Here we go — it’s testimony time. Yesterday the “Large Utility Intervenors” and Commerce DER filed their Direct Testimony.
Commerce:
Large Utility Intervenors:
Category Archives: Certificate of Need
PUC CoN & Siting/Routing FINAL Rulemaking meeting
It’s final… that is, the FINAL meeting notice was just issued, one more go round on these draft rules for Certificate of Need (Minn. R. Ch. 7849) and Power Plant Siting Act (siting and routing of utility infrastructure) (Minn. R. Ch. 7850).
We’ve been at this for about a year and a half, maybe more, and to some extent we’re going round and round and round.
Here are the September 2014 drafts, hot off the press:
Send your comments, meaning SPECIFIC comments, not “THIS SUCKS” but comments on the order of “because of _______, proposed language for 7950.xxxx should be amended to say_______.” It’s a bit of work, but it’s important, for instance, the Advisory Task Force parts are important because we were just before the PUC on this last week, trying to reinforce that Task Force’s are necessary, despite Commerce efforts to eliminate and/or neuter them. That despite ALJ orders otherwise, the Final EIS should be in the record BEFORE the Public Hearings and Evidentiary Hearings (just lost a Motion to require this last month).
How can you comment? The best way is to fire off an email to the Commission’s staff person leading this group:
kate.kahlert@state.mn.us
If you’re up to it, sign up on the PUC’s eDockets, and file your Comment in Docket 12-1246. If you’d like your comment filed there, and can’t figure it out, please send it to me and I’ll file it for you. It’s important that these comments be made in a way that the Commission will SEE, in a way that they cannot ignore, when this comes up before them.
Public Hearings for GNTL in October
The notice was just issued for the public hearings for the Great Northern Transmission Line. Be there or be square!
And here are the details:
Filed under Certificate of Need, Hearings
Information Requests Responses
There have been MANY information request responses filed by Minnesota Power. Below are responses to IRs from the “Large Power Intervenors” and the Commerce DER. Note that many are “Public Versions” meaning it’s essentially blank. There’s a “Non-Disclosure Agreement” to be signed to get this info. I thought I’d signed it, but I can’t find the “Top Secret” versions, and even if I had, well, couldn’t post them here.
These are Responses to the Information Requests of the “Large Power Intervenors” received thus far:
LPI_IR_002.1 – Attachment Public
LPI IR 003 & 004 Supplemental – FINAL
LPI IR 006.2 Attachment Public Version
LPI IR 006.3 Attachment Public Version
LPI IR 007.1 Attachment Public Version
LPI IR 008 Public Version – FINAL
LPI IR 008.1 Attachment Public Version
LPI IR 008.2 Attachment Public Version
LPI IR 008.3 Attachment Public Version
LPI IR 008.4 Attachment Public Version
LPI IR 008.5 Attachment Public Version
LPI IR 008.6 Attachment Public Version
LPI IR 010.1 Attachment Public Version
LPI IR 011.1 Attachment Public Version
LPI IR 014.1 Attachment Public Version
LPI IR 017 – FINAL – Public Version
LPI IR 017.1 Attachment Public Version
LPI IR 019 – FINAL – Public Version
LPI IR 019.1 Attachment Public Version
LPI IR 024.1 Attachment Public Version
LPI IR 028 – FINAL – Public Version
LPI IR 030 – FINAL – Public Version
Commerce:
20121102 Northern Area Study Presentation
20121105 MH Wind Synergy Study TRG Presentation_Updated
DOC IR 010 Supplemental – FINAL
DOC IR 009 Supplemental – FINAL
Filed under Certificate of Need, Information Requests
PUC Rulemaking — Send Comments on Drafts
The Minnesota Public Utilities Commission is winding up its rulemaking on the Certificate of Need (Minn. R. Ch. 7849) and Siting/Routing (Minn. R. Ch. 7850) chapters. My clients Goodhue Wind Truth and North Route Group have been participating all along, and their experience with the Certificate of Need and Routing/Siting process has helped inform this record and we sure hope leads to more sensible and workable rules, AND increased public participation.
Now is the time to download and make your comments on what should be included, what’s included that’s important and needs to go forward, and what needs to be reworded.
Send Comments to:
- kate.kahlert@state.mn.us
- and/or post to the Rulemaking Docket. To do that go HERE to the eDocket Filing Page, register if you’re not registered (it’s easy and almost instant), and post to Docket 12-1246.
It’s highly likely that the LAST meeting of the PUC’s Rulemaking Advisory Committee will be September 24, 2014 (9:30 a.m. at the PUC, in the basement).
