on February 1, 2012 – REFERENCE DOCKET E999-/M-11-324 and send to:

And here are comments from past years – for guidance, check these out:

2000 Summary of Proceedings

2000 Report EQB

2001 Summary of Proceedings

2001 Report EQB

2002 Summary of Proceedings

2002 Report to EQB

2003 Summary of Proceedings

2003 Report to EQB

2004 Summary of Proceedings

2004 Report to EQB

2005 Report to PUC

2006 Report to PUC – Docket 06-1733

2007 Report to PUC – Docket 07-1579

2008 Report to PUC – Docket 08-1426

2009 Report to PUC – Docket 09-1351

2010 Lipman Report to PUC – Comments Summary – Docket 10-222

Written Comments – Linked

For Hearing Exhibits, go to www.puc.state.mn.us, search docket 10-222

Here we go, comments filed:

NoCapX 2020 DEIS Comments

U-CAN Comments – Mississippi River Crossing

Applicants Supplemental DEIS Comments

WisDOT Comments DEIS

Can’t find any others in the inbox or filed…

Quick, fire off some comments on the Wisconsin Draft Environmental Impact Statement.

You can find the document at the ERFsite – go to www.psc.wi.gov, scroll down the screen to where you enter a docket number, and enter “05-CE-136” and then scroll down to the DEIS.  Scroll down to November 8, 2011, for the pieces of the DEIS.

Most important is the narrative, and Volume 2 is the maps, they’re quite large.

Here are most of the chapters, I had trouble with Chapter 8, so it’s not there, that’s the Q-1 Galesville Route, you have to go to the ERF site, as above, to get it.

Chapter 0 – Executive Summary

Chapter 1 – Overview – Regulatory

Chapter 2 – Need

Chapter 3 – Potential System Solutions

Chapter 4 – Mississippi River – Holmen Description & Alternatives

Chapter 5 – Environmental Impacts and Mitigation

Chapter 6 – New Briggs Substation

Chapter 7 – Q-1 Hwy 35  Route

Chapter 8 – trouble downloading

Chapter 9 – Q-1 Hwy 88 Route

Chapter 10 – Arcadia Route

Chapter 11 – Ettrick

Chapter 12 – Summary and Comparison of Impacts

I had high hopes for this DEIS.  Silly me.

An important but simple thing to note in your comments — THEY’VE GOT THE NAME WRONG!!!!  As in Minnesota, the Applicants applied for a project called the “Hampton-Rochester-LaCrosse Transmission Project.”  That’s easy to remember, it’s the start, middle and end of the line they’re proposeing.  But look at the DEIS – it’s entitled:

Alma-LaCrosse 345kV Transmission Project

SAY WHAT?!?!?!?!  Where does that “Alma-LaCrosse” come from — there’s not even a substation planned for Alma! That’s not the name of this project!

And it gets worse from there.  Here’s a part that really sticks in my craw:

The applicants’ decision on the proposed crossing was reinforced during the state of Minnesota EIS scoping process in the spring of2010.  The Minnesota Office of Energy Security (OES) convened two advisory task forces and a public scoping comment period on the issues and route alternatives that should be evaluated in the Minnesota EIS.  If the comments from the task forces and the public did not indicate that the LaCrosse crossing should be reevaluated in addition to the Alma crossing, then the scope of the Minnesota EIS would include the Alma crossing as the only crossing. The OES scoping decision in August 2010 confirmed the Alma crossing as the one to be carried through the two states’ review processes.  See appendix D, the Executive Summary of the Minnesota EIS, page 1 .

Wisconsin PSC DEIS, p. 36 (emphasis added).

HUH???   There is NO basis for this paragraph, ZERO.  It’s utterly false.  The Applicant’s decision to present only one option for a Mississippi River crossing was NOT “reinforced,” it was loudly challenged, and over and over and over in the Scoping Comments and by the Task Force, there were demands that there be more than one option.  And it gets worse:

If the comments from the task forces and the public did not indicate that the LaCrosse crossing should be reevaluated in addition to the Alma crossing, then the scope of the Minnesota EIS would include the Alma crossing as the only crossing.

