Category Archives: PUC Filings

Responses to initial Information Requests

mailbox

Fresh from the Inbox, Minnesota Power has responded to RRANT’s initial Information Requests:

RRANT_IR_001 – FINAL

RRANT_IR_002 – FINAL

RRANT_IR_003 – FINAL

RRANT_IR_004 – FINAL

RRANT_IR_005 – FINAL

RRANT_IR_006 – FINAL

RRANT_IR_007 – FINAL

RRANT_IR_008 – FINAL

RRANT_IR_009 – FINAL

RRANT_IR_010 – FINAL

RRANT_IR_011 – FINAL

RRANT_IR_012 – FINAL

RRANT_IR_013 – FINAL

RRANT_IR_014 – FINAL

RRANT_IR_015 – FINAL

Some will seem repetitive, but I’m just going around the same thing several ways…

The most interesting to me are the links in the response to IR 4 for MISO and other studies to justify or support building the GNTL project, THANK YOU Minnesota Power FOR SENDING WORKING LINKS:

System Impact Study (SIS) reports and meeting presentations

Draft SIS Report Prior Outage & Injection Analysis              7/9/2010

Draft SIS Report – TO Option                                                     4/26/2010

Additional Impact Analysis Draft Report                                 4/20/2010

Executive Summary (Final Report)                                           7/20/2009

Final SIS Report Summer Peak analysis                                   7/20/2009

Final SIS Report Winter Peak analysis                                      7/20/2009

Final SIS Report Stability analysis                                              7/20/2009

Updated Draft Stability SIS Report analysis                            6/29/2009

Updated Draft SIS Report- Winter Peak analysis                   6/29/2009

Updated Draft SIS Report- Summer Peak analysis               6/29/2009

Draft Stability analysis                                                                 4/30/2009

Draft SIS Report- Winter Peak analysis                                   3/20/2009

Draft SIS Report- Summer Peak analysis                                 3/11/2009

Draft SIS Report                                                                             1/13/2009

Preliminary Draft SIS Report                                                    12/16/2008

LT MH Study Screening results                                                  1/21/2009

MH_TSR_Group Study_Transmission Options                    1/21/2009

Facilities Study Reports and meeting presentations

MH-MP_AC_Thermal_Sensitivity_Analysis-Eastern_Plan-Draft_Report-01-07-13.pdf

MH-MP_AC_Thermal_Sensitivity_Analysis-Western_Plan-Draft_Report-01-07-13.pdf

MH-MP TSR meeting Feb 2013                                  3/6/2013

MH-MP TSR meeting Jan 2013_EPL                          1/8/2013

MH-MP AC Thermal Sensitivity Analysis – Draft Report – 01-03-2013      1/8/2013

Dorsey – Iron Range 500 kV Project Preliminary Stability Analysis – Draft Report – 12-5-2012    1/8/2013

MH Group Study Option 1 FS                                                      6/1/2010

MH Group Study CapX – TO presentation                              11/4/2009

CapX FS proposal presentation                                                  11/4/2009

Additional Analysis Scope document                                       11/4/2009

Final FS Report (GRE)                                                                1/19/2010

 

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Filed under Information Requests, Need, PUC Filings, Uncategorized

Electro-magnetic fields are dangerous

DSC01914

AAAAARGH… during last night’s meeting there was a question and concern expressed about electro-magnetic fields (I’ve focused primarily on magnetic fields, here and elsewhere).  The question was referred to Minnesota Power’s engineer, and was essentially dissed, then and also later by the engineer.

What Minnesota Power says about EMF in their CoN Application (201310-92766-02) (p. 45-46):

Maximum ampacity is defined for the Project as the expected capacity of the line, in this case 2,000 Amps. The projected peak loading of the line – 1,024 Amps – was derived from power system modeling of the Project under system normal conditions in a 2020 summer off-peak case with high Manitoba – United States transfers. Per IEEE Standard 644-1994 (R2008), IEEE Standard Procedures for Measurement of Power Frequency Electric and Magnetic Fields From AC Power Lines, values were calculated at minimum conductor-to-ground clearance (mid-span) at a height of one meter above ground.

