State regulators, state lawmakers, federal lawmakers, and community energy planners: Does the prospect of households paying an additional $160 per month on their electric bills prompt you to wonder what else could be done with these funds?












It is surprising how often climate change activists have to be reminded that it’s not the 1980s anymore. All large utilities, many large cities, many industry groups and utility-funded environmental groups are endorsing energy planning for either 50% or 100% renewable energy by a certain timeline. For the most part, environmentalists no longer confront utilities resistant to developing renewable energy, instead, utilities are begging State Regulators to allow them to own as many new solar and wind power plants as they can.

        As our most precious, land-based resources are in direct line of fire, the stage is set for truly historic, personal, community and institutional decision-making.

In Wisconsin, our Utility Regulators have never seen a new power plant or transmission line devised by MISO, the Midcontinent Independent System Operator, that they did not like. MISO is a not a governmental entity, as many tend to believe, it is a non-profit organization chartered and operated by transmission builders in the Midwest in 2001. MISO is not required by states or the federal government to plan additions to the Midwest transmission system; doing so is simply in the economic interest of transmission builders. Wisconsin Commissioners have had very close ties to transmission builders; some would argue too close. While serving as Commission liaison to MISO in 2019, Wisconsin PSC Commissioner, Michael Huebsch warned the public of imminent need for lines that are not even proposed when he voted to approve the controversial, $2.2 billion Cardinal Hickory Creek 345 kV transmission line,

And if you believe that this transmission line that we just put up is the last one you are going to have to deal with, you are wrong. . . There are more in the queue.”

Former Commissioner Michael Huebsch addressing the large, public, turnout at the Cardinal Hickory Creek transmission line decision, Madison, Wisconsin, August 20, 2019

Thus, it was with considerable trepidation that SOUL clicked on a March 17, 2021 publication by MISO’s Planning Advisory Committee entitled, MISO’s Long Range Transmission Plan Roadmap.1

Prior to 1998, Commissioner decision-making had to abide by Wisconsin-based energy planning conducted by PSC in collaboration with state utilities and public stakeholders. You read that correctly, public stakeholders. When ever a new power plant was proposed, the Advance Plan required that customer based alternatives be analyzed, first, and found to be less cost-effective. After the tedious but successful Advance Plan process was nixed by state lawmakers, PSC Commissioners began quoting MISO planning in their decisions– planning with bare trace of electric customer representation.6

The extreme liabilities of blindly backing MISO planning became painfully apparent in 2019 when PSC staff engineers carefully examined MISO modeling and discovered that a $900,000 transmission line rebuild that MISO planning had dismissed would deliver the same benefits as the very unpopular $621 million MISO, Cardinal Hickory Creek transmission line.2 In their final decision, Commissioners ignored the staff’s Alternative and in rationalizing their selection, cited MISO economic generalizations that were in direct conflict with PSC Staff findings.

Planning is the stage of problem solving when inclusiveness and open-mindedness occurs. Planning is when facts are agreed upon so that parties can iron out difficult differences and move forward, together. The casualty of not planning is harsh exclusion and dramatically eroded public confidence. The lack of energy planning in Wisconsin leads to physical losses, waste and cultural turmoil.

If states were to express reservations about MISO’s priorities, they would not be alone. Expert witnesses from other regions often comment that MISO planning is highly utility-centric. MISO’s utility members literally own a lot of power: 48% more power plant capacity per customer compared to PJM, the ISO with the most customers.3 MISO utilities own twice the power plant capacity per customer of utilities in the California ISO which is criticized for over-building.4

This article is an examination5 of multiple repercussions of MISO’s most recent planning followed by the investigation of a same-cost alternative that does take customers powers seriously.


The purpose of MISO’s annual exercise is in the name itself, Midwest Transmission Expansion Planning (MTEP). Despite electric customers having no vote in the planning,6 MISO proceeds to define the future electric service needs of 42 million electric customers served by its utility members.7 In effect, utilities submit wish lists for projects (transmission and power plants) that they would like to see endorsed by MISO for building during a defined planning window, in this case 2020-2039. MISO’s planning does not specify exact power plants or locations; it accounts for spending by amassed categories.8

Like most planning, the builders imagine differing future scenarios. In this cycle, three futures target three percentages of renewable energy to reside in Midwest outlets by 2039. Future 1 proposes increasing the amount from the current 9% to 26%.9 Future 2 proposes an increase to 36% and Future 3, an increase to 50%.10 As none of MISO’s futures aim for 100% renewable energy or Zero Carbon,11 SOUL focused its examination on the most ambitious future with a 50% renewable energy target.

The first step of energy planning is to identify existing need including demand for power, reliability issues and (if you are a transmission builder) whether wholesale power costs can be trimmed by reducing transmission system congestion. Lacking any of these traditional needs to cite, MISO’s report describes transmission “system barriers” that will arise in the future from an extraordinarily large number of requested new power plants, such as the 585 cited on page 4. On page 6 of the initial report, MISO shows these power plant requests and using a “build it and need will come,” logic defines planing that is inherently divorced from public need.12

Above graphic from page 6, MISO’s March 17, 2021 Planning Advisory Committee publication, Long Range Transmission Plan Roadmap. http://bit.ly/MISO-Roadmap-20210317

The color segments in each bar graph represent added power plants, by type, in the form of added energy consumption. From the present day to 2039, power plant and transmission builders plan MISO generating capability to grow an astonishing 282%, from a capacity of 170,000 MW to around 480,000 MW.13

MISO’s consumption reliant figures can be combined with power plant and storage costs and US Department of Energy (EIA) data to estimate megawatts (MW) of new power plants and costs for Midwest electric customer over the next 19-20 years:14

SOUL’s estimate of $1.8 Trillion translates to about $79 per month added to residential households electric bills with average use.15

Keep in mind that MISO’s planning would provide only 50% renewable energy to Midwest outlets. Experts argue that the last vestiges of carbon generation will be the hardest to replace, so its safe to assume that providing the remaining 50% renewable energy by 2050 would at least double MISO’s 2020-2039 spending.

