WISCONSIN REGULATORS AND MISO

ESTIMATING THE COST OF MISO’S LONG RANGE PLAN

MISO’S ELECTRIFICATION IMPACTS

MISO’S POWER PLANT ADDITIONS

MERCHANT POWER PLANT DEVELOPMENT

MISO’S LAND RQUIREMENTS

MISO’S TRANSMISSION REQUIREMENTS

SOUL’S CUSTOMER INVESTMENT ALTERNATIVE

SUMMARY

WIS

WISCONSIN REGULATORS AND MISO

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.”

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.
est

ESTIMATING THE COST OF MISO’S LONG RANGE PLAN

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

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?

LECT3

MISO’S ELECTRIFICATION IMPACTS

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 POWER PLANT ADDITIONS

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.

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.

MERCHANT POWER PLANT DEVELOPMENT

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.

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.

land 5MISO’S LAND REQUIREMENTS FOR ADDED POWER PLANTS

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 TRANSMISSION REQUIREMENTS

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

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.

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

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.

SOUL’S CUSTOMER INVESTMENT ALTERNATIVE

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

SUMMARY

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.

60 Trademark, REDDY KILOWATT CORPORATION

Very few residents of Iowa and Lafayette Counties in Wisconsin are aware that a Canadian-owned, multinational corporation, Pattern LLC,¹ has salespeople on the ground courting landowners to exchange a few hundred dollars for signed agreements so that Pattern can build about 86, ~650 foot high² Wind Turbines. Unless landowners slow down and make an effort to understand underlying liabilities and chose to not sign agreements, Pattern LLC will be enabled to hurry though weak, county-level reviews³ without sufficient accountabilities. Next, Pattern would submit application to the Public Service Commission of Wisconsin where, despite the state’s over-abundance of generation, Commissioners rarely encounter a new power plant they don’t approve of. Further, a “merchant” power plant as Pattern LLC seeks, despite its whopping 300 MW size, would not not evaluated for need, its economic competitiveness with end user alternatives for CO2 reduction and impact on Wisconsin electric bills.

Following are some, high order, landowner, local economic and health concerns that landowners, their affected neighbors and their elected officials are likely not yet familiar with:

• The most common complaint with large wind turbines is persistent noise often described as a, “continuous jet engine.” Sub-sonic pulses described as, ”hammering” can also materialize.⁴ Sustained noise 3-7 times louder⁵ than natural settings have caused severe loss of sleep, debilitating nausea, headaches, decline in ambition, memory loss, depression and other personal afflictions that have forced families to re-locate.⁶ In addition to scientific studies these WI interviews⁷ are useful to watch.

• At present, Iowa and Lafayette County Wind Ordinances provide no protections against large WT noise and sub-sonic hammering. At the very least, citizens must demand their County quickly adopt Wisconsin’s (PSC Code Section 128) suggested day and night noise limits (50 and 45 dBA) into their county level Wind Ordinances to at least create legal grounds for address. Landowners, Towns, Villages and Cities would be prudent to contact their County Planning and Zoning Committees and request inclusion of all provisions under State Code 128 into their County Wind Ordinances, ASAP.⁸

• There are complex negative impacts from large wind turbines that extend well beyond the minimum 1250 feet⁹ distance from residences that Wisconsin allows. There is a trend among municipalities across the county to increase this “setback” distance to a minimum of 3000 ft.¹⁰ Worsening risks, wording in landowner contracts allows the developer the option to position wind turbines wherever they want on the signee’s land. This makes acting neighborly and consulting with one’s neighbors before signing into a blind exercise. Landowners cannot even guess where negative impacts might occur and where new construction on neighbors’ properties would become illegal or imprudent– all at considerable distance.

• Following the inability to list and sell impacted properties¹¹ and net losses in tax bases even with infusion of state tax dollar subsidies,¹² the second most common complaint is shadow flicker disorientation from the rotating blades.¹³ Developers claim they can avoid this but the modeling is far from perfect. County ordinances lack minimal¹⁴ State Law flicker protections for large turbines which still allow impacts on all animals.¹⁵ Under current ordinances and contracts, Pattern is not obligated to accommodate landowner concerns until the turbines are built. “Mitigations” are often, “pointless.”¹⁶

• Historically, un-compromised land appreciates in value about 4% per year.¹⁷ When a turbine is added and property value drops 15%,¹⁸ Pattern’s estimated per MW payments may not cover this loss if the property is sold. Over 40 years, with a 15% sale loss included in revenue estimates, one turbine on a 160 acre parcel produces about one-third of Pattern’s estimates.¹⁹

• In address of climate change, improving electric customer efficiencies and home/local power reduces CO2 emissions far more cost effectively because use of grid power averaging only 9% wind power is greatly eliminated.²⁰ If the approximate, $900 million total cost of the Uplands Wind System were spent, instead, on Focus on Energy solar panel rebates for WI homes, this would remove three times more CO2 emissions than Uplands and save solar households ~$107 per month.²¹

• Further, a Harvard study²² analyzing hundreds of WT systems found that area ground temperature at night increase as much 2.7 degrees resulting in higher dwelling cooling costs and altered natural habitats. Farmers report significant health issues with livestock²³, extensive soil compaction²⁴, reduced wildlife populations²⁵. Utilities document significant bird and bat kills.²⁶

SAVE OUR UNIQUE LANDS – DO NOT SIGN WITH PATTERN LLC

For footnotes, visit: http://bit.ly/Uplands-3 Questions? Contact: info@SOULWisconsin.org or 608-625-4949

1 https://investors.patternenergy.com/financial-information/quarterly-results and https://www.prnewswire.com/news-releases/pattern-energy-enters-agreement-to-be-acquired-by-canada-pension-plan-investment-board-300950682.html

2Pattern is not yet publicizing turbine height information. October 2018 letters to prospective property owners near Montfort concerning the “Red Barn” wind power plant, specify total turbine heights ranging from 459 to 656 feet. Larger units are usually sought because they are more dollar efficient. For comparison, the existing turbines along Highway 18 east of Montfort are 329 feet high https://www.we-energies.com/home/montfort-wind-energy-center.htm