Come on, folks, what’s the basis for this!??!  I was there, and it just doesn’t exist.   The Task Force “facilitator” tried to boot me out of the meeting when a Task Force member asked why there was only one Mississippi River crossing, and I dared, DARED, to state that USDA’s RUS is reviewing 3 Mississippi River Crossings, at Alma, Winona and LaCrosse.

I’m asking you to leave…

…sigh… so now, what do we comment on?

I’d focus on noting whether all potential impacts are laid out, and look for EVALUATION, and ANALYSIS, not just a laundry list of what the impacts might be.

To make this a little easier, check this out:

COMMENT FORM

Now get to work!

Here’s what the

Just got word that Notice for the USDA’s RUS Public Meetings on the Draft Environmental Impact Statement is in the Zumbrota Shopper, and that the DEIS is released.

HUH?  I looked at the link in the notice… nada… turns out, per USDA’s Stephanie Strength, “The Federal Register notice and posting of the DEIS are not scheduled until Friday.”

So hold your horses!

The Comment period is open for 45 days following publication of US EPA’s notice… probably Friday too.

Also, there’s nothing in the Notice that says where to send Comments.  It says for further info or to request a copy of the DEIS to contact Stephanie Strength:

Stephanie.Strength@wdc.usda.gov

Public meetings are scheduled for evenings of the week of January 9, all week, with an “open house” from 5-6 p.m. and a “discussion period” from 6-8 p.m.

January 9, 2012, 5-8 p.m.
Alma High SchoolGym
S1618 State Rd 35
Alma,WI

January 10, 2012, 5-8 p.m.
Wanamingo Community Center
401 Main Street
Wanamingo, MN

January 11, 2012, 5-8 p.m.
Cannon Falls High School Cafeteria
820 Minnesota St
Cannon Falls, MN

January 12, 2012, 5-8 p.m.
American LegionHall
2153rd St SW
Plainview, MN

January 13, 2012,  5-8 p.m.
Centerville/Town of Trempealeau Community Center
W24854 StateRd 54/93
Galesville, WI

Every time I try to PDF the Notice, Firefox crashes.  Here’s what I’ve got, it’s hard to read.  When I get a better copy, I’ll post that.

Sort of legible Notice, p. 1

A not so legible Notice, p. 2

Here it is, MTEP 11, the Midwest Transmission Expansion Plan for 2011 (CLICK HERE, look on lower right), and it’s in the news too.  The main report and some appendices:

MTEP 11 – Draft Report

MTEP Appendices A B & C

MTEP 11 Appendix A-1_2_3 – Cost Allocation

Page listing all the Appendices

MTEP Appendix e52 Detailed Proposed MVP Portfolio Business Case

Please take note that this includes not only the CapX 2020 Brookings-Hampton line (#2 on map), but also the LaCrosse-Madison line (#5 on map), the one they need to build or they’ve got a lot of system instability goin’ on.

From my perspective, the most important thing to be aware of is that MTEP 11, and the MTEPs that preceded it, are about the shift to economic dispatch and development of the electric market.  At the outset, MISO studied potential benefits of this shift, and found massive economic benefits, of which they speak in their press release.  The economic benefits are realized by optimizing use of lower production cost generation, and in their own words, to “displace natural gas with coal.”  Don’t believe it?  Read this study that ICF did for MISO:

ICF – Midwest ISO Benefits Analysis

This is the worst possible result for those of us who breathe, and means that tens of thousands of landowners will have very high voltage transmission lines on their land, taken from them by eminent domain.  These projects, almost all of the MTEP projects, are not about electric reliability, they’re “need” is to deliver market transactions of electric generation from any “point A” to any “point B,” and this is a private interest, a desire for market profits, and not a public interest.

Another issue looming is “what does MISO ‘approval’ mean?”  Transmission lines are regulated by states, individually, and there is a movement to strip states of their regulatory authority and transfer that to federal entities.  Look no further than Obama’s transmission “fast track” proposal, naming one of the CapX 2020 projects!  States must make their energy regulatory decisions in an open, transparent process and based their decisions on ratepayer and public interest.  That focus is not present in federal top-down edicts.  States’ rights are at issue and we need to keep on our toes so this power shift doesn’t slide through.