If the $1.8 Trillion is simply doubled to $3.6 Trillion, the spending MISO adds to existing bills would require 80% of the total $4.5 Trillion analysts16 have forecast for all US customers to access 100% renewable energy. Notably, none of these industry zero carbon cost estimates engage the likely prospect of customers looking at their electric bills and wondering , Can I make my own 100% renewable energy for less than I am paying my utility to try to do it?

State regulators, state lawmakers, federal lawmakers, and community energy planners: Does the prospect of average households paying an additional $160 per month on their electric bills prompt you to wonder what else could be done with this these funds?



Note that the expense in the bottom line of SOUL’s $1.8 Trillion chart ($895 billion) comes from additional power use that MISO’s planning assumes.17 The 245% increase in electricity use can be seen on page 6 of MISO’s report in the taller height of the 2039 column compared to the 2020 column.18 MISO is projecting that Midwest customers will increase their use of electric power 4.8% per year with the impact of nearly doubling our current usage over 2020-2039 (84%).19

In forecasting this extraordinary growth rate, MISO incorporates unprecedented impacts from electrification. SOUL’s examination does not plunge into deep analysis of electrification but it is worth pointing out that some electrifications, like home heating conversion from natural gas to electric heat pump cause CO2 emissions to increase in many parts of the country. Will MISO utilities go on record urging customers to convert all power use to electricity use? Time will tell; but at this juncture, SOUL’s alternative assumes slow but significant conversions to electric vehicles (EV’s).20

As we wait to see what MISO assumes the public will electrify, it is prudent to stop and visualize the unprecedented growth in electricity use that power plant and transmission builders assume in the context of historical use.21

plant 4


MISO’s elegant graphics also allow one to grasp the large volume of proposed power plant additions. For example, compare the height of the green colored Wind segment in the current 2020 column to the green segment in 2039 under Future 3. Consider the height of the yellow solar segment in 2039 and there being no such segment in 2020.

Above graphic from page 6, MISO’s March 17, 2021 Planning Advisory Committee publication, Long Range Transmission Plan Roadmap. http://bit.ly/MISO-Roadmap-20210317

To address the variable nature of added, utility-scale wind and solar powered energy, MISO builders propose to collect about $186 billion from ratepayers for grid-scale battery storage. Despite this large amount of battery storage, builders also propose to increase Midwest reliance on natural gas generation 123%.22 This CO2 producing generation would remain in operation for decades challenging the feasibility of reaching zero carbon goals for the foreseeable future.

The graphic implies complete retirement of all coal power plants across the Midwest,23 but after the considerable natural gas plant additions (compare blue sections), MISO’s chart indicates that about13% more fossil fuel power would be consumed in 2039 compared to 2020.24 Does the building-premised planning do what PSC’s should expect it to do? Does it prioritize putting new steel in the ground above reducing CO2 emissions? There are indications it does.

Towards its Future 3 goal of 50% renewable energy, if MISO conducted comprehensive rather than expansion energy planning25 this would immediately recognize an evident need to control the projected, colossal growth in energy use. The proven tool to do this is Accelerated Energy Efficiency. By omitting this measure,26 MISO plans about 60% more new renewable generation than is required to hit the percentage based goal. How could this be?

There is a lot of waste in our homes, farms and businesses waiting to be eliminated. If Accelerated Energy Efficiency were used to steadily eliminate this waste and to offset electrifications keeping demand for power near 2020 levels, MISO’s 50% renewable energy target could be attained simply by: (1) Adding enough renewables to replace the retired coal plants and (2) Adding enough renewables to retire 13% of the existing natural gas plants.27 Not only is this approach far more resource efficient, it allows the remaining 87% of natural gas plants to be next in line for replacement. The comprehensive energy planning path would not double existing gas plants and make about 60% of the power plants MISO would add, unnecessary.

[SOUL is not promoting any utility-scale building, but illustrating the power of comprehensive planning where end users are part of the picture.}

Further, the use of energy efficiency to lower energy use also makes it easier to retire coal power plants. The reason for this was demonstrated in 2020 when COVID-19 caused around the clock demand for electric power to decline simulating the effect of improved equipment and dwelling efficiencies. For 2020, the US Department of Energy (EIA) reports that energy-related carbon dioxide (CO2) emissions decreased by 11% with 7% of the drop coming from the reduction in electricity use.28 With only a 3.4% annual decline in electricity use, emissions from coal generation dropped a very impressive 19%. CO2 reduction from the comparatively variable natural gas generation was more stubborn, these emissions increased 3%.

When coal plants are retired, electric customers still have to pay for them unless they are very old and have not been improved with expensive additions like smoke stack scrubbers. MISO’s $1.8 Trillion plan does not include continuing payment on debt for such “stranded assets.” Corporate leadership at publicly regulated utilities like WE Energies, Alliant, MG&E and XCEL have not yet proposed to absorb part or all of these considerable costs as part of good citizen corporate planning.