Maximum amps 52.94-88.54 at the edge of the Right of Way… Projected loading at the edge of the Right of Way, 26.81 – 44.76 mG.  That’s HIGH!

Here’s their chart for the meetings:

DSC01915

Now, here is a chart showing ampacity and MVA for various voltages and configurations, taken from this chart from the SW MN 345 kV Certificate of Need proceeding (Ex 35 App 7 Conductor spec-ACSR):

Ex 35

They’re talking about ampacity of 2,000, which is higher than the chart goes.  And this is to be a 500 kV line with three conductors per phase, so the MVA rating at nominal voltage would be above 4,704 MVA.  And remember, MW are essentially MVA (ask an engineer to explain the difference).  Minnesota Power is saying that this project proposal is based on a 250 MW Power Purchase Agreement, and the potential of another 133 MW PPA.  250 + 133 = 383 MW.  Out of MVA rating at nominal voltage of 4,704.  Now I’m a math idiot, so let me get out the calculator:  4,704 – 383 = 4,321 MVA missing-in-action.  What do you think will comprise the excess capacity for this project?  Seems to me to be substantive size, type and timing issues here!

This is all about having a high capacity line to be able to market power south and eastward, let’s be clear about that.  And folks, that is NOT a public purpose, that’s all private profit for Manitoba Hydro and Minnesota Power.

Now utilities have been known to understate projected loading, and have typically never admitted potential capacity of these projects, and they’ve been outed on this before:

Bruce McKay_Affidavit_CapX 2020 Brookings-Hampton Routing 08-1474

Bruce McKay_Affidavit_Hiawatha CoN-10-694

Bruce McKay_Affidavit   CapX 2020 Hampton-La Crosse Routing 09-1448

The point?  They’re consistently under-representing the capacity of the line, the projected loading and the potential loading.  In calculating EMF exposures, it’s important to use both the utilities numbers (presumed low) and the MVA rating of the line.  These two points form a range of potential loading and potential EMF emissions.  This full range must be addressed in environmental review, and to not address this full range is misleading.  The full range has yet to be addressed in any environmental review I’ve seen in my nearly 20 years and that must change.

The Power Line Task Force went to the PUC about shutting down the existing 69kV line that was going to be converted to a 115 kV, a transmission line in people’s backyards.  The PUC didn’t regard it as a problem, Commissioner (former Rep.) LeRoy Koppendrayer made one of his famous statements about the safety of EMF, stating, on the record, that he had an electric blanket and every time they used it, 9 months later they had another kid.  Really… And he probably uses a cell phone without a headset too…

The Appellate Court also didn’t care… and it was probably the best oral argument I’ve done in my career…

Power Line Task Force, Inc. v.  Public Utilities Commission

The PUC and courts don’t want to get into the minefield of EMF.  Think about what it would mean if utilities were held liable for damages due to EMF?  Think of the liability!  It’d be bigger than asbestos!  Shades of The Distinguished Gentleman!

LOOKING FOR BASIC INFORMATION ABOUT ELECTRO-MAGNETIC FIELDS?

The best resource I know of is Roger Conant’s site on Power Line Health Facts, at www.powerlinefacts.com.  It looks like he’s let the site go, but it’s available on the Wayback Machine.  Here is the EMF page — CLICK HERE.  This was last captured in April, 2012.

The information that we presented in the Southeast Metro transmission line case in 2000-2001 resulted in the first denial of transmission permits by local government based on concerns about EMF.  Here’s a short version from the Power Line Facts site.  The cities of South St. Paul, Mendota Heights, and Sunfish Lake joined together to form a Steering Committee which heard the evidence (this was applied for by then Northern States Power as a local government permitting decision), and the Steering Committee decided the permits should not be granted, and then each of the local governments individually rejected the permit applications.  Great!  Until one by one, Northern States Power started throwing its weight around and filed suits against all the local governments.  Despite a thorough record and well substantiated decisions by all, they rolled and caved to Northern States Power.

