Responses to No CapX & CETF Motion to Compel

Filed under:ITC MN & IA 345 kV — posted by admin on March 22, 2014 @ 1:48 pm

Hot off the press, the responses filed yesterday to our Motion to Compel and for Leave to Participate in Discovery and Cross Examination:

ITC Midwest Response to Motion_20143-97504-01

MCEA et al., Response to Motion_20143-97498-02

MCEA et al, Affidavit_20143-97498-03

Motion to Compel Discovery Filed

Filed under:BadgerCoulee - Wisconsin,ITC MN & IA 345 kV — posted by admin on March 8, 2014 @ 6:30 am


Just filed in the ITC Midwest MN/IA transmission case – because Minnesota Center for Environmental Advocacy, Wind on the Wires, Fresh Energy and Izaak Walton League refuse to answer Information Requests:

CETF and NoCapX2020’s Motion to Compel

The truth is ugly, but these documents reveal what they are, and some good indications of their price.  It’s important that they disclose, and important that the record reflect, the agreements that Minnesota Center for Environmental Advocacy, Wind on the Wires, Fresh Energy and Izaak Walton League have entered into, and the terms of the agreements, including terms regarding positions taken in interventions, what they are required to advocate for, in what venues, and prohibitions from advocating against utility policy and/or projects.  These agreements have had such wide ranging policy impacts, I’m sure they think for the good, that the end is worth the means, but I’ve been picking up the pieces of their messes, representing people and communities harmed by the deals, by the impacts…

Why are these agreements a problem?  Because the agreements they’ve entered into, at least those I know of, are primarily agreements of self-interest, without consideration of the impacts… think about the “alternate site mandate” or the Benson turkey shit burner of the 1994 Prairie Island bill, or the “Innovative Energy Project” Excelsior Energy Mesaba Project and expansion of dry cask storage of nuclear waste of the 2003 Prairie Island bill,  or the 2005 Transmission Bill from Hell and all the perks to allow CapX 2020, plus C-BED and a substation and turbine on Speaker Steve Sviggum’s land too… nope, no way, no how, these agreements are not in the public interest, are not in their “members” interests, and have had significant detrimental impacts on clients that have come to me for help in dealing with those impacts.

More Information Requests for ITC Midwest

Filed under:BadgerCoulee - Wisconsin,ITC MN & IA 345 kV — posted by admin on March 5, 2014 @ 4:44 pm


It’s a different kind of “Wild West” in transmission these days (the photo up above could well be the old 230 kV line through PA and New Jersey!).   But I did send out a lot of Information Requests today on the ITC Midwest MN/IA transmission project:

IR 1 to ITC (sent a while ago, responses received)

ITCM Response to CETF-NoCapX2020 IR No. 1

IR 2 to ITCMidwest

IR3 to ITCMidwest

IR 4 to ITCMidwest

IR 5 to ITCMidwest

IR 6 to ITCMidwest

IR 7 to ITCMidwest

IR 8 to ITCMidwest

IR 9 to ITCMidwest

IR 10 to ITCMidwest

What I’m most concerned about is that they’re touting all these benefits resulting from this project, but the benefits are associated with not just this project, but the REST of MVP 3, which is this project PLUS the MidAmerican part of MVP 3 in Iowa, PLUS MVP 4 (heading eastward to the Mississippi, and MVP 5, which is heading up to the Madison 345 kV ring, not just the part connecting the MVP 3 and MVP 5, but also Badger Coulee connecting CapX from La Crosse to Madison.  IT’S ALL CONNECTED, and the benefits, as modeled by PROMOD, are economic benefits, where a fundamental assumption of the modeling which includes ALL of the MVP projects, and not just MVP 3, MVP 4 and MVP 5, but all 17 of them.  17.  OK, find, we’re including all those benefits…

… but what about costs?  Wellllllllllllll…

They’re only addressing costs for their teeny-tiny portion of MVP 3, about 1/2 of it in Minnesota and a little bit into Iowa, the red part on this map, and no other costs:

ITC MVP Study 3

The cost/benefit analysis of this project is a little unbalanced:


And it should come as no surprise that their lead witness, ITC Midwest’s David Grover, was behind the TRANSLink docket (oh my… for that docket, go to the PUC search page, and search for docket 02-2152 (NSP) and/or 02-2119 (IP&L) where both utilities were asking the PUC for permission to transfer transmission assets to TRANSLink, what was to be the first transmission only company in Minnesota.   It wasn’t exactly going well, and so they bought out the enviros who had intervened:

Settlement Agreement – ME3(Fresh Energy), Izaak Walton League, Minnesota Center for Environmental Advocacy, North American Water Office

Things went south in transmission from there, because even though the TRANSLink Petition was withdrawn, the utilities just did it another way, and got everything they wanted,  including legislation authorizing transmission only companies:

2005 Ch 97 – Transmission Omnibus Bill from Hell — Xcel’s transmission perks and C-BED

… plus perks like construction work in progress (CWIP) rate recovery, broadened definition of “need,” on and on, a transmission company or utility’s dream.

image: detail of installation by Bronwyn Lace