RESPONSE TO THE
Silent Treatment
Controversial Transmission Line
Locks-in Billions in Costs
for Decades of CO2 Increases
1. Conflicts with Utility Interests Dispensed
On September 26, 2019, the largest out-pouring of citizens, public intervenors and elected officials participating in a utility case in Wisconsin history, the Cardinal Hickory Creek high transmission line (CHC), was met by a well known, defense mechanism: the silent treatment.
Granted, the three, politically appointed Commissioners of the Wisconsin Public Service Commission (PSCW) faced a challenging agenda on that day. Before taking up discussion of their final decision concerning the transmission line, they took up a motion requesting that two Commissioners recuse themselves from the final CHC decision on the basis of conflicts of interests.1
In arguing his defense, PSCW Commissioner Mike Huebsch contended that his past involvement with regional, utility-funded, energy planning through MISO2 does not constitute a conflict of interest because his MISO discussions do not pertain,“to any specific project.” Huebsch did not account for the fact that transmission builders used MISO energy planning under his review in 2017 for the 2018 CHC proposal he was about to vote on again. After refusing to recuse himself, Commissioner Huebsch turned to the ratepayers at the meeting and blamed those parties for having conflicting goals,
“If you like renewable energy, you like transmission lines . And if you believe that this transmission line that we put up is the last you are going to have to deal with, you are wrong.
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The public intervenors’ recusal motion asked recently appointed PSC Commissioner Rebecca Valcq to explain how she was not conflicted by many years as a lawyer working for a Wisconsin utility who owns a large majority of a transmission company that would profit from CHC. In response, Commissioner Valcq asked the public to trust her professional abilities to not be biased. She expressed regret that her reputation had been questioned in the papers and on the radio and asked that such insinuations be treated as contempt.
2. Public Input Dispensed
Next on the meeting agenda was the substance of the CHC proposal where Commissioners were expected to share reasoning used in reaching their final decision. Without preamble or discussion, the Commissioners quickly moved to approve their draft decision on the CHC project. Then, with only three, “aye’s,” years of intensive work by a record number of citizens, public intervenors and PSC staff passed, in the blink of an eye as if none of this had never occurred.
Given the enormous consequences and the sheer number of top notch, experts the final decision for CHC should have been the most significant energy planning document in Wisconsin history. Unfortunately, Wisconsinites concerned about land impacts, CO2 emissions, climate change, electric bills, energy efficiency and solar affordability must now examine what the Commissioners’ omitted due to lacking, ”credibility and likeliness.”
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3. Environmental Protections Dismissed
Thousands attending public hearings or writing comments were adamantly concerned about the environmental harm CHC would bring to the ancient lands of Driftless Wisconsin and the region's economic well being. With due respect to the heritage and futures of these lands, here is a list of prudent protections the Commissioners ignored:
- The protection of 2,500 acres of ancient, cultural and natural habitats resting immediately under existing low voltage wires from steady disruption of bush whacking, helicopter sawing, herbicide spraying, soil compaction and forest clearing.
- The protection of 70,000 acres or 110 square miles of homes, businesses, schools, farmettes, century farms, parks, trails, village and city lots resting adjacent to or within a half mile view of 170 foot high towers. These dearest of properties risk value losses from 5-45% of their market value estimated at $90 million.
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- The protection of a growing tourism industry that brought more than $100 million to SW Wisconsin in 2018. This puts billions of revenue and jobs at risk if CHC detracts only few percent of tourist interest.
- The protection of one of North America’s greatest wonders and natural assets, the Upper Mississippi River National Wildlife Refuge and associated flyway where nearly half of our migrating birds pass or reside.
- The traditional honor of protecting home and community for tens of thousands of residents. This potential loss has already started an exodus as properties lose their intrinsic rural/natural value and become unmarketable.
- Increasing protections from power losses associated with extreme weather events thay national experts proposed through faster development of home and local power generation. Instead, Commissioners banked on the other direction, increasing public vulnerabilities to the grid.
4. Energy Cost Oversight Dismissed
The Commissioners’ September 26th decision contains no mention of Wisconsin state lawmakers who repeatedly and respectfully asked for financial accountability. On March 8, 2019, seven lawmakers representing both parties signed a letter to PSC Commissioners asking them to first examine the economic outcomes of the seven expansion transmission lines previously built before moving ahead with an eighth. Dismissal of this request is plain and simple fiscal irresponsibility.
Similar to the Commissioners’ excisions in their verbal and written documentation, utilities also tried to keep harmful evident from getting into the record. Under oath, at least three utility witnesses very familiar with price impacts on the Midwest electricity market, insisted they did not know if wholesale prices of electricity had generally increased or decreased over the last decade. Wholesale pricing is well-documented; utilities prefer that discussion about it is not.
Since Wisconsin joined the regional electricity market in 2005, wholesale pricing of electricity across the Midwest has dropped about 50%. In contrast, over the same time period, the price that Wisconsin customers were forced to pay for power increased 50% including encompassing rate and fee hikes.
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The reason behind this contradiction between wholesale price plummeting and ratepayer cost soaring is very well known within utility circles. After the new market came into play, state utility Commissions let transmission builders off the leash in hopes of the expansion lines accessing lower cost power. In Wisconsin, the gamble on expansion transmission lines cost ratepayer an average of $428 million per year.