Steering Committee Papers from www.powerlinefacts.com via Wayback Machine

In that case, we presented Dr. Martin Blank and Dr. Magda Havas.

Testimony of Magda Havas – SE Metro

Testimony of Dr. Martin Blank – SE Metro

We also used Dr. Blank for the Susquehanna-Roseland transmission line case to get information about EMF into the record:

Testimony of Dr. Martin Blank – Susquehanna-Roseland

Another good source is the World Health Organization:

WHO EMF home page

WHO EMF Research

WHO Environmental Health Criteria 137

Here’s their fact sheet in English on Static electric and magnetic fields: English

And their fact sheet in English on Electromagnetic hypersensitivity: English

On the  page there’s a “What’s New” (but I don’t think 2010 info is “new” though):

If you’re looking for information on EMF, you can find a lot in the internet.  Just filter it carefully, don’t believe everything you read!

You can by a Gauss Meter to go around the house and underneath operating transmission lines to get a feel for magnetic field levels.  You can get them online, pricey and cheap, and a cheaper one would probably be sufficient to learn about magnetic field levels in your environment — just google “Gauss meter” and many will pop up!

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Filed under Environmental Review, Information Requests, PUC Filings, Uncategorized

Last night, Roseau, tonight Baudette!

If you have questions, or would like to receive alerts and notices, please contact me through the “About” page linked above!  (Don’t use “Comments” below because I’m being spammed to death and they all go into the trash!)

PublicMeetingSched

Here’s the PUC’s Presentation that they’re giving at the meetings.

Comments are due by 4:30 p.m. March 14, 2014

Send to:

bill.storm@state.mn.us

Here’s Minnesota Power’s Great Northern Transmission Line announcement of the meetings with their explanation of what this is about.

DSC01896

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:

1.0 INTRODUCTION
1.1 Purpose and Need
1.2 Regulatory requirements

2.0 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 Permits

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
4.7 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

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.

DSC01904

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So what is Xcel, et al., up to?

When the “Regional Utilities” submit Comments like this, and reiterate that they plan to intervene and propose a different corridor as a “system alternative,” just what are they up to?  As I posted yesterday, I asked about intervention and got nothing, no idea when they’ll file, and really, no idea IF they’ll file.  Could be just a threat…

Threat of what, well, a threat of claiming an interest in this proposed line — that’s all that makes any sense:

Regional Utilities_Comments_201311-93834-01

snippet1

Assist the Commission?  We know how they “assisted” ATC on the Badger Coulee line, claiming 1/2 ownership:

FERC Complaint – Ownership of Badger Coulee

And Xcel won that one, after which ATC tried to claim 1/2 of CapX Hampton-La Crosse and lost…

Commission Order – Xcel 1/2 Owner!

Snippet2

Are we in for a repeat?  Hey, it worked for them once, why not again!  When the “Regional Utilities,” Xcel, et al., want to “help the Commission” how could it be anything but good for the “Regional Utilities” a/k/a Xcel Energy?  So how are they focused on helping themselves, errrrrrrr, “helping the Commission,” yeah, that’s it… and to what?  Seems it’s pretty limited, they’re either helping themselves to new for-profit transmission and marketing ability for export generation running from Manitoba Hydro’s Dorsey substation into their CapX 2020 transmission line at Barnesville… or do they want to help themselves by threatening a reroute and then “settle” for an ownership piece of the Minnesota Power line as proposed, like their 50/50 split with ATC on Badger Coulee?  And are there other options?  Well, “Regional Utilities,” we’re depending on you to let us know!

Xcel, et al., have not yet intervened, so we don’t know what they’re doing, other than to proposed this other route, as a “system alternative,” which is bizarre.  It’s at least a threat, but where are they headed?  That’s between Minnesota Power and Xcel, et al., but it makes me a little squeamish thinking of the possibility of such a major reroute with inadequate notice, particularly one that MISO has not put to the head of its class in the MTEP.  Not to mention that Xcel should know better than to throw its weight around like that, not a good way to make friends and influence people.