3County level reviews of power plant proposals are fundamental to granting necessary county permits before the proposal goes to the state Public Service Commission. All public concerns and interests must be spelled out in County Ordinances in order to require address by Pattern LLC. These include providing in-depth financial accountabilities, requiring site-specific studies of potential health impacts and specifying public information meetings to be required. Iowa County’s Wind Siting Ordinance can be accessed here: https://bit.ly/IowaCo-Wind-Ord Lafayette County’s here: https://bit.ly/LafayetteCo-Wind-Ord

4These impacts are usefully described in the five Interviews with Wisconsin Wind Farm Residents conducted by Tim Harmann of Brown County Citizens for Responsible Wind Energy. https://bit.ly/WI_Wind_Interviews

5The quieter the background sounds are, the louder the introduced noise seems. The 3-6 times difference in apparent loudness with and without a wind turbine is based on agricultural settings having natural sound levels at night of 27-30dB(A) or lower. WI law permits wind turbine noise at residencies at night to be as high as 46 dB(A). In Iowa, landowners have measured turbine noise at their homes in excess of 70 dB(A). Each 6 dB(A) increase is perceived as a doubling in loudness. The Wisconsin permitted 46 dB(A) level is 19 dB(A) greater or 3 times louder than natural sounds at night. The difference masks many natural sounds, makes energy efficiencies like sleeping with window open at night impossible and causes many persons to experience sleep loss. If the noise should reach 70 dB(A), the additional 24 dB(A), would make the turbine noise more than seven greater than natural, rural sounds at night. Dr. Robert Rand discusses the sub-sonic phenomena starting at 1 hour, 27 minutes into this video: https://www.youtube.com/watch?v=2kvoZO-DEho&feature=youtu.be

6Families were obliged to move when the much smaller Shirley Wind system with 8, 2.5 MW turbines was installed. https://www.wbay.com/content/news/Brown-County-Board-meeting-on-Shirley-Wind-Farm-444039653.html See video of the special public health meeting that was held in 2017, https://www.youtube.com/watch?v=2kvoZO-DEho&feature=youtu.be

7Interviews with Wisconsin Wind Farm Residents, conducted by Tim Harmann of Brown County Citizens for Responsible Wind Energy. https://bit.ly/WI_Wind_Interviews

8Iowa County Planning & Development 222 N. Iowa St. Dodgeville, WI 53533 608-935-0398; Lafayette County Planning and Zoning Committee: 626 Main Street, Darlington, WI 53530, 608-776-3836

9Wisconsin PSC Code Section 128.13 and referenced Table 1: http://bit.ly/WI_128_SetbackTable1

10Wind Turbine Safety Setbacks Now Exceeding 3000 Feet, http://bit.ly/MuniSetbacksGreaterthan3000ft

11See interview with Jim Volmer starting at 04:54 https://bit.ly/WI_Wind_Interviews

12Land that houses power plants does not pay property taxes in Wisconsin. If the 300 MW power plant is approved, state tax dollars would be diverted to cover a portion of lost tax revenue. The financial ability of this subsidy to cover lost tax revenue losses has not been demonstrated and may not unless counties ask for accountability. Further, these diverted state tax dollars contain no compensation for equally significant tax base losses as properties within the counties and municipalities are sold at declined property values. SOUL estimates an average annual decline of $1 to $2.6 million in property devaluations spread across the immediately affected jurisdictions. See Tab 2 of downloadable spreadsheet at: http://bit.ly/PropertyTaxDevaluationImpacts The bottom of the range is based on Wisconsin’s historical sales rate of .6% of agricultural land being sold each year (27%, cumulatively, over 40 years) and a modest 5% decline in property values within one mile of turbines. The higher range is based on a .9% per year sales rate (40% over 40 years) and a, still modest, 10% decline in property values.

13See multiple video documents by landowners; interview with Elizabeth Eberts starting at 03:34 Wisconsin Wind Farm Residents https://bit.ly/WI_Wind_Interviews

14Wisconsin PSC Code Section 128.15 permits up to 30 hours a year http://bit.ly/WI_128_Flicker This standard is particularly challenging to meet when turbines are placed on hills above valleys where shadow projections can reach many residences, work places, livestock, natural habitats are recreational resources at large distances.

15 Wisconsin poultry farmer Jim Vollmer describes large losses at his chicken operation starting at 02:00 https://bit.ly/WI_Wind_InterviewsThe article, Do Wind Turbines Harm Animals?contains a number of links to landowner accounts.

16See multiple interviews with landowners; interview with Elizabeth Eberts starting at 03:34 Wisconsin Wind Farm Residents https://bit.ly/WI_Wind_Interviews

17Appreciation rate based on sales, http://bit.ly/WI_Ag_Land_Sales_4_Percent . From 2000-2018, the value of agricultural land in Wisconsin increased more than 6% per year from $1,804 to $5,818 per acre. From 2014 to 2018, values rose 4% per year. It is safe to assume continuation of the 4% appreciation rate as, “[The Covid-19] virus is impacting how we spend money, how we shop and, perhaps, even where we want to live. Data from Realtor.com shows suggests people are interested in moving and there seems to be an increasing appeal in properties outside of cities. The Realtor.com figures, which compared June, 2020 to June of 2019, found that homes in rural and suburban zip codes saw the biggest jump in average views per property. Homes in urban zip codes had a 19 percent increase in views compared to last year. But homes in suburban zip codes had a much larger 30 percent jump. And homes in rural zip codes saw a 34 percent increase.” See http://bit.ly/Covid_34_percent_increase_rural_living

18 As shown in this comparison by McCann, http://bit.ly/WindTurbinePropertyValueImpactKielischMcCann studies of wind turbine impacts on property values funded by wind and utility interests conclude there is a modest negative impact on values while those done by independent evaluators show very significant range of losses from 15-45% and an average of 29%.