Most of the $500 billion that MISO builders ask customers to spend on utility-scale wind and solar power plants would be developed by “merchant” power plant builders (the Invenergy’s, NextEra’s, Pattern’s and EDF’s of the world).29 The bulk of the profit earned by these international companies flows out of state, if not out of the country.

Merchant power plant builders are a specialized class of utilities who face much less regulation than public utilities. They are not required to demonstrate that their proposed plants are necessary to provide adequate power; they are not required to show added plants would be cost or CO2 reduction effective compared to alternatives and merchant builders are able to use clandestine tactics in land acquisition that laws prevent public utilities from using. To add injury to customer insult, the public utilities end up owning said plants.

When public or regulated utility, like Alliant, seeks a new power plant, it is required to give formal public notice before they can start approaching potentially affected landowners. Often, the utility chooses to provide public information meetings to help avoid being criticized for secrecy. Current state law allows merchant plant developers to escape all expectation for public transparency. As Wisconsin public utilities rush to collude with merchant developers, the secrecy is causing daily shock and dismay all across Wisconsin.

On April 29, 2021, there were 64, active status solar, wind and battery storage projects in the MISO interconnection request queue in Wisconsin.

Above map of solar, wind and battery facility selections in MISO’s Generator Interconnection Queue on April 29, 2021. The resource is updated regularly at: http://bit.ly/MISO-Queue-Map

For merchant utilities, the most critical step of developing a power plant is leasing the large amount of necessary land. For a solar plant, this involves the merchant land agent driving down a rural driveway, talking with the property owner, one-on-one, offering to lease land for $1000 an acre, handing them a 60+ page lease contract, and, sometimes, an on-the-spot signing bonus. In most cases, no fundamental project information covering overall facility size, equipment dimensions, power ratings and maps is offered.

With rental prices for farming considerably lower than $1000 an acre, some landowners, especially absentee ones, sign the contract without getting experienced financial and legal advice.30 The land agent is then able to take this signed contract to neighbors and point out that they might be surrounded by solar panels and lose out on the benefit if they do not sign. When landowners do sign, developers discourage these households from talking about it enabling agents to continue seeking contracts without word spreading.

It is very possible for merchant developers to get 75% of the required land under contract before there is any published awareness of the merchant developer’s interests. By this time, unfortunately, the power plant developer can receive grid connection permission from MISO, make application to the PSC and get the project approved through a streamlined process that is very challenging for affected landowners and communities to contest.

The land leases often include 2% annual increases over a period of 40-50 years during which the developer holds exclusive development rights over the land. These contracts can also be sold to another developer.

If one does the math on $1000 per acre lease with a 2% annual escalator over 50 years, it becomes clear that the power plant owner has substantial financial interest to buy the land, outright after a few years. If the utility purchased the land at five times market value in 5-10 years, it could avoid more than half of the total cost of the lease payments over 50 years.31 Aside from a sea of solar panels, who would want to move to a rural township where a utility owned most of the land? This is of no concern to the utility interests because no studies of economic impacts are required.

Merchant plants also qualify for large federal level tax breaks and other credits, money that would otherwise go to funding public endeavors.

Because of the permitted secret dealings, the community or county at large may not even hear about the plant before it has been approved and purchased by a public utility.32 Recently, Alliant filed a single request to the PSC to buy five merchant power plants before some of the plants were even approved. Once owned by a public utility, the cost of the plant and guaranteed profit for the utility is passed onto ratepayers.

Lawmakers wisely forbid public utilities from accessing this streamlined process but they are taking full advantage of it, nonetheless.

To date, the largest solar plant proposed would occupy about eleven square miles abutting Cambridge and Rockdale, Wisconsin in Dane County and the Rockdale 345 kV substation.33 Utility interests are crowding around the MISO developed substation bringing as much as 650 MW of solar, 100 MW of battery storage, another .5 mile 345 kV transmission line and possibly and second or third natural gas power plant.34 If these build outs are realized, the Cambridge-Rockdale area could become the largest utility district in US. Ironically, it would never be tested for need or cost effectiveness and completely escape Environmental Impact Study.

As pictured below, landowners in Cobb/Montfort, Wisconsin are observing the construction of a 300 MW, 3000 acre, solar power plant with an estimated one million solar panels. Area farmers who did lease their land agree with those who did not that disruption to the lands is far more severe than they imagined. The excavations have already caused their ties to their land to dissolve before their very eyes. Area topsoil was scraped off and piled up. Clay subsoils were graded in slopes that completely obliterated the ancient, Driftless, watershed. Truck after truck of gravel was packed into the clay. Despite the power plant developer’s talk of creating “butterfly habitat,” and the land ultimately being “improved,” farmers note that weeds are certain to over the radically disturbed soils unless non-budgeted millions are spent towards prairie habitat.

300 MW Badger Hollow solar power plant under construction, March 26, 2021
Cobb/ Montfort, Wisconsin.


Much of the new land that MISO builders are seeking would be for wind power plants. In the first decades of rurally located wind power plant development, industry and academic studies35 estimated that an average of 70.6 acres of land was required per megawatt. Increasingly, experts who study the refined impacts of turbulence on power production expect this value to double as lower quality wind resources are engaged. The land requirements are staggering to estimate.