Once more with feeling, here’s what their “system alternative” looks like on a map, their map:

Dorsey_CapX_System_Alternative

Take a good look at this map, and compare with the most recent MP proposed corridor, focused on the northern options and eliminating the one dropping south and running around Red Lake:

RouteCorridors

Think about good things… think about the bad things….

 

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Schedule for GNTL Docket

Last Friday was the Prehearing Conference and an odd time was had by all.  It’s admittedly ALJ Ann O’Reilly’s first transmission contested case, so she’ll be having a fun time, I’m sure.  And I’m pretty sure it’s also Christi Brusven’s first big transmission line, and even Eric Swanson’s… ya know, I’m really feeling like an old fart!

The most interesting part of this is that the “Regional Utilities” are planning to intervene, Xcel, Otter Tail Power, and MRES, with the purpose of telling the Commission that it should instead use its “system alternative” which would connect down to CapX 2020!  Like wow, that’s going to be a hoot!  I don’t know that’s ever been tried before, kinda cheeky, eh?  But they’ve got to fill CapX with something, and we all knew it wasn’t needed, didn’t we?!?!

Here’s the “system alternative” line from Dorsey into CapX at Barnesville (p. 11, North Area Study, Application, Appendix M) (note that for this study they increased Manitoba Hydro imports to 1,100MW):

Dorsey_CapX_System_Alternative

And now for the proposed schedule… We’ll be circulating the scheduling order and then send it to the ALJ, so it’s not official, but this is pretty much it, and when it IS official, I’ll be posting it.

The Environmental Review schedule continues as before:

PublicMeetingSchedScoping Comments are due by 4:30 p.m. on March 14, 2014.  Send to bill.storm@state.mn.us

EnvRev

The rest of the schedule looks like this:

Schedule

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Scheduling for GNTL Certificate of Need proceeding

We’re inching forward in the scheduling for the Not-so-Great Northern Transmission line proceeding at OAH.  Commerce and Minnesota Power have sent in proposals, Commerce for the public hearings across the state, and MP for the whole shebang!

The Prehearing Conference is on Friday, THIS Friday, the 17th at 10 a.m. in the PUC’s Small Hearing Room.

Here are the proposals, starting with the TENTATIVE public hearing schedule:

PublicHearingSched

Here’s MP’s proposed environmental review schedule (and it’s way too ambitious, Commerce can’t get anything done that fast, we’re always waiting for environmental review, and the public hearings shouldn’t be held before that’s done!):

MPsEnvRevSched

And MP’s Hearing schedule (HA!):

MPsHearingSched

Less than a year for a 200+ mile part of a US/Canadian 500 kV line?  You be dreamin’.

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RRANT files Petition for Intervention!

HomerRant

Definition of RANT

Today the Residents and Ratepayers Against Not-So-Great-Northern Transmission filed a Petition to Intervene in the Great Northern Transmission Line proceeding at the Public Utilities Commission, now moving to a Contested Case at the Office of Administrative Hearings before ALJ Ann O’Reilly.

RRANT Letter, Notice of Appearance, and Petition for Intervention

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PUC Order for Hearing issued

gavel

 

Just out, the Public Utilities Commission has issued its Order moving this transmission project application toward hearing.

Order for Hearing 12-1163

 

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PUC “Staff Briefing Papers” filed

Public Utilities Commission meeting to decide whether to refer to OAH for a contested case hearing:

Thursday, December 19, beginning at 9:30 a.m.
Agenda item 3
Minnesota Public Utilities Commission
121 – 7th Place East, 3rd Floor, Large Hearing Room
St. Paul, MN

The most important thing for the public to be aware of at this stage is that this is a NEED proceeding, not about routing.  This docket will determine whether the project is NEEDED, and after that, a separate application will be made for a route.  Comments regarding route are NOT relevant here.  Comments about NEED are NEEDED!  Minnesota Power doesn’t have a compelling need case, much less a sufficient need case, and that’s what’s at issue.