A few things that need work:
- Ch. 7849 & 7850: Need language mirroring statutory language regarding testimony by members of the public UNDER OATH (ALJs have refused to offer people opportunity to testify under oath, and PUC has stated that it makes a difference, “but were those statements made under oath” and if not, less weight.
- Ch. 7849: Advisory Task Forces need language of statute, and membership not limited to “local units of government.”
- Ch. 7849 & 7850: Transcripts available online — need to address this in rules and reporter contracts.
- Ch. 7849: Scoping and Alternatives — compare with Ch. 7850. Similar process?
- Ch. 7849.1450: When is it Commerce EER & DER
- Ch. 7849 & 7850 – timing should be similar for completeness review, etc.
- Ch. 7850: Public Meeting separate from Scoping Meeting (Public Meeting is to disseminate information, Scoping Meeting is for intake).
- Ch. 7850: Power Plant Siting Act includes “Buy the Farm.” Need rules regarding Buy the Farm.
Now is the time to review the drafts, above, and send in Comments. There may be, I hope there are, revisions released prior to the next meeting, but usually it happens just before, and there’s no time. So here’s where we are now, and Comments would be helpful.
Filed under 7850, Buy the Farm, Certificate of Need
Useful information? Please donate!
Donate!!! Yes, you!! See that “PayPal” button up to the right? Join the challenge to transmission that they don’t need and we don’t want! Residents and Ratepayers Against Not-so-Great-Northern Transmission, an ad hoc advocacy association, has Intervened in the Certificate of Need, a public interest intervention focused on showing up to weigh in on the big picture issues (Important note, we’re aiding public participation, but not taking a position on route.).
Minnesota Power’s Direct Testimony Filed
Oh, it’s been a busy week, and it’s only Wednesday. Buried alive in paper, as I frantically try to sort out the old files from my other office, get rid of the dusty, moldy things from over a decade ago, and what does Minnesota Power do but dump 20 pounds of Direct Testimony. On the other hand, it does look like good stuff, a stimulating read, lots of fun to be had over the weekend!
MP_Testimony_Atkinson_Direct_20148-102147-02
MP_Testimony_Donahue_Direct_20148-102147-04
MP_Testimony_Hobert_Direct_20148-102147-06 MP_Testimony_Hobert_Direct_Sched2_20148-102147-06-2 MP_Testimony_Hobert_Direct_Sched3_20148-102147-06 MP_Testimony_Hobert_Direct_Sched4_20148-102147-06-2
MP_Testimony_McMillan_Direct_20148-102147-03
Filed under Certificate of Need, Hearings, Need, PUC Filings
Demand down, “It’s a new world for us” utilities!
I love it when this happens — when the truth is so obvious that they can no longer deny it:
This decreased demand is the reason they want us to pay for transmission lines across the U.S. so they can market all this surplus power in locations where prices are higher. DOH!
Electricity Sales Anemic for Seventh Year in a Row – WSJ July 28 2014
Filed under Certificate of Need, MISO, Need, Uncategorized
Scoping Comments due Friday @ 4:30 p.m.
No, not that kind of scoping, for scoping of the Environmental Report, or is it THIS Environmental Report… whichever, it’s this kind of scoping:
In this case, it’s Environmental Report, or Environmental Report, and not Environmental Impact Statement (that is an issue that should be raised, see below, and the rules pertaining to an EIS in a Certificate of Need proceeding), and they’re looking for what all specifically should be included in this “Environmental Report.”
There’s a “Draft” scoping decision that has the rough outline:
What to submit for comments? Well, it’s got to be specific! They have general categories, and if you have something specific for consideration within these categories, send it in! And if there is an environmental consideration NOT addressed here, send it in!
Comments are due by 4:30 p.m. on Friday, March 14, 2014.
Send to bill.storm@state.mn.us
Some ideas:
- Cumulative impacts must be addressed. I’ve heard of an instance where someone was hit with a pipeline and a transmission line recently, and now Minnesota Power is proposing getting hit AGAIN for the GNTL! “You’ll get used to it?” Nooooo, that’s not within the realm of rational response or probable outcomes. How are the impacts of multiple projects balanced with Minnesota’s policy of “non-proliferation,” where transmission is to be run on “pre-existing” corridors? Where transmission is routed on greenfield, and then followed by other infrastructure, over and over and over… how is this taken into account?
- The full range of potential electric and magnetic fields must be addressed, not just a minimal number that’s a small percentage of potential capacity (as is usually done by Commerce’s EIS/ER — NOT acceptable).