In the below graphic, the estimated land usage required for MISO’s added power plants is shown based on 140.6 acres per MW for wind and 10 acres per MW for utility-scale solar plants.36

The paired columns on the left represent land use requirements for utility-scale solar, wind and natural gas power plants in 2020 and the 32,000 new square miles required under MISO Future 3 with it’s 50% renewable energy target.37 For reference, the state of Indiana covers 35,867 square miles. Doubling MISO’s current power plant allocations to achieve 100% renewable energy would necessitate land impacts roughly equal to the land area of Missouri.38 Web searches produce other land requirement estimates that dwarf39 these estimates.

Independent studies40 have shown that property buyers are less inclined to purchase rural land in areas where there is substantial industrial presence resulting in land devaluations ranging from 5-45%. In the above graphic, the pair of columns on the right compares estimated property devaluation today to those created under MISO Future 3 by 2039.41 These losses are calculated as a 10% devaluation of land within 1 mile of the power plants. These losses are not included in the $1.8 Trillion estimated price tag.


MISO’s long-term planning42 includes an initial or an indicative map of the new, high-capacity expansion transmission lines that builders suggest would become necessary to support the power plant additions they have outlined in their 50% renewable plan.

SOUL has estimated the cost for what appears to be about 100 new, high -capacity expansion transmission projects at approximately $100 Billion based on a number of indicators.43

Above map from page 11, MISO’s March 17, 2021 Planning Advisory Committee publication, Long Range Transmission Plan Roadmap. http://bit.ly/MISO-Roadmap-20210317

A close-up view of just Wisconsin in the above map shows that transmission builders Xcel Energy and American Transmission Company are considering about eleven expansion transmission lines including nine, high-capacity 345 kV lines, one, higher capacity 765 kV line and one, ultra high capacity HVDC line that would span most of the state.

Above graphic based on a close-up screenshot of MISO’s page 11 map in the Long Range Transmission Plan Roadmap. http://bit.ly/MISO-Roadmap-20210317 The displayed routing is simplified and should not be taken as actual routing of transmission facilities. Pictured transmission facilities are part of MISO’s initial planning phase, not final selections.

Since 2002, Wisconsin PSC Commissioners have approved seven, 345 kV expansion transmission lines– each one opposing overwhelming, unified opposition from communities and ratepayers.44 Public reaction to the Commissioners’ 2019 approval of the 100 mile Cardinal Hickory Creek line (which included dismissal of PSC Staff’s one mile alternative)45 was swift and resolute. Appeals were filed by two affected counties, two municipalities, three organizations (including SOUL of Wisconsin) and a number of private intervenors. The fact that the multi-circuited, 180’ high, 345 kV transmission line would carve new corridor through the Upper Mississippi River National Wildlife Refuge has garnered the world-wide opposition of more than 48,000 petitioners.46

ITC-Midwest corridor clear cutting in-progress, February 2021, for the Cardinal-Hickory Creek 345 kV expansion transmission line just south of crossing the The Upper Mississippi River National Wildlife Refuge on the Iowa side of the river. The approval of this highly controversial transmission line by Wisconsin PSC Commissioners is being appealed in court along with related cases concerning Commissioner conflicts of interest and an Army Corps of Engineers imposed delay due to negative construction impacts on Native American historical assets. (Photo by Dena Kurt).

Before choosing to threaten the public with more MISO transmission lines, Commissioner Huebsch likely did not pause to consider the amount of wide spread opposition that even a single, new line in Wisconsin would incite. If Commissioners attempt to push through even a small fraction of the transmission builders’ selfish aspirations, it would have a devastating impact on public trust in the Commission and in utilities. Citizens and public defenders are very aware that they are conscripted to pay the costs of new utility steel in the ground because Commissioners can only do so in the name of public convenience and necessity, not for private interests.

At the final public feedback session of Governor Evers ’s Task Force on Climate Change in April 2021, the only topic receiving more discussion than doubling the state’s Energy Efficiency program was merchant power plant invasions of Wisconsin communities. These communities have no choice but to resist because they are losing their homes, farms and local economies. As SOUL’s customer investment Alternative shows, market place competition is on the side of communities, not utilities. It will not be long before urban neighborhoods are fending off utility occupation and demanding rights to develop local energy resources to save their communities as well.


Power plant and transmission line builders are very aware that climate change concerns are causing better off customers to consider opening-up their wallets. While the comprehensive losses of climate change cannot be quantified, the cost per residential customer for MISO-supplied 50% renewable energy can. From this estimate, the cost for 100% renewable energy and Zero Carbon by 2050 can be extrapolated:47

For MISO residential electric customers with average monthly use, the 2020-2050 total cost of utility service would carry a price tag of about $139,000.48

One, obvious, alternative to dollars flowing to utility interests is for customers to retain the dollars and make their own energy improvements. To this end, SOUL has modeled an alternative using accelerated energy efficiency, on site and community-owned solar, battery storage and modern energy management. Additional solar and storage has been added for electrifications including 50% of vehicle use converted to EV’s. The alternative engages all three sectors: residential, commercial and industrial.

For the same $1.8 Trillion49 that MISO’s plan asks of customers through 2039, each Midwest residential customer with average use would be able to make the following purchases with their $22,500, 20 year, “budget:”

  • Install 4.7 kW of rooftop/on-site or community located solar at a cost of about $11,800.50 (A 4.7 kW system has about 16 panels and requires a roof or lawn area of about 17’ X 17’ or 12’ X 27’.)
  • Install the equivalent of a 70% share of a Tesla Powerwall battery system, load management and make energy efficiency investments at a cost of about $10,700.

