ITC’s MN/IA line — DEIS Comments and FEIS release

Filed under:ITC MN & IA 345 kV,Nuts & Bolts — posted by admin on May 8, 2014 @ 11:10 am

Comments are due on the Draft Environmental Impact Statement on May 9 — that’s TOMORROW!  More on this below on this post.

raymond.kirsch@state.mn.us

fax: 651.539.0109

Ray Kirsch, Environmental Review Manager
Minnesota Department of Commerce
85 – 7th Place East, Suite 500
St. Paul, MN  55101-2198

Now, about the Environmental Review and scheduling…

Here’s a part of the Scheduling Order for the ITC Midwest MN/IA 345 kV line docket:snippet

As I work on the DEIS comments due tomorrow on the ITC Midwest MN/IA 345 kV Transmission Project, I realized that environmental review is not incorporated into the scheduling order:

SchedOrder3_20144-98187-01

That’s most unusual… I had to call Ray Kirsch to find out when the Final EIS is going to be released.  That’s July 11, 2014.  It’s not on the Scheduling Order.  So what?  Well, think about it… what that means is that the public hearings are May 13 & 14th, the Evidentiary Hearings is May 19 – 23rd, the record closes on May 30, and so all the hearings are over and the record is closed when the FEIS is released!  It also means that the Public Comment period, which closes also on May 30, 2014, doesn’t give the public any way to comment on adequacy of the FEIS.  And parties’ Initial Briefs are due on July 11, 2014, so we can’t comment on it in the Initial Briefs either.  No, this is not OK.

So I fired off a letter, and am ready to file a Motion if need be:

CETF & No CapX 2020 Request for Extension of Schedule for Public Comments and Briefing on FEIS Adequacy

+++++++++++++++++++++++++++++++++++++

Again, send DEIS comments to:

raymond.kirsch@state.mn.us

fax: 651.539.0109

Ray Kirsch, Environmental Review Manager
Minnesota Department of Commerce
85 – 7th Place East, Suite 500

St. Paul, MN  55101-2198

Some issues that come to mind:

  • The DEIS should define “need.”
  • The DEIS should specify what capacity are they wanting, and what they want it for.  ITC claims that a lower voltage line “would be unable to provide enough capacity to improve reliability or support additional generation.” p. 49.  OK, so what capacity is that?
  • Every time the DEIS says “need,” it should change that to “want” or “desire.”  That would make it a lot easier to understand.
  • To the extent that it is claimed that this project is “to enable new wind” and “deliver existing and future wind generation” it must document how it is assured that wind is enabled/delivered, mindful that FERC specifies that transmission cannot discriminate and must serve all types of generation, and there’s a lot of coal coming in from the west.
  • The DEIS “Alternatives” section says “ITCM notes that the need for its project has been substantiated by its own studies and by those of MISO.”  Ummmm, the only option considered by ITCM and MISO is transmission, it’s a transmission-only company and a transmission operation, DUH!  “Additionally, MISO conducts studies to determine those projects that best meet identified transmisison needs.”  Oh, and those “identified transmission needs” are… ????
  • PROMOD modeling is ECONOMIC modeling.  Economic want, desire for profits, is not “need.”
  • There is a lot of surplus generation west of this project (see p. 48 of DEIS referencing “even more surplus generation that must be exported to regional load centers…”
  • “Different size” is not limited to “different voltage” and “different endpoints.”  For transmission, size = capacity.
  • The DEIS correctly states that “ITCM is an electric transmission company; it does not operate electrical generation plants or provide retail electric service.”  GOOD, that’s TRUE!  Now, what does that mean when considering how ITCM frames this project?
  • “In conclusion, while the 161 kV rebuild alternative may have potential for reduced human and environmental impacts, ITCM’s analysis indicates that it is less effective than a 345 kV line at meeting the need for the project.”  Ummm., SO?  What’s the state’s independent analysis?  Isn’t this what an EIS should be?

In the meantime, here’s the DEIS for review:

Draft Environmental Impact Statement Text

Appendices

 

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image: detail of installation by Bronwyn Lace