And it’s not “just” the ICF report above, that’s it’s all about coal is clear from prior press.  Here’s an important sentence, quoting GRE’s spin-guy Randy Fordice — explaining what we all know, that the MISO effort to get the “benefits” of displacing natural gas with coal:

They now consider the line to be a multi-value project since system reliability- and service to existing substations and existing fossil fuel plants- are also benefited, he said.

Coal with benefits, yesiree…  Gotta hand it to Fordice for being honest!

Here it is in the news:

$730M transmission line to harness South Dakota wind

Wind?  NOT!  Recall that honest quote from Fordice, above!

Power line projects advance, despite opposition

And in the St. PPP:

Power line project to Dakota County clears last hurdle

By Leslie Brooks Suzukamo
lsuzukamo@pioneerpress.com
Updated: 12/08/2011 10:22:15 PM CST

The operators of the Midwest’s power grid on Thursday approved a $730 million high-voltage transmission line from Brookings, S.D., to the town of Hampton in Dakota County.

The transmission line is one of 17 big projects given the green light by Midwest Independent Transmission System Operator, better known as MISO, in an initiative designed to strengthen the grid and speed up the development of renewable wind energy.

Called the Brookings Line, the 230-mile project could carry wind energy from the Dakotas and southern and western Minnesota, say a group of regional utilities led by Xcel Energy and Great River Energy, who back the project.

Opponents who live along proposed path of the 345-kilovolt line have questioned the line’s necessity. Some of have expressed concern about their health by living close to such high voltage; others say the line will become a conduit for coal power from the Dakotas instead of a green project carrying wind power.

But the Minnesota Public Utilities Commission voted to go ahead with the project in April 2009, and the Minnesota Court of Appeals upheld that decision a year later.

The line has received all needed permits from the Minnesota Public Utilities Commission, said Randy Fordice, a spokesman for CAPX 2020, a consortium of regional utilities. Construction could begin next April, Fordice said. The project is an example of wind transmission projects being drawn up across the Midwest that MISO is trying to accommodate.
These projects are envisioned to help states meet their standards or targets for adding renewable energy such as wind power to their energy mix in order to reduce dependence upon coal-fired power plants that spew emissions that are unhealthy and linked to climate change.

Minnesota has the region’s strongest renewable energy mandate, requiring its utilities generally to provide 25 percent of their energy from renewables by 2025.

The mandate puts a heavier burden upon its largest utility, Minneapolis-based Xcel Energy, requiring it to derive 30 percent of its power from renewables by 2020.

The unanimous vote by the MISO board in Carmel, Ind., marked the first time the grid operator took into account the policy needs of states, said Beth Soholt, executive director of Wind on the Wires, a St. Paul advocacy group for wind energy.

“I would call it historic,” she said. Before this, MISO primarily focused on the reliability of the grid and not concerned with the kind of power transmitted over it, she said.

MISO’s approval will make it easier for Minnesota to export wind energy in the future, MISO vice president of transmission asset management Clair Moeller said in a press conference.

Although the MISO board’s decision approves 215 projects worth $6.5 billion, the 17 green power projects like the Brookings line account for $5.2 billion of the cost.

Ultimately, ratepayers will pay for all these projects, but so-called multivalue projects like the Brookings Line carry a tariff that spreads the cost across MISO’s 12 states and the Canadian province of Manitoba.

So, instead of Minnesota being saddled solely with the cost of the Brookings Line, states as far away as Michigan will help shoulder the burden. And vice versa.

The MISO board reasoned that all states benefit from these projects, because they strengthen the grid, shoring up aging infrastructure. They also allow states to add renewable energy and clear out congestion on the lines so states can have better access to cheaper electricity when they need it, which makes the grid more efficient.

“It’s hooking up Midwest power to meet Midwest needs,” Soholt said. The grid MISO operates stretches from the Dakotas to Michigan and Manitoba to Indiana.

