No CapX 2020 Non-Party Brief

Filed under:BadgerCoulee - Wisconsin,Cost Recovery,FERC,Wisconsin — posted by admin on February 2, 2015 @ 10:16 am

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Leave it to the PSC to say, “Hey, here’s an open door” and then make it a screen door that’s locked!  In the Badger Coulee docket, the ALJ offered an opportunity to file “Non-Party” briefs and then it turned out the transcripts weren’t posted on ERF until the Thursday afternoon before the Friday brief deadline.  Thankfully Frank Jablonski offered to send the early transcripts sans corrections on Tuesday when I asked. I’d filed a quick Motion for Extension, no word on that yet, but brief has been filed:

NoCapX Motion for Extension to File Non-Party Brief

How is one supposed to write a brief without transcripts?  Oh, right, we’re not supposed to.  Oh well…  So here we go:

No CapX 2020_Non-Party BriefFILED TODAY!!!

In this docket I was compelled.  There were such important things that were utterly ignored.

For example, check the record about cost allocation, rate recovery, return on investment… Look at the testimony of Hodgeson (ATC) and Hoesly (NSP-Wisconsin).  Hodgson’s not exactly credible on the stand — when questioned about rate impacts on ratepayers, nada, he refused to address impacts on ratepayers, only that “benefits” will go to utilities:

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Trying again:

Hodgson1Untitled2Untitled3

Nothing about Schedule MM, nothing about Schedule 26A, which are how they came up with this numbers game.  And he put it together, lots was submitted CONFIDENTIALLY, info under wraps.  But the most primary concepts he will not talk about, and the primary documents are not in the record.

Can you believe that?  I… know… no-tingk!

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Does Hodgson know nothing?  Not quite.  Take a look at Hodgson’s prefiled testimony, and do a search for Attachment MM and Schedule 26A, look at how he talks about it:

Hodgson Direct

Hodgson Rebuttal

Hodgson Sursurrebuttal

His testimony is about cost allocation, apportionment, and each balancing area’s assessment for the lump of the MISO 17 MVP Portfolio projects.  And, yup, in Hodgson’s Direct Testimony, “Attachment MM” is used 12 times in his Direct Testimony.  “Schedule 26A” is used 8 times.  So where is Attachment MM?  Where is Schedule 26A?  They’re not attached as exhibits.  They’re not in the record that I could find.  WTF???

Who cares about MISO Tariff Attachment MM and Schedule 26A in the Badger Coulee docket?  Apparently no one.  The Applicants sure wouldn’t want to disclose this if they don’t have to, and they didn’t.  The intervenors didn’t care, it’s not been entered as an exhibit by any of them.  So where in the record is anything about how these MVP costs will affect Wisconsin ratepayers?

Here’s NSP-Wisconsin’s Hoesly, his testimony on this is limited to p. 5-6, noting that Hodgson did the work:

Hoesley Direct Corrected

THERE WAS NOT ONE SINGLE QUESTION FOR HOESLEY!  Well, PSC’s Urban and Sirohi too…

Here they are, the primary documents, from the ITC Midwest MN/IA 345 kV case:

MISO Tariff Attachment MM (from ITC docket)

Exhibit B_Schedule 26A Indicative Annual Charges_02262014 (from ITC docket)

Hodgson also refers to MISO Tariff Attachment O, and here it is:

ATC’s Rate Formula (Attachment O)

And for a bigger picture, here’s recent ATC info:

ATC_2015_Attach_O_G_MM_Schedule 1

ATC_AttachmentMM 100114

ATC Budget and Rates (note they use “coincident peak” for these calculations):

ATC Budget and Rates

And from that, these documents (some repeats) that were prepared for an October rate dog & pony:

Budget Presentation
Rate Formula (Attachment O)
2015 Attachment GG
2015 Attachment MM
2015 Schedule 1
2015 Transmission Service Rates (Schedule 7 & 8)
ATC Rate Projections through 2019

Who cares?  Well… anyone who is concerned about what Wisconsin, Minnesota, or anyone in MISO might be stuck paying for these MVP projects!

Do tell — how can the Public Service Commission of Wisconsin make a decision in this docket without the MISO Tariff Attachment MM and Schedule 26A in the record?  How can it make a decision without considering what Wisconsin’s assessment for all those $5.86 BILLION in MISO’s 17 MVP projects amounts to?



image: detail of installation by Bronwyn Lace