Dairyland’s Q-1D South Environmental Assessment

Filed under:Q-1 Upgrade,Uncategorized,Wisconsin — posted by admin on June 19, 2016 @ 3:37 pm

Graphic3

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:

Ulman_St[1]

Really… Here’s what it looks like from a satellite with the lines drawn in, on the far south:

End of the Line

Here’s what it looks like further north — look at all those homes:

Sheet Map 3

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.
So look what Dairyland says about these clearance problems, first on page 3-3 of the Q1-South_Environmental Assessment in its discussion of alternatives, specifically joining with Xcel Energy, which has a similar line right through the community over homes and through yards on the other side of the highway:
p23
Though there’s no case law about this, Dairyland states, “This provision likely applies to Xcel as a public utility but not DPC as a cooperative.”  That’s pretty presumptive, with no basis for the presumption, DPC!  And they wiggle around again, claiming the code doesn’t apply to them 10 pages later:
[33_1p33_2
Do you buy that argument???  First, they don’t even cite the correct PSCW section, using “PSCW 114.234(a)(4)” rather than PSCW 114.234(a)(2).  Note they state that “public utilities may seek waivers of any rule expanding upon NESC requirements…”  But if they’re saying the code doesn’t apply to them, why would this apply to them and they can seek a waiver?  Under their argument that the PSC Code doesn’t apply to them because they’re a cooperative, then if that applied, then this would not apply to them either.  Or is it the opposite, that the Code does apply to them, they cannot rebuild the line under  and have to apply for a waiver to the PSC?  Which is it, Dairyland?  Oh, but wait, I thought part of why you’re doing it the way you are, applying to local governments, in this short segmented version of your Q-1 line, was that you don’t want to have to go to the PSC, that you’re trying to get around it…
Segments
Segmenting, particularly segmenting to avoid environmental review, is not OK, Dairyland…

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image: detail of installation by Bronwyn Lace