19Pattern’s estimate $4000 per MW annual payment (with 1.9% per year increase) is not guaranteed and subject to other losses. The estimated net income from land leased for wind turbine use, conducted by SOUL incorporates impacts two, likely payment reductions: (a) A 15% decline in property value endured if property has to be sold within the 40 year term; (b) Continuation of the historical decline in wholesale electricity pricing at 6.3% per year, the rate from 2005-2019. The table at the top of Tab 1 of SOUL’s spreadsheet, http://bit.ly/PropertyTaxDevaluationImpacts suggests the adjusted revenue with a property changing hands over 40 years is much lower than the figures in Pattern’s estimated payment schedules for a 3.5 MW wind turbine located on a parcel of 160 acres. See table in spreadsheet showing net average annual turbine income / loss with property devaluation factored in if the parcel is sold 5, 10, 20, 30 and 40 years after turbine installation. Because the turbine affects the value of the whole land parcel, turbine payments in this example are not large enough to make up for the property devaluation if the property is sold before 8 years. If sold in year 40, the adjusted revenue over would be about 33-35% the amount in Pattern’s payment schedule . Key assumptions in this analysis include: Land payment of $4,000 per MW escalated at 1.9% per year over 40 years; 2022 property value set at: $4,000 per acre; size of land parcel affected by WT siting: 160 acres; Turbine size: 3.5 MW; Agricultural land unaffected by wind turbine appreciating in value 4% per year from 2022 to 2062; and 3 acres of land occupied by turbine and access roads removed from agricultural rental at $400 per acre per year in 2022 and rental fee increasing at the rate of 2.5% per year. Landowners can customize most spreadsheet assumptions to estimate the impacts.

20This percentage is up from 5% in 2010 and after billions spent on utility transmission and power plant expansions. See Table1: Capacity, Energy Output, and Price-Setting by Fuel Type, Energy Output Share, “2019 STATE OF THE MARKET REPORT FOR THE MISO ELECTRICITY MARKETS at page 30, https://www.potomaceconomics.com/wp-content/uploads/2020/06/2019-MISO-SOM_Report_Final_6-16-20r1.pdf#page=30

21Alternatively directing dollars to enlarging Focus on Energy rebates creates no net cost to Wisconsin electric customers because every rebate dollar results in three dollars saved in avoided energy costs. In contrast, Wisconsin electric customers do assume the costs of power plants connected to the grid. Investing the same amount as the Uplands Wind proposal, instead, into Wisconsin’s heralded but under-funded, Focus on Energy program (PSCW SEA pdf p. 67) would assist home, farm and business owners make energy efficiency and on-site solar improvements. Dollar for dollar, these rebate-aided, money saving investments by customers are more cost effective at reducing CO2 emissions because they directly reduce use of grid-supplied power. In contrast, the power from wind turbines only increases the relatively small percentage of renewable energy in Wisconsin’s grid. For details about the Focus on Energy rebate based alternative that is more land and climate change friendly, download this spreadsheet at: http://bit.ly/SOUL_UplandsVsFOE_CO2 The economic/CO2 comparison is sim ilar to analysis done for the 300 MW Badger Hollow solar power plant as analyzed here: https://bit.ly/SeriousAbtC02-Pt1

22 Large-scale wind power would require more land and cause more environmental impact than previously thought http://bit.ly/HarvardHeatStudyOverview “Harvard University researchers find that the transition to wind or solar power in the United States would require five to 20 times more land area than previously thought, and if such large-scale wind farms were built, would warm average surface temperatures. . . Keith and Miller established a baseline for the 2012-2014 U.S. climate using a standard weather forecasting model. Then, they covered one-third of the continental U.S. with enough wind turbines to meet present-day U.S. electricity demand. The researchers found this scenario would warm the surface temperature of the continental U.S. by 0.24 degrees Celsius, with the largest changes occurring at night when surface temperatures increased by up to 1.5 degrees C. This warming is the result of wind turbines actively mixing the atmosphere near the ground and aloft while simultaneously extracting from the atmosphere’s motion. . . the warming effect is predominantly local to the wind farm.” The complete study by Harvard researchers is linked in the overview.

23Wisconsin farmer Jim Vollmer starting at 02:00 https://bit.ly/WI_Wind_Interviews The article, Do Wind Turbines Harm Animals? contains many links to other accounts.

24Compaction: See Wisconsin farmer, Alan Haas, starting at 44 seconds: https://bit.ly/WI_Wind_Interviews

25Wildlife populations: Wisconsin farmer Jim Vollmer starting at 3:44: https://bit.ly/WI_Wind_Interviews

26A 2018 estimate of bird and bat killing paid for by wind developer MidAmerica for 22 of their Iowa wind turbine systems over 30 years ranges from 961,635 to 1,188,075 avoidable deaths including two protected bat species, water fowl, raptors and song birds. (Data from .pdf page 155, Table 5.4-1; http://bit.ly/BirdBatTakingsPermit_MidAmerica )

       Through Fall 2019 and early Winter 2020, a team of five, volunteer citizen public intervenors accomplished what no organizations, public utilities, government entities or law firms had previously achieved. 1 They uncovered and exposed costs and benefits of region-wide utility expansion “planning” designed to study the addition transmission lines, remotely located power plants towards the goal of reducing CO2 emissions over time.

        This article takes their findings and allows Wisconsin and Midwestern electric customers to: (1) see how these proposed costs would affect their personal electric bills and associated CO2 emission reductions and (2) compare these results with much smaller rebate additions to their state energy efficiency programs and, (3) Combine this with “going solar” at their home or business. Before getting to the personal calculator, lets examine some shocking findings the intervenors learned about planning done by utility interests through the Midcontinent Independent System Operator or, MISO:

• Most utilities in the Midwest don’t do energy planning. They rely, primarily, on annual, collective, Midwest Transmission Expansion Planning (MTEP) conducted for and by utility interests. ² The planning assumes that utilities will spend many billions on new power plants and these assumptions are never submitted for professional review by impartial parties.
• MISO’s planning does not include input from affected electric ratepayers who would pay down the high interest debt on the utility investments over coming decades.  Before the State of Iowa began its review of MISO’s Cardinal Hickory Creek transmission proposal that intervenors participated in, Iowa State Representative Charles Isenhart asked MISO planners to meet and talk with Iowa ratepayers and elected officials who wanted to learn about costs, CO2 emission impacts and other information. MISO rejected the request of the elected official whose district was directly impacted.
• The opening paragraphs of MISO’s planning publicity asserts that MISO MTEP planning is designed to create net benefits. For more than 10 years, state utility commissions in the Midwest have falsely assumed that “net” means ratepayers would receive savings from MISO’s planning.  Instead,”net” refers only to very small, potential wholesale power savings over 40 years under favorable economic conditions eventually offsetting the building costs of the transmission line. The potential pennies per month in wholesale cost savings does not account for about $16.60 per month ratepayers would assume over 15 years for the new power plant-related costs. ³
• Klopp also found that, savings from “cheap wind energy” would not exceed 35 cents per month savings for the average Midwest household. This isolated calculation not only ignores the $16.60 per month to pay for the the new power plants but that an equal amount of that new generation is added fossil fuel generation.⁴ 
• It was confirmed in the proceeding that wind generation provided only 8% of the power in Midwest outlets in 2018 and that fossil fuel generation is still providing about 70%.⁵
• In return for ratepayers committing $200-272 billion towards new power plants, MISO utilities forecast that regional CO2 emissions would drop a mere 3.8%-5.8% in the year 2031 for the 42 million customers these utilities served.⁶.
• Using discovery and cross-examination to uncover other assumptions in the planning, intervenors found that utilities forecasted investment in energy efficiency and distributed solar to not grow from current levels through 2031. As a result, lowered demand for power from efficiency improvements in home and businesses is ignored along with developments of solar and battery storage for the next 15 years.⁷
   

Where Do Midwest States Currently Stand in Terms of CO2 Reduction Goals?

        The below graphic shows three conditions: CO2 reduction progress from 2005-2018 (brown line), post-2018 reduction based on continuing our existing measures (orange line) and the red line shows the additional measures required to reach a significant 50% reduction in power plant related CO2 emissions in the year 2031 relative to 2018. 2018 was used because its the last year of reliable data and 2031 matches the reference year of MISO’s planning which make comparison of benefits more accurate.

      Existing measures producing a decline in CO2 emissions of 2% per year is based on continuing the 2005-2018 trend in emissions from Iowa, Illinois, Indiana, Michigan, Minnesota, Missouri and Wisconsin. The red line, “Additional Measures” target of a 50% reduction from 2018 to 2031 gives states a respectable start towards 100% reduction by 2050. The 1.8% per year decline in annual electricity use required to hit this target is within the performance realm of the better state energy efficiency programs.

The energy reduction capabilities of energy efficiency programs in the US are annually tracked by the American Council for Energy Efficient Economies.⁸ Selected, 2018 state data has been assembled in the below table and averaged. Across the seven states, an averaged payment of $1.59 per month has been reducing annual energy at the rate 1.06% per year. Massachusetts’ Accelerated program is included to show that considerably higher reduction rates are possible.

By offering very attractive rebates for efficiency and distributed solar improvements, public instruction of conservation skills and by financially rewarding MA utilities to meet reduction targets, 2005-2018 CO2 emissions in Massachusetts have decreased at a rate almost three times faster than in Midwest states. Massachusetts is now embracing battery storage and modern load management in order to, “not only change how we supply energy, but how we use energy as we shift our focus to strategic electrification and reducing peak demand in order to create a cleaner electric grid” ⁹ Judson said. With roughly the same number of electric customers as WI, MA will invest $2.8 billion over three years towards end user improvements to obtain $8.6 billion in savings and other benefits. New power plants only add cost with no net return.

Compare Regional Utility Spending vs. Energy Efficiency/Solar Investments USING YOUR ELECTRIC BILL

    Download the spreadsheet to your computer with the below steps and to make personal adjustments to it.

1. As shown below, click once on “File” to open the pull down window.
2. Hold the cursor over the word “Download” until a window opens.
3. Click on the string, “Microsoft Excel (.xlsx)”
4. A download window will open allowing you store the file where you want it on your computer.
5. Double-click on the downloaded file to open it.

To customize the Calculator to match your electric bill, access a recent electric bill. Find the number reflecting your total monthly usage in kilowatt-hour or “kWh” units. If you cannot find it, the average monthly residential usage for Wisconsin is about 700 kWh. Find the rate per kWh you pay and write this number down, If you cannot find the rate, the Wisconsin average is .14 dollars or 14 cents. Look for the “facility fee” or “electric service charge,” amount on your bill. If you cannot find it, use $8.00. Follow the below steps to enter these numbers into the calculator sheet that looks like this:

1. In the Step 1 section, double-click in the white box. Enter “KWh” monthly number of monthly use,
2. In the Step 2 section, hover the cursor to the right of the number in the larger white box until an arrow appears, Click on the arrow and select the amount you will spend on Focus on Energy from the choices provided, Select $4.26 for an accelerated program, $2.71 for a program that is double the current size, $1.15 to match the current program funding and $6.60 for the maximum accelerated amount.
3. Also in the Step 2 section, hover the cursor to the right of the number in the white, “Your kWh Rate” box. Click on the arrow and select a dollar value close to your rate. Double-click in the white box in the lower right and enter the amount of your electric service charge.
4. The financial and CO2 emission impacts of adding a right-sized SOLAR array to your house, farm or business are automatically estimated in the bottom section, ADDED HOME SOLAR FOR NET ZERO CARBON. If you have another cost per watt you want to use for the solar installation, enter in the box to the right of “Change Price as Needed.”

     Comparing the Impacts

The middle section is a comparison of your electric bill total, today, to two spending paths: With Energy Efficiency and with Proposed $200-$272 Billion for Regional Utility Expansions. The comparisons feature future, estimated Electric Bills in the year 2031, percentage cost increases (excluding solar) relative to doing nothing. At the far right is the total CO2 reduction the measures would make in year 2031. Differing CO2 reduction from just the two paths, are displayed under “Additional CO2 Reduction.”

