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

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.