All solar installations are modeled as net metered or grid-tied. As such, battery storage and excess solar generation can be efficiently shared through local distribution lines. Solar and storage have been sized to offset 100% of customer electricity use, accommodate EV charging and manage power use during non-solar hours. The size and cost of the systems can be scaled-up for customers who require more power and scaled down for those who require less– all within MISO’s system-wide assumptions.

Unlike MISO’s planning which would only achieve 50% renewable energy, the Alternative provides participating customers 100%, “zero carbon,” renewable energy. 51 If adopted by Midwest customers at the rate 4% per year, the Alternative would enable existing renewables to contribute a significant 19% of energy by 2039 for off-solar hour powering and battery charging.

The alternative takes considerable advantage of energy use reductions by assuming customers would triple their current investments in state energy efficiency programs to match that high-performance states like Massachusetts.52 These improvements to buildings and equipment are excellent job stimulators in all local economies.

The below graphic compares the costs and benefits of the two, very different, energy investment paths in sid-e by-side 2039 electric bills. In this example, the residential customer made the solar +storage Alternative investment in 2020 under the option of cash or borrowing the funds. No incentives or tax credits have been applied except for a 26 cent per watt rebate for the solar investment matching that of the popular Focus on Energy program in Wisconsin. 53

Because solar panels have a life span of 30 years, the early acting customer is rewarded about $100,000 in avoided energy payments over 30 years (including battery storage in 20 years.)54

This emphasis on customer investment and home/business energy management creates the opposite of increasing use and utility reliance. The individual measures create net energy reduction over time even as electrifications such as EV’s takes place. In the graph below, the impact of MISO customers adopting the alternative customer investment at rate of 4% per year is compared to MISO future 3 with its 145% increase in energy use in the year 2039.55

The yellow area represents the avoided use of grid power relative to “current use” due to the steady adoption of the distributed solar, battery storage and energy efficiency. The electric vehicles (EV’s) adopted at the rate of 1.1% per year are charged by the customers’s solar investments.

The alternative requires no new power plants or expansion transmission lines.

For the year 2039, the model predicts that annual use of grid power will have fallen 54% which creates another direct benefit. The drop in demand would allow existing transmission lines to easily accommodate power from the renewables retained and maintained since 2020. Under 54% less use, this power could meet about 19% of the total demand for grid power. If the assumed 4% per year customer investment adoption rate continued through 2050, only 4% of customers would be relying on grid power.

Except for tripling the energy efficiency programs and allowing residents who cannot house solar to do so through community solar lots, the alternative requires very little policy action. Mathematically, it targets 96% zero carbon by 2050. The few policy changes effectively allow customers to compete with utilities in the fair market where a substantial, $32 per month electric service fee funds distribution and transmission line up-keep.56

Land-use wise, SOUL’s modeling assumes that 50% of the distributed solar is installed on-site and 50% would be located in nearby community-owned installations.57 Sized relative to customer use, the largest of these installations would be a few acres but, of course, all acres add up. If all 42 million MISO customers were to take the customer investment path, about 4,200 square miles of new land would be required.58

4,200 square miles is about 90% less than MISO’s 43,000 square miles when land use for transmission is folded in. MISO’s use figures and renewable energy percentages apply only to MISO utilities. The 43,000 miles do not include approximately 80,000 miles of new transmission lines with many more new power plants that nationally organized power plant and transmission line building interests are eyeing for the Midwest.59


Customer investment in energy efficiency, on-site solar, battery storage and load management signifiicantly out-performs potential MISO Future 3 spending for these considerations:

Environmentally: Applying the same dollar amount that MISO assumes customers to pay over the next 20 years, alternative customer investment in on-site or community-owned solar, battery storage and energy efficiency at the rate of 4% per year could achieve 96% carbon free energy by 2050 whereas MISO’s utility-scale spending only targets 50% renewable energy.

Economically: For a Midwest residential customer with average use, the alternative $22,500 investment would save about $100,000 over 30 years through avoided energy costs while providing outage protection through solar+ battery storage. To increase grid dependency under MISO’s 50% renewable energy planning would add about $79 per month to the same electric bill, on average, over the first 20 years.

Local Economic Health and Land-Use: The large number of new power plants and transmission lines in MISO’s plan would negatively impact about 43,000 square miles of land and thousands of rural economies. Full deployment of the customer investment alternative would require about 4,200 square miles of distributed facilities, a 90% reduction in negative land impacts in comparison.

Capitalizes on Existing Renewables. Due to reduced grid dependencies of the Alternative path, our current Midwest renewables (52 TWh) would provide about 19% of grid power in 2039. With grid congestion essentially non-existent under radically declining demand, existing wind and nuclear power would travel widely and efficiently for charging home, business and industry batteries during non-solar hours.

The primary reason that ratepayers, environmentalists, elected officials and decision-makers are easily hypnotized by utility expansion promotions is the inability to envision better spending options. Because of the sheer economic advantages of the customer investment path, the number of people enslaved to centrally-supplied power will steadily shrink. As the high costs of utility expansion are understood, the ability to spend or borrow $20,500 to ultimately save $100,000 will become a key lesson in Home Economics 101.

A great deal of contemporary advertising touts increased personal power and ease through miniaturizations. US consumers are intrigued with gadgets and the act of controlling their environments. Customer energy investment is an aesthetic that produces savings. If that is not enough incentive, keep in mind that humanity has never like BIG GLARING THINGS, especially in natural settings.

Has the time arrived to escape the chains of Reddy Kilowatt60who proclaimed in 1926 that electricity is a slave ready to serve us? Ours is the age of fair and distributed liberties not of increasingly consolidated power. There is too much to lose by allowing ourselves to feel powerless.