- Alternatives will be analyzed — but what alternatives — alternatives to what? This is a project “needed” to transmit a nominal amount of electricity under a PPA between Minnesota Power and Manitoba Hydro, and the rest is for export. So given that “need” claim, what alternatives are there? This is transmission for profit. Is the search on for another revenue stream for them? Are there alternatives to satisfy this “want” that pretends to be a need? How will the state handle this?
- Because of the magnitude of this line, so many miles long and such high capacity, an Environmental Impact Statement should be completed, not just this Environmental Report (p.s., there’s no provision under MEPA, 116D, for “Environmental Report” as an environmental document).
And if you’re interested in the Canadian “Independent Expert” report on environmental considerations, and remember, this is for the WHOLE Canadian project:
Filed under Certificate of Need, Environmental Review, PUC Filings
Tonight, Wednesday night, in Baudette
Live from Baudette — we’ve got internet access in the building! Can you tell I’m trying to get today’s work done as we go?
We’re in the Ambulance Garage to talk about the “scope” of the Environmental Review, this isn’t posted on the PUC docket yet:
DRAFT ER Scoping document
Comments due by 4:30 p.m. March 14, 2014
Send to:
bill.storm@state.mn.us
Tracey Smetana, the Public Advisor, is presenting now:
Tonight we don’t have as many people as last night, but it’s a good crowd and we’re moving along through the presentation.
Now for Minnesota Power:
The PPA they now have is 250 MW and they’re looking at another for 133 MW. 250 + 133 = 383! MP claims there’s an increase in demand. They serve the Iron Range and are seeing substantial load growth and are projecting that into the future.
Now it’s Bill Storm, Dept. of Commerce:
One thing they’re doing a good job of is explaining the difference between Certificate of Need and Routing, and that this is all about “need.” Each one of them raises this, and it seems people are getting the difference, but I think discounting this proceeding when/because they’re really concerned with the routing. So if you look on p. 6 of the DRAFT ER Scoping document, now’s the time to, as Bill Storm says, to “fill in the details.” Here’s the Draft Scope:
The environmental report will address/discuss the following matters:
1.0 INTRODUCTION
1.1 Purpose and Need
1.2 Regulatory requirements2.0 PROJECT DESCRIPTION
2.1 General
2.2 Design
2.3 Right-of-Way Requirements and Acquisition
2.4 Construction
2.5 Operation and Maintenance
2.6 Permits3.0 ALTERNATIVES TO THE PROPOSED HVTL
3.1 No-build Alternative
3.2 Demand Side Management
3.3 Purchase Power
3.3.1 Long term Purchase Power
3.3.2 Short term Purchase Power
3.5 Up-grading Existing Facilities
3.6 Facilities of a Different Size
3.7 New Generation4.0 ENVIRONMENTAL AFFECTS
4.1 Air Quality
4.2 Biological Resources
4.3 Culture Resources
4.4 Geology and Soils
4.5 Health and Safety
4.6 Land Use
4.7 Noise
4.8 Socioeconomics
4.9 Transportation
4.10 Visual Impacts and Aesthetics
4.11 Water Resources (surface, groundwater, wetlands)
4.12 Waste Management and Disposal
For example, “3.5 Up-grading Existing Facilities” is one to think about, there are lines from Manitoba Hydro down to Minnesota Power territory, so why couldn’t they build those larger? Reconductor, or raise the existing line voltage to 765 kV and that would increase the capacity.
Now David Leonhardt, and he’s the Chair of the Friends of the Big Bog State Recreation Area, which has the longest Bogwalk in the world!! Concerned about impact of the line on the unspoiled view at the terminus of the bogwalk. He also suggests to follow the existing line that is there, but that’s in a SNAP area where they’re not allowed to put a line alongside the existing one.
John Paulsen – why can’t we follow one of the existing lines? Bill Storm said that it’s a routing question, MP says that the routing through SNAP areas takes it off the table. We’re following the existing as much as possible, and what we’re proposing is a much larger scale.
Charles Bruer – can you define Scientific and Natural Areas? MP & B.S.: They’re designated tracts of lands due to characteristics, not altered by human activity.
Wendy Rogers – question about electro-magnetic force, how far does that go out from the line? B.S.: This is one of the things I always must address in an Environmental Report. What can we expect EMF for a 500 kV line and what do we know about it. B.S.: I get the normal levels from the Applicant, and then push it to failure, and report both.
Steve Weymore – wondering why the terminus east of Grand Rapids is need if it is needed for mining, I don’t see that as the terminus. MP: Mining and expansion of load is the reason, and the number of lines going into Blackberry.
B.S.: Remember, this is need, and we’ll be getting into this again in the Routing, I expect it will probably be in May, and we’ll do a more detailed environmental review at that time.
Filed under Certificate of Need, Environmental Review, Meetings, Open Houses