The bottom section shows the benefits that would come from “going solar” at home or business in combination with the Focus on Energy or other energy efficiency program spending selected in step 2. The solar installation is automatically sized to match or offset the amount of power needed to operate the house or business to produce zero net carbon emissions. The combined efficiency and solar resources realize a virtual” or mathematically -computed, 100% reduction in CO2 emission impacts. Increasingly, adding battery storage to home and business systems will enable actual, 0% carbon impacts. The section also computes the very substantial energy saving or losses and the amount of one’s monthly electric bill in 2031.

Below is a comparison of the economic and environmental impacts of the different spending paths based on 2018 average, residential use of 700 kWh per month at Wisconsin’s average rate and service fee.

Set Your Own Standard and Inform Your Wisconsin Lawmakers About Your Progress

        In his first proposed budget as Wisconsin Governor, Tony Evers proposed lifting the 1.2% spending cap on Wisconsin’s under-founded Focus on Energy Program. Lawmakers let this improvement slip-by– not because of opposition to his suggestion but for lack of ratepayers speaking up for it. Over the last several months, calls to increase Focus on Energy rebates have accelerated. The measure is a high priority in the Governor’s Task Force on Climate Change discussions and a top recommendation of the Wisconsin Academy following their Climate Fast Forward Conference discussions. In its current Strategic Energy Assessment, the Wisconsin Public Service Commission observes that Wisconsin’s Focus on Energy program is the #1 program in the US based on energy use reduction per dollar invested. The PSC states it has found a way to (very modestly) increase funding to the Focus on Energy program to try an accelerate it under the existing paltry amount of $1.15 per month.

       Because we have focused ratepayer dollars on expanding our utilities’ assets, household affordability of electric service in Wisconsin is probably the highest in the Midwest when the high service fees are factored in. The high cost is making Wisconsin businesses increasingly uncompetitive with similar businesses in other states. As soon as Lawmakers recognize the net greater affordability over time, the profound emission reductions and the local job growth that would stem from a modern, accelerated efficiency program, they will vote to approve one. It is mostly a question of how soon will they act, not whether they will act.

       Large changes usually come from the bottom-up. Wisconsin utilities are resistant to a modern energy efficiency program because current state laws encourage them to promote growth in use which, today, means more waste and emissions. As Massachusetts has demonstrated, there is plenty of money for utility profits on the better path. It is decrease in demand that makes coal power plants cost ineffective and shut down– not more, “lower cost” power. In truth, all wholesale power is “cheap,” from 2.6 to 4 cents per kWh, or only 25% of the electric bill. As SOUL’s recent comments to the PSC demonstrate, the utilities’ default “planning” to add $3.2 billion in new power plants, even with many renewable ones, is extraordinarily cost and environmentally in-effective.¹⁰ Mirroring regional utilities’ lethargic environmental planning, Wisconsin utilities project only a 2.5% reduction in CO2 emissions from 2020-2030.

Wisconsin, cannot wait to change– to wait for the rising political will of rightfully angered communities responding to backwards high voltage expansion transmission lines and locally debilitating five square mile solar power plants in order to achieve fair and respectful energy laws. Affordability and expedience aims to waste less and need less. A better world is passionate about our better selves with voices far louder and more effective than spurts of frustration, anger and silent cynicism.

NOTES

Question:

What business would make a similar investment seven times and not stop to check its performance?

Answer:

One that is guaranteed 10.2% return no matter what the performance is.

Collectively, the electric customers or ratepayers of Wisconsin utilities function as one, big investment business. We spend more than $7 billion per year for four, basic expenses:¹

• 45-60% ($50-65/mo) Payment on debt for power plants, transmission/distribution lines and other, grid-related costs. These costs were previously approved by either the Wisconsin Public Service Commission or commissions in other states.

• 25-30% for “wholesale power”  ($30/mo)

• 15% to one’s utility (~$15/mo)

• 1.2% ($1.20/mo) for our collective Energy Efficiency rebate pool (Focus on Energy)

Guess which of these four percentages on electric bills has proven to be the most effective at reducing CO2 emissions?

Since 2006, Wisconsin electric ratepayer have invested in and built seven expansion transmission lines. All of the lines promised to deliver savings and faster reduction of CO2 emissions associated with our electricity use.²

The companies who sold us these products, American Transmission Co (ATC), Xcel Energy, ITC-Midwest and Dairyland Power Cooperative will not reveal their full costs or describe the impacts on average, monthly Wisconsin electric bills in traditional ways that customers can evaluate. This is the equivalent to a retailer refusing to describe or reimburse customers for products they sell. When asked to rule on this imbalance the Public Service Commission of Wisconsin is on record defending utility refusal.³

In contrast, Wisconsin law requires the performance of our Focus on Energy efficiency investments to be audited every four years, yet we lack accountability for the much larger amounts we pay every month towards expansion transmission lines.⁴ We do, however, have three indicators that costs have far outpaced the builders’ estimated savings:

• Absence of bragging. If energy savings existed, successful transmission builders would be foregrounding this evidence in their endless stream of proposals.⁵

• Our electric bills. Since 2006, Wisconsin rates have risen much faster than the national average and are the second highest in the Midwest. Since 2012, the fixed cost “meter fee” for each customer has risen an average of 9% per year⁶.

• Flat and declining use has negated potential savings. In 2007, Transmission builders developers warned that the cost of the Paddock Rockdale 345 kV expansion line between Beloit and Madison (visible from I-39) would add to Wisconsin electric bills unless state electricity use increased at least .5% per year (one half of one percent) in coming decades. Costs for this line and others are now pilling up as state electricity use averages .8% per year less than builders predicted as necessary to produce net benefits.

In 2019, Five Wisconsin lawmakers asked the Wisconsin Public Service Commissioners to test the economic performance of past expansion transmission lines to inform the review of the Cardinal Hickory Creek proposal but the agency failed to respond.⁷]

Section II: Can We Get a Deal for Us?

Wisconsin electric customers are committed to conservation and environmental goals,..