For questions and information, contact SOUL of Wisconsin, info@SOULWisconsin.org

1 MISO Long-Range Transmission Plan Roadmap, Planning Advisory Committee, March 2021 https://cdn.misoenergy.org/March%2017%202021%20PAC%20Item%2003a%20LRTP%20Initial%20Roadmap541171.pdf

2 PSCW Commissioner approval of the MISO project, Cardinal Hickory Creek, is currently in appellate court. SOUL’s Briefs contain accounts of staff’s over-looked findings at https://apps.psc.wi.gov/pages/viewdoc.htm?docid=372122 and https://apps.psc.wi.gov/pages/viewdoc.htm?docid=372750 .

3 Data source: RTOs and ISOs: Uniformity, Regionalization, and Future Challenges, Alexandra B. Klass, University Minnesota Law School, March 2015 at pdf p. 3, https://hepg.hks.harvard.edu/files/hepg/files/3_klass.pdf?m=1523993841

4 Californians are paying billions for power they don’t need, LA Times, By Ivan Penn and Ryan Menezes, Feb. 5, 2017 https://www.latimes.com/projects/la-fi-electricity-capacity/

5 A spread sheet with calculations and assumptions is available by emailing info@SOULWisconsin.org

6 Lack of electric customer input was queried and borne out in cross-examination of MISO planner Mathew Ellis and also through discovery before the Wisconsin Public Service Commission and Iowa utility Board. For example. .pdf p. 51 of https://apps.psc.wi.gov/pages/viewdoc.htm?docid=372325 To Ellis, “Has MISO ever done direct contact to end use customers?” Ellis: “Not to my knowledge,” For MTEP plan voting, the organizations that represent customers are represented by a single appointee who abstains.

7 https://mrec.org/files/2020/02/Mosolf.ChallengesForRTOs.2020.pdf#page=5 (pdf p. 5)

8 See pdf p. 6, MISO Long-Range Transmission Plan Roadmap, Planning Advisory Committee March 2021 https://cdn.misoenergy.org/March%2017%202021%20PAC%20Item%2003a%20LRTP%20Initial%20Roadmap541171.pdf#page=6

9 The 9% figure can be found on pdf p. 15, Table A1: Capacity, Energy Output, and Price-Setting by Fuel Type 2018–2019, in Potomac Economics’ Report on MISO performance, 2019 State of the Market Analytical Appendix, June 2020 https://www.potomaceconomics.com/wp-content/uploads/2020/06/2019-MISO-SOM_Appendix_Final.pdf#page=15

10 See pdf p. 7 MISO Long-Range Transmission Plan Roadmap, Planning Advisory Committee March 17, 2021 https://cdn.misoenergy.org/March%2017%202021%20PAC%20Item%2003a%20LRTP%20Initial%20Roadmap541171.pdf#page=7

11 In citing attributes of the MISO-planned, Cardinal Hickory Creek 345 kV transmission proposal on August 20, 2019, PSC Commissioner Huebsch described the project, “And is the best option to provide a safe, reliable and affordable electric needs of our state and the goal of a more carbon free energy portfolio.”

12 State goals are mentioned without citation. Wisconsin is said to be one of four states with “100% renewable energy goals” which is not the case. The Governors’s zero carbon pledge has not been sanctified with legislation or PSC policy.

13 Capacity factors for the TWh to MW nameplate calculations were derived from data provided on pages 6 and 8. See SOUL spreadsheet tab, “MISO Future 3 Costs + Comp ALT” available by emailing info@SOULWisconsin.org

14 MISO states its 2018 capacity as 177,000 MW https://mrec.org/files/2020/02/Mosolf.ChallengesForRTOs.2020.pdf Power plant cost estimates include construction capital, revenue adders, O&M, land leases and other expenses. See spreadsheet tab, “MISO Future 3 Costs + Comp ALT” available by emailing info@SOULWisconsin.org

15 All dollars are 2020 dollars without impacts of inflation and financing factors. Use is calculated from 2020 to 2039 with this formula: Residential percentage of MISO use (.383) * total cost of $1,815,966,962,290 ($696,909,164,887) / Residential percentage (.8732%) of 42 million MISO customers (36,672,378) / (240) months. See spreadsheet tab, “MISO Future 3 Costs + Comp ALT” available by emailing info@SOULWisconsin.org

16 CleanTechnica: https://cleantechnica.com/2020/10/29/us-energy-2050-100-carbon-free-100-electric-up-our-game-6x-part-2/ Wood Mackenzie estimated $1.8 Trillion for 50% renewable energy for all US electric markets, not just MISO: https://www.woodmac.com/our-expertise/focus/Power–Renewables/us-renewable-energy-policy-scenario-analysis/

17 See Rows 198-203, spreadsheet tab, “MISO Future 3 Costs + Comp ALT” Spreadsheet is available by emailing info@SOULWisconsin.org

18 576 TWh consumed during 2020 and 1,422 TWh consumed in 2039.