Here are the PUC’s Staff Briefing Papers:

Staff Briefing Papers_201312-94525-01

The project description is off where it says:

The project would join with a new 90-130 mile transmission line in Canada to form a new international transmission interconnection to provide approximately 750 megawatts (MW) of transfer capability.

Not quite.  This is a 325-400 mile long transmission line, with 90-130 miles in Canada and 235-270 in the US.  The correct way to state this is “The project is a 325-400 mile line with approximately 1/3 in Canada and 2/3 in the US.”  There’s no substation at the border, it’s not two separate lines or two separate projects, just two jurisdictionally separate proceedings.

And they’re accepting two things that should be questioned.  First problem is staff’s acceptance of Minnesota Power’s claim of 750MW transfer capacity increase.  Second is acceptance of elimination of the Blackberry – Arrowhead leg of the project without any analysis/question about why, and what that means for the project, which is just one leg from Manitoba Hydro off to Michigan.  A radial 500 kV line?  One that requires a Presidential Permit?  Going into the Blackberry substation?  Why?  Whatever for?  It’s good to let people along the Blackberry-Arrowhead stretch know that this project does not included that part, but it’s equally important not to give them false hopes that it’s out completely, because it will come back.

Commission Decision Alternative B3 should be crossed off, deleted, eliminated.

PUC Staff view of issues:

Staff identified two areas where the process could be improved. First, staff recommends that those members of the public who were initially included in the notice plan for the southernmost portion of the project should receive supplemental notice that their community is not under consideration for the current project. Secondly, staff recommends that because the public comments received during consideration of the certificate of need application primarily spoke to routing matters, these comments should be filed to that docket once a route permit application is open for comment.

It’s good that they’re directing the public advisor to file the routing related public comments  in the routing docket when filed, but look how they’re discounting the public.  Please DON’T presume that all public comments are about routing because they’re not.  Those regarding NEED should be considered in this NEED docket, and only those about route should be sent to the routing docket.

It’s good that they’re directing Minnesota Power to send materials to a library in each affected county, GOOD!!!

Now, on to the meeting next week.  See you there!

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Comments on Completeness

question_marks

Is the application complete?  The Public Utilities Commission will consider whether it is complete at its meeting on December 19, and remember, you can catch the meeting online.  The webcast link is on the meeting agenda, and they’re changing around the website so I don’t have a link now to post (and you might need an app to view).

Here are the Comments filed thus far.  The comment deadline has passed, but Minnesota Power made a statement that I just couldn’t ignore!

Public Comments 201311-93786-01

Public Comments 201311-93612-01

Public Comments 201311-93253-01

Commerce DER Comments – 201311-93825-01

Commerce DER_Comments_ Nov21_201311-93930-01

Large Power Intervenors_InitialComment_201311-93819-01

RegionalUtilities_Comments_201311-93834-01

The “Regional Utilities” Comment was interesting in that they’re saying that the Fargo CapX 2020 transmission line could do the job.  Granted the project is for export, which is the purpose of CapX 2020 too, but this one was designed to get over to Michigan.  What I like about it is that they’re showing that it is all about export, and I’d love to see them get into a pissing match about it.

And Minnesota Power had this to say:

Minnesota Power Reply Comments_201312-94238-01

And this part was more than a little odd:

Subject to Commission approval of the Certificate of Need for the GNTL Project, all of this upfront work will enable a June 1, 2020 in-service date as required under the PPA. At most it appears that the Regional Utilities have conducted additional transmission studies around the Concept. The Regional Utilities’ vague reference to these additional studies may be an attempt to position them for an intervention under Minn. Rules 7829.0800. However, at this time, the Regional Utilities do not appear to have a unique interest in the Project – a fully participant funded transmission line – particularly considering that the Department will represent the
interests of Minnesota ratepayers and the public.

As major transmission owners, suggesting an essentially competing transmission project as an alternative, yup, they’ve sure got an interest, and a unique one at that.

I fired off a Comment, just couldn’t let that slide:

Overland_December_10_2013

Onward — the PUC meeting is on the 19th.

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