A 2018 study⁸ by the American Council for Energy Efficient Economies (ACEEE) shows that Wisconsin electric customer commitment to reducing use and lowering CO2 is high by all standards. Even at its current, under-funded level, Wisconsin’s Focus on Energy program reduces electricity waste at the impressive rate of .7% per year. The annual amount compares very favorably with programs and public participation in other states when performance per dollar invested is ranked. ¹⁴

It’s crucial to keep in mind that the harmful CO2 emissions are part and part and parcel of the grid-supplied power in our outlets. In 2017, power in the Midwest averaged 8% renewable energy with 73% coming from fossil fuel generation. By 2019, after additional billions spent on expansion transmission lines and remote power plants the percentage in the Midwest had increased only 1%.¹⁰ A drive in almost any direction in Wisconsin will encounter a massive transmission line system promised to make good on environmental goals that has failed.

“The cheapest energy is the energy you don’t use in the first place.” – Sheryl Crow

Though most Wisconsinites share a traditional, “waste not, want not,” sensibility, many households do not yet practice the simplest of conservation awarenesses. For example, household electricity consumption drops tends to drop about 13% when someone in the household tracks usage from month to month. Add to this, a number of low and no cost improvements and the household reduction can achieve 30%^.11 These, combined with increasingly better habits, automatic timers and replacing a few inefficient appliances can reduce use 50% or more.¹² Unlike the non-guaranteed, estimates that utilities make, these CO2 reductions and dollar savings are both maximized and assured.

Data in The American Council for Energy Efficient Economies report, reveals Wisconsin electric customers’ ability to leverage energy efficiency rebates to slash usage.¹³ While Wisconsin ranks sixth in reduced electricity use per rebate dollar invested, the state ranks low, 36^th among 46 participating states, in the amount of rebate dollars made available for state customers to purchase the most efficient appliances and make other dwelling and business improvements. Only South Dakota’s per capita rebate amounts are smaller among midwestern states.

Unfortunate confusion persists around the source of funding for Wisconsin’s Focus on Energy program with some state lawmakers believing the program runs on utility donations or taxes.¹⁵ In reality, the program exists through monthly payments made by Wisconsin electric customers into a rebate pool that customers and businesses draw from to help them afford higher efficiency appliances, energy improvements to dwellings and modern energy savings tools and on-site solar. The rebates better enable customers to make over 90% of the resulting investments without passing these costs to ratepayers.

Question:

Environmentally, how effective are these appliance, equipment, dwelling and behavioral and solar improvements at reducing CO2?

Combining state data from ACEEE’s report with state CO2 emission records from the US Department of Energy, it becomes evident that states with accelerated energy efficiency programs are also leading the way in CO2 reduction.¹⁶

These programs are successful because ratepayers and businesses are highly motivated to realize significant savings over time. The emission reductions are dramatic because using significantly less power means less dependence on the source of the problem– grid supplied power that is 68-75% fossil fuel generation. A key difference in higher-funded or “accelerated” efficiency programs is the greater degree of public education and outreach. Unlike Wisconsin, accelerated programs provide impartial, non-business affiliated energy conservation and efficiency specialists to help home and business owners develop objective improvement plans. Renters also participate through incentives offered landlords and apartment building owners. Industries with heavy reliance on electric power such as dairy farm operations are offered highly specialized rebates. With every passing year, Wisconsin’s Focus on Energy program falls further and further behind. Other states are slashing use and adding distributed solar at rates that directly avoid the transmission and power plant utility expansions that plague Wisconsin electric bills. It has been six years since retiring PSC Wisconsin Commissioner Eric Callisto advised in his dissenting opinion regarding a historic cost increase for Madison Gas and Electric customers:

“I think we should …evaluate placing a fair and transparent value on distributed generation, and at least start down the discussion path of the role of regulated utilities in a future with flat load growth, increased distributed generation and more robust consumer involvement in energy choices.¹⁷“

Section III: Big is Big

With utilities in Wisconsin posing many more renewable energy and natural gas power plants,..

Dropping costs of solar panels and the prospect of affordable battery storage has more people considering “going solar” than ever before.²¹ As previously mentioned, solar that is distributed to home, farm, business and community-serving locations has the added advantage of avoiding CO2 emissions at a faster rate. The benefit can also be dramatically amplified when households and businesses shift their heavier uses of power to solar production hours of the day.

In contrast, the CO2 reduction abilities of utility-scale renewables is limited. Adding renewables to the grid further increases grid dependency and the tremendous amount of wasted energy inherent in the fossil fuel generation. More than 60% of the energy used to generate power with the coal and natural gas power plants that supply 68-75% of our power to Wisconsin literally goes up in wasted heat and CO2 and other harmful gasses.

Thus, when a household or business uses conservation or efficiency to reduce use of 1 kWh hour of power, it avoids the equivalent of nearly 3 kWh’s of comprehensively measured energy with associated negative environmental/climate change impacts.

In the early 1980’s, utility interests began widespread public relations campaigns inferring that renewable energy added to the grid somehow replaces of fossil fuel generation. In 2005, Wisconsin joined MISO, a massive electricity market of utility interests who plan costly grid expansions proffering the same replacement advertisements. After 45 years and billions in new costs, the attainment of only 9% renewable energy in Midwest outlets deserves wide criticism. Had the same billions been placed into customer or demand side energy efficiencies and CO2 reduction maximized distributed generation, many Midwest communities could be on the verge of zero carbon emissions associated with electricity use. The clear path before us was never replacing “dirty” power plants with “cleaner” ones but removing waste and dependence on a for-profit, monopolized electric market with no inherent motivation to make significant environmental progress. The Wisconsin Public Service Commission (PSCW) has furthered our utilities’ absolute monopolization of not only electric customer dollars and more recently, large expanses of state lands and local economies. The ability to hold off the next stage of unnecessary monopolization of land and local economies rests cultural understandings of the same, superior alternatives.