19 See rows 198-199, spreadsheet tab, “MISO Future 3 Costs + Comp ALT” Spreadsheet available by emailing info@SOULWisconsin.org

20 Clean Technica estimates that electricity use due to electrification will increase about 3.5% per year. See Row 126, Column G “ALTERNATIVES – ENERGY USE Costs” tab in SOUL Spreadsheet. According to 2019 Bloomberg analysis, annual passenger EV sales surpassed 2 million in 2018, are expected to increase to 10 million by 2025, 28 million by 2030. Bloomberg expects about half of passenger vehicle sales with be EV’s by 2040. Under a similar growth rate, Clean Technica estimates that 23% more power would be required for EV’s in 2035 compared to use at 2019. SOUL applied this ratio as a growth rate. https://cleantechnica.com/2020/10/17/us-energy-2050-100-carbon-free-100-electric-up-our-game-6x-part-1/

21 MISO does not provide past usage records for public examination. Historical use was estimated using EIA data, totaling annual energy use for key MISO states and proportionally applying the annual deviations to MISO’s 2020 TWh figure. See “EIA Electricity Data” spreadsheet tab

22 Calculation: (Gas 2039 (411) TWh / Gas 2020 (198) TWh) – 1 = 2.227

23 MISO planning suggests there would be no generation from coal by 2039 but the numbers are discrepant with Wikipedia list: https://en.wikipedia.org/wiki/List_of_coal-fired_power_stations_in_the_United_States According to WIKI, there are about 90 coal plants in MISO states totaling 78,050 MW but some of these are in other ISO’s. MISO’ retired generation figure of 192 TWh at MISO’s Capacity Factor of .4 computes to 54,795 MW of retired plants whereas WIKI’s and PSCW’s factors of .6 and .7 compute 192 TWh to 36,530 MW and 31,311 MW, respectively.

24 Calculation: 441 TWh Gas (2039) / (198 TWh Gas + 192 TWh Coal ) -1 = .13

25 Also called Integrated Resource Planning (IRP) where all energy spending options are considered including demand side improvement of load management, energy efficiency, conservation, distributed generation, battery storage and non transmission alternatives. Wisconsin’s Advance Plan energy planning prior to 1998 was IRP.

26 MISO’s past expansion planning has placed the greatest investment in energy reduction measures such as energy efficiency under the future with the highest economic activity and growth. If consistent, Future 3’s 4.8% per year growth includes their maximum reduction measure investments.

27 For calculations, see Rows 1-17, Columns V-AA, spreadsheet tab, “MISO Future 3 Costs + Comp ALT”

28 U.S. energy-related CO2 emissions declined by 11% in 2020, EIA, APRIL 12, 2021 https://www.eia.gov/todayinenergy/detail.php?id=47496

29 These companies are regular donors to groups like RENEW Wisconsin who promote utility scale development without reservation. See profiles of some of the companies at http://bit.ly/RENEW-WI-UtilityDonors

30 The developers tout $4,000 per MW annual payments split between town/county governments but these are largely reimbursements for lost tax revenue as utility property does not pay taxes. Initially, land lease payments seem attractive but much less so when compared to the inherent value of uncompromised property appreciating at the average rate of 4-6% per year and the community upheaval the plants create.

31 Assumptions: 2021 value of land: $6000 per acre; lease $1000 per acre with 2% annual escalator; cost of lease over 50 years in 2021 dollars: $87,200; land buyout price in year 5: $30,000 per acre; prior lease payments: $5,204 per acre. Savings to utility: $52,067 ($87,271- $30,000- $5,204)

32 On April 30, 2021, the Wisconsin State Journal first alluded to concerns of Potosi, Wisconsin at the same time it reported that the Wisconsin PSC had approved the merchant developer’s application. http://bit.ly/GrantCountySolarApproval_20210430

33 On map: http://bit.ly/Rockdale345kVSubTransmission

34 See sought assets in MISO queue on map: http://bit.ly/DaneCoEnergyDistrict

35 See .pdf p.4, THE FOOTPRINT OF ENERGY: LAND USE OF U.S. ELECTRICITY PRODUCTION, Strata, 2017 https://www.strata.org/pdf/2017/footprints-full.pdf Corrigendum: Observation-based solar and wind power capacity factors and power densities, 2018 Environ. Res. Lett. 13104008) Lee M Miller1,3 and David W Keith1,2

36 10 acres per MW is based on 3,000 site controlled acres for the 300 MW Badger-Hollow solar plant in Cobb/Montfort, Wisconsin. Nearby, an application for 91.6 MW wind facility was filed on May 6, 2021 utilizing 12,200 acres or 133 acres per MW. See .pdf p. 3 https://apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=411086

37 See SOUL spreadsheet tab, “Land Use of MISO Plan ”

38 Missouri land area covers about 68,886 square miles. https://state.1keydata.com/states-by-size.php

39 ENERGY TRANSITIONS Biden’s dilemma: Land for renewables, Peter Behr and Jeffrey Tomich, E&E News, March 24, 2021 https://www.eenews.net/stories/1063728295

40 See comparison of utility-funded vs independently studies of wind turbine impacts on property values collected by McCann: http://bit.ly/WindTurbinePropertyValueImpactKielischMcCann Utility studies pose there are modest negative impact on values while those conducted by independent evaluators show very significant range of losses from 15-45% with an average of 29%.

41 Based on a recent MISO queue of active projects, the estimate assumes wind power plants have an average size of about 131 MW, solar power plants an average size of 144 MW and natural gas plants, 206 MW. These assumptions compute to approximately 1040 wind, 864 solar and 207 gas power plants would be surrounded by 21,525, 4,381 and 700 square miles, respectively, at a distance extending 1 mile from the plants. Assuming a Midwest average cost of $3,200 per acre, the estimated value of the surrounding properties within 1 mile totals about $1.3 Billion, today, and would be about $8.3 Billion higher with MISO plant expansions by 2039.

