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Here’s the PUC’s Presentation that they’re giving at the meetings.
Comments are due by 4:30 p.m. March 14, 2014
Here’s Minnesota Power’s Great Northern Transmission Line announcement of the meetings with their explanation of what this is about.
It was a standing room only crowd. Maybe two chairs open, but a few of us were standing up, so… 60+, though not many speakers. The most important part of the message: THIS IS ABOUT NEED. This is where it’s determined whether the project is needed or not, and this is where you can have the most influence, but on those issues. This is where you can raise enough questions about need that the Public Utilities Commission just might agree that this project is not needed, and if so, it won’t be built on ANYONE’S land. No one wants transmission, unless they’re looking to “Buy the Farm” under Minn. Stat. 216B.12, Subd. 4, and sell their property to the utility and get out, but let’s get real, no one wants to be forced to leave their home. So now is the time to challenge them, in the Certificate of Need docket, before it gets to “get it off my land” or worse, “stick it THERE!”
What’s to challenge?
First, the concept that they need this big 500 kV line with emergency rating of 1572 MVA (essentially MW) when all they’ve got going is a 250 MW Power Purchase Agreement.
Second, this need is not reflected in their forecasts, call up Minnesota Power and request a hard copy of the application, and appendices, and you’ll see!
Third, this project hasn’t even made the “A list” of MTEP, meaning it’s not in Appendix A of those deemed “needed” by MISO. Not that that has anything to do with “need,” because that’s a market based premise, and also is becoming a circumvention of a state’s regulatory authority, a complicated but oh-so-relevant notion.
What’s happening now is a determination of the “scope” of the environmental review. It’s a “high level” review, meaning the generic impacts of this project and alternatives, and this need docket is the only place where “alternatives” will be considered.
They’ve included some information in their application under Minn. R. 7849.0250 and Minn. R. 7849.0260 . This Certificate of Need proceeding is the only time the “No Build Alternative” is considered, once need is determined and it moves into routing, “no build” is not regarded as an option. The application is online, at the PUC docket site — go HERE and plug in docket 12-1163 — 12 (year) and 1163 (docket number). If you want a hard copy, contact Minnesota Power and they’ll send you one.
Here’s the quote from the DRAFT ER Scoping document:
The environmental report will address/discuss the following matters:
1.1 Purpose and Need
1.2 Regulatory requirements
2.0 PROJECT DESCRIPTION
2.3 Right-of-Way Requirements and Acquisition
2.5 Operation and Maintenance
3.0 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 Generation
4.0 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
4.10 Visual Impacts and Aesthetics
4.11 Water Resources (surface, groundwater, wetlands)
4.12 Waste Management and Disposal
So to make a relevant comment on “scope” you need to let them know what specific things in the above categories should be included in the Environmental Report. This means telling them not “EMF” in that broad stroke, but to say, “When you consider EMF, consider the range of levels, from the low statement of Minnesota Power, 750 MW, to the higher emergency rating of 1572 MVA.” That means that you’d get the numbers for the highest potential EMF of the project.
Another thing is to request that they look at the size and timing of this project. MP says that they have a 250 MW PPA, and maybe another PPA in the future, so is that any reason to build a 1572MVA emergency rating 500 kV line? Seems like it’s too early to “need” something this large, and it’s way too big for their claimed need.
And as in the post below, I’m concerned about this “system alternative” that Xcel Energy, et al., are promoting (So what is Xcel, et al., up to?). They’ve not intervened, and they must put their cards on the table. It feels like a threat, that Xcel is throwing its weight around, and it really screws up any notion of what’s at issue. They put it out there, but don’t follow through and we don’t know whether to take them seriously.