By ignoring that public demand for power is dropping and could drop much faster, decision-making at Public Service Commission of Wisconsin continues to bolster absolute control of utilities. Contradictorily, within a one year span of time, the PSCW approved a 625 MW natural gas power plant in Superior, Wisconsin ²² and more than 500 MW in massive solar power plants without mention of fossil fuel generation retirement. The 300 MW Badger Hollow solar power plant covering 4-5 square miles of prime farmland with a million solar panels near Montfort, in Southwestern WI is used here to compare results from the alternative efficiency and distributed path. The comparison provides both the monetary but environmental bottom lines by forecasting CO2 emission reductions over the 30 year lifespans of the investments.

With more that 47 million megawatt hours of Wisconsin fossil fuel generation to replace under antiquated PSCW thinking, ²³ it is crucial for Wisconsinites to place utility scale solar power plant land requirements into perspective. At a conservative land use rate of 8 acres per utility scale solar MW, more than 400 square miles of Wisconsin land would need to be permanently blanketed with solar panels. It is worth driving on State Highway 18 west of Dodgeville, WI for a personal experience of two, continuous miles of solar panels being constructed between the Cobb and Montfort. The first hand encounter will leave no doubt that solar power plants on this scale permanently transform rural communities as properties are converted to utility ownership and the former agricultural economy disintegrated. Prior to PSCW decision-making, all solar power plants of this scale have been located in sparse, arid areas.

At an inclusive cost of about $504 million that would be passed to Wisconsin ratepayers, the 300 MW Badger-Hollow solar power plant would avoid about 6 million metric of C02 emissions over its expected lifespan of 30 years. Distributed across Wisconsin’s 2.6 million residential customers, Badger-Hollow would would add about 14 cents per month over the three decades, A simple, tested alternative is to apply the same millions to rebates through the Focus on Energy Program to stimulate more electric customers to go solar. The program currently offers a 26 cent per watt solar rebate fund that is exhausted every year. $504 million in rebates could assist more than 380,000 households to install 5 kW solar arrays which, together, would avoid 50 million tons of C02 emissions– 8 times more than Badger Hollow.

With solar panels now offsetting rising electricity costs in these homes, saving would average about $72 per month over 30 years including paying for the initial investment. The table includes two examples where the rebate incentives are increased to 52 cents and 90 cents per watt of the estimated $2.50 per watt for residential rooftop solar installations. Even when rebate incentives are substantially increased the environmental benefits are profoundly greater. Unlike Badger-Hollow which only adds to electric bills, the estimated $76 per month savings per solar household amounts $27,000 in energy savings Across all 190,000 solar homes, more than $5 billion in energy savings would be realized.

The National Laboratory of the U.S. Department of Energy has estimated that at least 33% of the electrical power needs can be derived from rooftop solar.²⁴ Under Massachusetts’ higher rebates for energy efficiency and distributed solar investments, home and business solar installations have exceeded 1500 MW. ²⁵

Section IV: Past Time to Re-Invigorate Focus on Energy

In 2009, Wisconsin lawmakers voted to ramp up the Focus on Energy Program in several steps exceeding the doubled funding level considered here. Unfortunately, the improvement was soon nixed by then Governor-elect Walker. In 2018, Governor Evers asked Wisconsin lawmakers to remove the current 1.2% cap on the program but the improvement has yet to introduced for action.²⁶ No doubt, it will require wide requests from ratepayers and businesses to wake up lawmakers but the lack of a diverse energy economy in Wisconsin compared to Illinois, Michigan and Minnesota will become very apparent within a few years.

Another policy update looms on the horizon for Wisconsin as well. Most states with accelerated energy efficiency programs have policies that reward utilities for reaching defined energy reduction goals. The utilities are also rewarded for Greenhouse Gas Emission reductions. The money for these payments comes from sharing a slice of the substantial monetary benefits of the accelerated energy efficiency, dwelling improvements and distributed energy programs. The policy is called “de-coupling” because it minimizes the loss of revenue that a utility would normally feel when energy sales decline. De-coupling can take place with other rate structure changes to enable more competition between utilities and companies that make improvements on the home, business and community level. In our present “coupled” state, Wisconsin PSC practice and laws encourage undesirable behaviors from the utilities they regulate: they oppose measures that lower power consumption and cash flow to utilities; they have new steel in the ground build prejudice because, currently, it is the only measure that guarantees monetary rewards, while holding key fossil fuel generation power plants, the utilities do not target CO2 emission reduction because there is no money in it, and; utilities will not consider downsizing and right-sizing even when appropriate because the PSC only incentivizes utility growth.

Eventually, the rate of capital building will force electric service costs high enough to force the commission to shift focus and follow the steps of other states. Even at today’s costs, consumers who do the math see how much they can save over time by going solar and battery storage is catching up quickly. In sum, there is so much money to be saved through efficiency and generation self-sufficiency that the Commission will be forced to recognize it. Utilities already do; they are not going to leave the feed trough as long as the PSC keeps filling it up with ratepayer dollars.

Where does Focus on Energy stand today? Auditors who assess the performance of the Focus on Energy program note the significant reduction in use per ratepayer dollar spent but consistently suggest that public outreach and conservation education could be significantly improved. Focus has begun some measures in this regard such as free, basic household energy efficiency kits, email announcements, offering community-based workshops and suggestion box. If you have not yet ordered one of the free efficiency kits with LED bulbs, low flow shower heads and smart power strips, doing so will also place you on their email list. Remember to mention the importance of the efficiency/local power path and Focus on Energy when communicating with lawmakers and the PSCW.

Some groups, including Renew Wisconsin propose that Wisconsin ratepayers need to support rapid utility expansion and the efficiency path at the same time. Their all of the above stance foresees no substantial changes other than huge tracts of land being gobbled up utilities. The forecast assumes Wisconsin ratepayers will be content with continually escalating costs and poor CO2 reduction performance.

