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Iowa Utilities Board

February 15, 2018
Emmetsburg News

What is the responsibility of the Iowa Utilities Board (IUB)? The "Mission" statement, is "The Iowa Utilities Board regulates utilities to ensure that reasonably priced, reliable, environmentally responsible, and safe utility services are available to all Iowans."

One of the IUB's responsibilities is issuing certificates for electric generating facilities to operate.

Iowa Code 476A 1:5 ""Facility" means any electric power generating plant or a combination of plants at a single site, owned by any person, with a total capacity of twenty-five megawatts of electricity or more and those associated transmission lines connecting the generating plant to either a power transmission system or an interconnected primary transmission system or both." However, the IUB has provided a loophole by defining a facility as just a gathering line within the site.

That is the issue here, what is defined as a "facility." Is it a commercial electric plant of 340 MW or 14 to 15 "gathering lines" of less than 25 MW.

To explain what a "gathering line" is and why only up to 25 MW is an issue is as follows:

1. A gathering line is the underground cable that connects each industrial wind turbine together, which then runs to a substation.

2. The substation then either boosts or lowers the voltage prior to sending the electricity onto the transmission grid.

3. Each turbine has a 2MW capacity in the Palo Alto facility.

4. So, you would put 12 turbines on one gathering line, for 24 MW.

5. So, 170 turbines would have 14 to15 gathering lines for a commercial industrial wind electric plant, generating up to 340 MW.

The reason that electric utility companies are using the 25MW ruling, is to avoid doing an environmental review, which is part of the mission statement of the IUB. The IUB is shirking their fiduciary responsibility to rural residents of Iowa by allowing this to continue. If this was a gas or coal electric generating plant that produced 340 MW, that plant would be required to apply for a certificate from the IUB. Why should wind be any different?

In addition, the point is that the IUB was given the chance with our petition for declaratory order to finally justify the gathering line threshold for determining what is a facility requiring a certificate from the IUB, and the IUB failed to provide that justification - because they can't justify it. By allowing wind project developers like MidAmerican to evade the environmental review that would be required to obtain a certificate the IUB is failing in carrying out its mission statement.

The Office of Consumer Advocate in their response brief to the IUB, filed January 5, 2018, DRU -2017-0003; comments; "The current practice of dividing a wind energy project into multiple gathering lines with a total capacity of twenty-five megawatts of electricity or less to avoid requesting a certificate pursuant to Iowa Code 476A.2 increases costs to customers." How? By trying to keep the gathering lines under 25 MW, the utility company has an incentive to avoid regulation at a cost to customers by increasing the gathering lines therefore increasing the cost of the project to avoid complying with the regulatory requirements of Iowa Code 476 A. This increase in cost is then passed on to the customer.

Bertha Mathis

Emmetsburg, IA



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