Proposed High Voltage Transmission Line along a Greenway

Background
Our local electric utility, Xcel Energy, has proposed two new substations and a double-circuit high- voltage transmission line along the Midtown Greenway in Minneapolis. Xcel claims that this is the best/only way to increase the system capacity to meet the power needs of the area. (In recent years there has been significant development in the area with expansion of the Wells Fargo mortgage service center, expansion of two hospitals and a major office/retail/residential mixed-use redevelopment of an old Sears regional distribution center and store.

In Minnesota, this line will need the approval of the Minnesota Public Utilities Commission. In fact, state law gives the City of Minneapolis no say in this project--only the PUC has any authority. Xcel has filed a request with the PUC and the public process started last week with a public meeting. This week, the first meeting of the Public Advisory Task Force for the project happens (I am the representative from my neighborhood on that task force.)


At last week's public meeting, I provided the following testimony (well, it was close to what is below, I presented from notes, not from a written document--so this is based on those notes:

My Public Comments

Introduction:
My name is Sheldon Mains, I have lived in the Seward Neighborhood for 30 years and am the Seward Neighborhood Group Representative on the Public Advisory Task Force. These comments however are only mine. They have not been approved by the SNG board.

Over twenty years ago, I worked in the transmission line routing program when it was housed in the old Minnesota Environmental Quality Board. However, the staff assigned to this project were not involved with this program when I worked there. I did work with Deborah Pile, the person who is the assigned Public Advisory when I was in a different job in a different agency.

Public Adviser:
I'm going to take this opportunity to introduce Deborah Pile. As Public Advisor, it is her job to help the public be involved in this process. This process involves a lot of rules and procedures so she can be of great help (but can not provide "legal advice.) In short, it is her job to help the public fight (or support) this project. Contact her at Deborah.Pile@state.mn.us or 651-297-2375.

First routing project in a dense urban area:
The law and the rules for this state function were written assuming routing mainly over agricultural, forest and undeveloped land. There are rules and parts of the law that specifically deal with agricultural land, mining land and tourism. There is nothing that specifically deals with densely developed urban land.

This is the first VERY urban route the power line routing program has dealt with. You are going to have to be creative in applying the rules.

You have already done so in setting up the advisory task force—the rules call for at least one town board member—no town boards in Mpls but there are City recognized neighborhood groups—which you did include—thank you.

A few other places where creativity will be required:
Under Minnesota Statutes Section 216E.03 DESIGNATING SITES AND ROUTES
(5) analysis of the direct and indirect economic impact of proposed sites and routes including, but not limited to, productive agricultural land lost or impaired;

There is no agricultural land on this route. However, you will need to consider the direct and indirect economic impact on potential development along this route.

Minnesota Rules 7849.5930 PROHIBITED ROUTES Subp. 2. Parks and natural areas.
No high voltage transmission line may be routed through state or national parks or state scientific and natural areas unless the transmission line would not materially damage or impair the purpose for which the area was designated and no feasible and prudent alternative exists. Economic considerations alone do not justify use of these areas for a high voltage transmission line.

There are no state parks in Minneapolis. But the Midtown Greenway is a recreational and open space that serves an area of the state where there is limited recreational and open space. In fact, I would guess that if you added up the public use of ten average state parks in Minnesota, it would not come close to equaling the use of the Midtown Greenway. In fact, with the limited open space in this area of Minneapolis the PUC should require that XCEL pay the full cost for the replacement of any open space it uses.

Consideration of Alternatives:
MN Rules 7849.5920 FACTORS EXCLUDED.
When the Public Utilities Commission has issued a Certificate of Need for a large electric power generating plant or a high voltage transmission line or placed a high voltage transmission line on the certified HVTL list maintained by the commission, questions of need, including size, type, and timing, questions of alternative system configurations, and questions of voltage shall not be factors considered by the commission in deciding whether to issue a permit for a proposed facility.

This rule is clearly to avoid re-hashing need and alternative ways of providing for that need when there has been a Certificate of Need issued since those issues are dealt with in that process. This rule clearly only applies "When the Public Utilities Commission has issued a Certificate of Need..." There has been no Certificate of Need and none is required. Therefore, this rule does not apply and you are allowed to consider alternative ways of providing for the need and to review what the need really is.

Because of the above rule, and since it appears that the alternative routes down residential streets are not real alternatives (Xcel has not been able to provide an example of where they have place high voltage transmission lines down residential streets), you need to consider more alternatives.

A need for transmission capacity or distribution capacity?
It is clear that the power supply system for this area of Minneapolis needs to be improved. One thing that should be considered is whether the need for improved power supply in the project area is due to a need for more transmission or a need for improved distribution and more substation capacity). Back when I was working for the Minnesota Environmental Quality Program, I remember NSP (Xcel's previous name) proposing a transmission line from Minnesota to Eau Claire Wisconsin to improve the power supply in Western Wisconsin. It turned out in that project that much of the problem was caused by inadequate distribution, not inadequate transmission. Xcel never built that line and there doesn't seem to be a power shortage currently in Western Wisconsin.

Besides considering the character of the need, I propose that one alternative that is considered is what I call the One Substation Alternative:

• One new substation along the existing HVTL.
• Improved distribution from that substation and other substations serving the area. Remember, much of the distribution in this area is over sixty years old
• Replace old equipment and add capacity in existing substations that serve this area.
  

Who pays for undergrounding:
In rural Minnesota, when transmission lines follow survey lines or existing rights of way, it can cost more than going straight across an agricultural area. This specifically benefits only the farmers whose property is crossed but all rate payers for that power company pay for that additional cost. When the Benton County to Milaca line (I think in the early 1980s) was routed around the developed core of Milaca, all rate payers paid for it.

If it is decided that undergroundiing the best option here, all rate payers in the state should pay for it, not just the rate payers in the local area (as Xcel has proposed).

Thank you for your time