________________________________________________________________________________

1 In theory, Wisconsin lawmakers define what kinds of power plant and transmission investments ratepayers can be required to make. In practice, the three Commissioners heading the Public Service Commission of Wisconsin make the final spending decisions monetarily affecting electric bill decades after the Commissioners’ terms are complete. Wisconsin Commissioners are appointed for six year terms by the Governor. In some states, Commissioners represent specific areas in the state and are elected by citizens in those areas. Electric bill percentages: See http://soulwisconsin.org/Resources/FootnoteHarbour.pdf#page=42 and this 2011 MISO account: https://apps.psc.wi.gov/pages/viewdoc.htm?docid=370481 at p.86, Table 2.6-2: Comparison of BAUMLDE future retail rate to current [rates] in early, 2011. Generation Production or wholesale energy makes up 25% of the average Midwest retail electric bill. Together, Generation and Transmission account for 45% of the retail electric charges. The trend of high annual growth rates for power plant and transmission costs in Wisconsin can be seen at https://apps.psc.wi.gov/pages/viewdoc.htm?docid=364956 at .pdf p.60-61, Figure 25 Eight-year Annual Growth, Rate of Revenue Requirement Components—Major IOUs (%).

2 Net energy cost savings & environmental benefits claimed, 2007-2018 http://soulwisconsin.org/Resources/FootnoteHarbour.pdf#page=46

3 To date, transmission builders refuse to provide customers, state lawmakers and the PSC evidence that their products deliver the benefits they promise even when formally requested by intervenors representing public interests. See response to data request 15, pdf p. 48 http://apps.psc.wi.gov/pages/viewdoc.htm?docid=360493 and transcript of a special PSC hearing to compel transmission builders to provide ratepayer level impacts at starting at p. 202 https://apps.psc.wi.gov/pages/viewdoc.htm?docid=364604

4 WI Transmission Expansion Spending table excerpted, pdf p. 40 http://soulwisconsin.org/Resources/FootnoteHarbour.pdf#page=40

5 List of expansion transmission lines proposed and approved in Wisconsin http://soulwisconsin.org/Resources/FootnoteHarbour.pdf#page=44

6 Wisconsin Utilities, 2012-2016 Fixed Fee Increases, http://soulwisconsin.org/Resources/FootnoteHarbour.pdf#page=13 Fixed cost payments for Milwaukee ratepayers ranked second highest among US cities in 2016: https://www.synapse-energy.com/sites/default/files/Caught-in-a-Fix.pdf#page=12

7 (Bipartisan, Wisconsin State Legislators) Request for Economic Performance Testing of Expansion Transmission Lines, http://apps.psc.wi.gov/pages/viewdoc.htm?docid=361228

8 The 2018 State Energy Efficiency Scorecard, ttps://aceee.org/research-report/u1808

9 Writes engineer Bill Powers regarding the Badger-Coulee transmission line proposal, “The cost of the no-wires alternatives to offset the 0.22 percent per year peak load growth scenario, at $3.37 million (Load Management), $9.45 million (Energy Efficiency), and $18.75 million (community solar), are a fraction of the $190.9 million identified by ATC to upgrade LV segments as an alternative to B-C.” pdf p. 46, http://bit.ly/Powers-Direct

10 MISO 2016 State of the Market Report, excerpt on pdf p.36 http://soulwisconsin.org/Resources/FootnoteHarbour.pdf#page=36 See .pdf p. 30, Table 1: Capacity, Energy Output, and Price-Setting by Fuel Type, 2019 STATE OF THE MARKET REPORT FOR THE MISO ELECTRICITY MARKETS https://www.potomaceconomics.com/wp-content/uploads/2020/06/2019-MISO-SOM_Report_Final_6-16-20r1.pdf

11 SOUL’s free, “Wisconsin Meter Watch” initiative has demonstrated that households are capable of very significant reductions without compromising comfort or quality of life. http://soulwisconsin.org/Documents/13X13_EfficiencyHandout.pdf

12 Electric hot water heaters, common to rural Wisconsin average about 30% of household use. Replacing an electric heater with an on demand propane water heater not only eliminates significant demand for electrical power but reduces associated CO2 emissions by 1/3 to 1/5.

13 On p.10, ACEEE points out “..the third tier Kentucky, Nevada, Ohio, and Wisconsin are tied for 29th. Small improvements in energy efficiency will likely have a significant effect on the rankings of states in these middle tiers.”

14 State annual, incremental reduction in use, by percentage divided by the rebate dollars collected for this purpose.

15 Why Did WI Utilities Bother to Cut WI’s Energy Efficiency Program a Mere 7%? http://soulwisconsin.org/Documents/7-percent_EE-First_ForknRoad.pdf

16 Only 2017 spending is compared in this graphic. State groupings are used due to significant differences in CO2 emission accounting from state to state and the fact that some states monetarily reward utilities for CO2 reduction.

17 MGE PSC Order .pdf p. 133, http://psc.wi.gov/apps35/ERF_view/viewdoc.aspx?docid=226563

21 Rural Northern Wisconsin Logs Record-Setting Solar Group Buy, Kari Lydersen, https://www.usnews.com/news/best-states/wisconsin/articles/2018-12-08/rural-northern-wisconsin-logs-record-setting-solar-group-buy

22 Utility regulators approve controversial $700M natural gas plant in Superior https://bit.ly/625MW_SuperiorGasPlant

23 68% of Wisconsin’s 69 million megawatt-hours (MWH) in 2018 was fossil fuel generation. See EIA graph at https://bit.ly/WI_Generation_EIA

24 See p.47 https://www.nrel.gov/docs/fy18osti/70901.pdf#page=47 Rooftop Solar Technical Potential for Low-to-Moderate Income Households in the United States. Wisconsin land use involved to meet 100% 2016 Wisconsin net generation with utility scale solar or alternatively, utility scale wind turbines. https://gallery.mailchimp.com/b59cfca00987b6608bf82d01f/images/f3e99378-77d8-4f1f-bd87-050a691d8526.png

25 Developing a Post-1,600 MW Solar Incentive Program: Evaluating Needed Incentive Levels and Potential Policy Alternatives, https://www.mass.gov/files/documents/2016/10/nf/developing-a-post-1600-mw-solar-incentive-program.pdf

26 Governor Tony Evers proposes carbon-free electricity by 2050, Chris Hubbuch, Wisconsin State Journal, http://bit.ly/Evers_MoreEEConservation