The projects “will allow the region to build a robust transmission grid that will bring reliability and economic benefits to the region as well as smoothing the way for the Midwest to tap its considerable wind resources,” said Rob Gramlich of the American Wind Energy Association.

In other states, some projects will next have to undertake lengthy regulatory approval.

Last year, some states in MISO had balked at the new Multi-Value Projects tariff, saying they were too far from Minnesota and the Dakotas to benefit from their wind power on the grid.

But other Midwestern states have already started tapping into the prairie winds. Indiana Power and Light Co. has a purchase agreement with a wind farm in Lakefield in southwest Minnesota.

Back from Madison, a long long day, I just don’t do mornings well, 4:45 a.m. sucks.  Anyway, here’s the Prehearing Order for the CapX 2020 Hampton-Rochester-LaCrosse transmission line, hot off the press:

Prehearing Conference Memo – December 6, 2011

The most important part of this, well, the part that sticks out for me, is that the “technical” (evidentiary) hearing is at most one week long.  The Certificate of Need in Minnesota took 5 weeks, maybe more, and each routing proceeding took 2 weeks, and here we’re doing both in one week?  I just don’t see how that can be done.

Next are public hearings, and that will be on March 13 and 14, 2012, in only two locations, with afternoon and evening sessions.

And check this — there’s this point about cross-examination of witnesses, and the judge said “presenting a direct case on cross isn’t going to work.”  That was in a discussion of “At Hearing” point #4:

4. Limit cross-examination of a witness by the length and scope required to reasonably investigate matters with respect to the testimony of that witness. To investigate beyond these parameters requires the party to have followed the applicable pre-hearing process for compelling the witness to appear at hearing.

OK, so let’s look at the “pre-hearing process for compelling the witness to appear at hearing,” that’s Prehearing point #4 and 6a:

4. Any party who compels a witness to appear at hearing shall create a volume of written testimony for that witness in the form of either a deposition or interrogatory. This requirement shall not apply if the party receives consent of the other parties and Commission staff prior to the deadline to file such testimony.

6.a. The volume of written testimony for any witness being compelled to appear, and corresponding exhibits, by the deadline to file rebuttal testimony.

I can see a logistical plus for us on this, filing ahead of time, but this looks to me to be the death of live testimony under cross.  And LOTS of data requests — and they (ATC particularly) are not too happy about what’s been sent thus far.  Oh well, here we go!

It’s official – December 29th is the Annual Hearing on the Power Plant Siting Act.  Written Comments are due by 4:30 p.m. on February 1, 2012.

MPUC – Notice of Annual Hearing – Power Plant Siting Act

First, what’s the Power Plant Siting Act?  It’s the state chapter of statutes and associated rules that govern how we site power plants and transmission lines in Minnesota:

Power Plant Siting Act – 216E

The PPSA Annual Hearing has also included references to wind siting, which is 216F.  The PSA includes “Buy the Farm” (216E.12, Subd. 4) which is under siege now that CapX 2020 permitting is at the stage where they’re taking land by eminent domain.

Here’s the short version:

This is your opportunity to tell them how you think the Power Plant Siting Act isn’t working (ummmmm, yes, presumptive, but been there, done that, it ISN’T working) and to tell them how it should work.

This is your opportunity to submit Comments, oral at the hearing (Judge Lipman will be presiding again) and in writing.  Send written comments to:

Written comments may also be submitted until 4:30 PM, February 1, 2012.  Reference Power Plant Siting Act Annual Hearing docket number E999/M-11-324 in all correspondence. Comments should be sent to Judge Lipman at:

Here are my comments from last year and the Rulemaking Petition I submitted.  The Rulemaking Petition was split off, and I resubmitted directly to OAH for the 1400 and 1405 rules (the OAH rules).  Still need to rework the ones for PUC (7800 series), and I’ll do that by the hearing date.

Overland Comments 2010

Overland rulemaking Petition – 2010

Do show up and let them know in technicolor what YOU’VE experienced.  This is important.