42 MISO Long-Range Transmission Plan Roadmap, Planning Advisory Committee March 2021 https://cdn.misoenergy.org/March%2017%202021%20PAC%20Item%2003a%20LRTP%20Initial%20Roadmap541171.pdf

43 Comprehensive, cost accountability for transmission lines is difficult to ascertain. For example, MISO estimated the 100 mile, 345 kV Cardinal Hickory Creek line at $492 million. PSC staff estimated comprehensive cost at $621 million or $6.21 million per mile– 26% more than MISO’s estimate. 345 kV lines are the least costly facilities in MISO’s plan which includes 500 kV, 765 kV and HVDC (High Voltage DC which may be under-grounded). SOUL estimates the map on p. 11 represents in the neighborhood of 10,000 miles of new transmission under Futures 1,2 and 3. The $100 Billion total estimate creates an average cost of $10 million per mile appears to be reasonable considering that some of the lines would be built in the future when inflation could make the costs higher. See calculations in “MISO Future 3 Costs + Comp ALT” starting at row 362

44 List: http://soulwisconsin.org/Resources/FootnoteHarbour.pdf#page=46 For degree of public opposition, see SOUL Initial and Reply Briefs for Cardinal Hickory Creek. https://apps.psc.wi.gov/pages/viewdoc.htm?docid=372122 and https://apps.psc.wi.gov/pages/viewdoc.htm?docid=372750 Wide public input received during the PSCW review of Badger-Coulee Proposal was more than 98% opposed.

45 PSC Staff’s Base With Asset Renewal Alternative (BWARA) is comprised of re-building three, 70 year old transmission lines with modern wires that would double their power carrying capabilities. The cost of the up-grading the lines which are reaching the end of their expected lifespans was ~$900,000 compared to the Cardinal Hickory Creek Project at $621 million before being scheduled for decades of payments. BWARA received wide support including that of state lawmakers representing the affected area. https://apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=372611

46 Petition at https://www.change.org/p/us-army-corp-of-engineers-stop-the-destruction-of-the-upper-mississippi-river-national-wildlife-fish-refuge?

47 In departure from vague, CO2 reduction accountability, MISO’s most recent planning targets identified, precise volumetric outcomes. Combined with other knowns and conservative assumptions, observers are able to estimate MISO’s future rates and usages to much greater extent.

48 All SOUL cost calculations are in today’s dollars without the cost of financing or adjustments for dollar devaluations except where noted. This 2020-2050 total includes power, electrical service fees, the large increase in energy use, MISO’s capital additions and rates continuing to increase at the historical rate of 2.5%. For conservative simplicity, use is assumed to be flat from 2040-2050 as carbon reduction efforts shift to consumer side improvements, even under MISO’s purview. See rows 130-159 and 186-192 of tab “MISO Future 3 Costs + Comp ALT”

49 To power all MISO homes, businesses and industries with 100% distributed solar + storage, the modeling indicates the Alternative would cost about $1,847,961,138,935 or 1.7% more than the $1,815,966,962,290 estimated for MISO future 3 costs.

50 Customer on-site and community-owned solar installation costs from 2020-2039 are both assumed to average $2.50 per watt for Residential customers, $2.00 per watt for Commercial customers and $1.30 per watt for Industrial customers. See tabs for each sector in SOUL’s spreadsheet. An article assessing three studies estimates that the price of solar will decline 34% by 2030 and 63% by 2050, Will solar panels get cheaper? https://www.thesolarnerd.com/blog/will-solar-get-cheaper/

51 As energy efficiency and customer based solar and battery storage incrementally reduce use of MISO system generation, funds to continue legacy payments on MISO plant and transmission line investments built before 2020 are accounted for in the modeling by assuming a rate inflation rate of 2.5% per year. Higher inflation rates can be experimented with in the modeling.

52 The added cost of the state energy efficiency programs is about $46 billion. See ALTERNATIVES – ENERGY USE tab of SOUL spreadsheet

53 The CO2 emission comparison figures in the cover graphic can be found in the MISO Future 3 Costs + Comp ALT tab, rows 162-167 Rows H-O. .26 X 4,700 watts is a one time rebate of $1,220 funded by the accelerated efficiency program allotments.

54 MISO 30 year costs at $139,300 – Alternative 20 year costs at $38,957

55 See “2010-2039 MISO vs Alternative Use Graph” tab in SOUL’s spreadsheet

56 $32 per month X 42 million customers is $16.1 Billion per year which is about ½ of MISO annual gross market transactions in 2018. https://mrec.org/files/2020/02/Mosolf.ChallengesForRTOs.2020.pdf

57 Residential 1,081 sq. miles, Commercial 1,892 sq. miles and Industrial 2,028 sq. miles. See assumptions on row 45, column P of the “100% RESIDENTIAL.. COM.. INDUS solar ALT” tabs

58 See starting at row 86, “Land Use of MISO Plan ” tab in SOUL’s spreadsheet

59 See Americans for a Clean Energy Grid recent article, TRANSMISSION PROJECTS READY TO GO: PLUGGING INTO AMERICA’S UNTAPPED RENEWABLE RESOURCES by Goggin, Gramlich, and Skelly. At p. 11. Twenty-two transmission projects covering 8,000 miles are described as, “about 10% of the transmission investment that is needed to decarbonize the power system.” None of the 22 transmission lines the national group features overlap with transmission projects s on MISO’s indicative map on .pdf p. 11 of MISO’s report.


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