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Translated into impacts on electric bills, nearly all of the rate and fee increases are due to these transmission and power plant purchases. Utilities make these purchases using high interest, 40 year loans that Wisconsin ratepayers are just starting to pay down. In short, all utilities no longer earn principal profit from selling power, they make it from “putting new steel in the ground” and getting 10-14% guaranteed return with our electric bills securing this debt.
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Ratepayers and businesses tend to notice 50% price increases. Ratepayers also notice when rates continue to rise after many transmission lines advertised to “increase access to cheap wind power,” are up and running.
While Commissioners are content to parrot non-committal, utility wording, like “increase access,” CHC intervenors need to see actual impacts. Annual reports by Potomac Economics independently measuring electric market performance are a good, factual source. In 2011, electric power made available to MISO/Midwest market customers averaged 5.2% wind power and 74% fossil fuel generation. By 2018, after strapping regional electric customers with at least $18 billion in new expansion transmission lines, the available power averaged only 8% wind power with fossil fuel content dropping only 1% to 73%.
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The environmental performance is abysmal. Preventing this wasteful ploy is a function of Commissioners interpreting the utilities’ energy planning and then using public intervenor and staff alternatives to negotiate and improve the lot for ratepayers, the environment in balance with utility profits. Our Commissioners lack the awareness and skill to perform this essential role..
5. State Energy Planning Forfeited
Despite energy planning being a law-designated outcome of CHC case, the term energy planning is conspicuously absent from the Commissioners’ decision.
Also gone from the Commissioners’ final decision are the words, “CO2,” “emissions” and “climate,” even though a month earlier Commissioner Valcq publicly pronounced CHC as the, “cornerstone of a zero carbon future.”
If Wisconsin is to reach this goal, it is paramount for electric customers to understand that the utility planning endorsed by Commissioners in the approval CHC aims to take the state in the opposite direction:
- Contrary to flat and declining use over the past 10 years, utility interest planning assumes that Wisconsin’s electricity consumption over the next 40 years will increase 11% to 27% higher than current use. If this theoretical and unnecessary waste becomes reality, it would cost Wisconsin ratepayer $42 billion in added electricity charges.
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- The utilities’ planning dismisses US Department of Energy findings that energy efficiency, dwelling improvements and home/local solar power have been the primary CO2 reducers since 2005.14 Wisconsin’s efficiency/solar rebates are at the bottom of Midwest states15 and utilities are happy about this. Their energy planning, embraced by the Commissioners, assumes that the number of homes and businesses going solar in coming years will not increase and that Wisconsin investment in energy efficiency rebates will stagnate or increase no more than 10%.16 These figures are not only unrealistic but are manipulated to eliminate CHC’s real competition, superior savings and CO2 reductions Non-Transmission Alternatives.
- In addition to adding more transmission lines, utility planning contains a hidden budget of about $43 billion for new power plants used by Wisconsin.17 The transmission builders’ planning forecasts a blend of fossil fuel and renewable new power plants over the next 40 years they claim would avoid 36.3 million metric tons of Wisconsin CO2.18 “Millions” sounds like a lot, but the amount spread over 40 years is equivalent to a total of only 10 months of Wisconsin 2017 emission levels19 and it does not count the additional CO2 emissions spurred by increases in electricity use the utility planning assumes.
- When the CO2 emissions produced by the extra 11-27% power usage are factored, the blend of future power plants that utility interests have ]assumed would add the equivalent of 6 years of Wisconsin CO2 emissions.
- The actual cornerstone of Wisconsin (and MISO) energy planning should be economic accountability created by state lawmakers.20 State law minimally requires that new spending should at least pay for itself, in this case, over 40 years through energy cost and other savings. This ow bar set for utilities was seen as sufficient in 1998 to discourage obvious, unnecessary spending. Instead of recognizing that CHC does not meet the legal minimum, the Commissioners’ decision bypasses PSC staff findings that CHC would not recover its $2.2 billion cost21 over 40 years in 8 of 11 future scenarios they carefully studied.22 Under full transparency, none of the scenarios are capable of savings because utilities do not count the hidden tens of billions in added energy and power plant costs that utility energy planning assumes.
Economically and environmentally, the Commissioners have chained a utility-profiting albatross around ratepayers’ necks in the name lower costs and lower CO2 emissions. Tellingly, in no place do transmission builders or Commissioners bluntly state that our bills or our emissions would be lower. They know their planning can’t defend these outcomes.
6. Modern Energy Economies Dismissed
The Commissioners’ decision also ignored the extensive Non-Transmission Alternatives energy planning that SOUL engineer Bill Powers and other recognized engineers conducted. Powers’ planning is based on proven, end user investments to dramatically reduce use and create profound energy and CO2 savings.
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Based on expanding the Energy Efficiency and 40,000 home/business solar incentives in Wisconsin’s Focus on Energy Program, adding new incentives for 47,000 inter-connected home battery systems and creating a solar+storage back-up power system for a community of 14,000 electric customers, Powers predicts 40 year avoided energy and other savings greater than $4 billion and CO2 emission reductions equivalent to 6.9 years, 9 times more than CHC reductions.
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Expanding Powers’ Non-Transmission Alternatives (NTA’s) installations and Wisconsin’s Focus on Energy (FOE) program to achieve zero carbon goals by 2050 would require about 36 NTA projects and tripling current FOE incentives. The total cost for this would be about a total cost of about $10.7 billion. Importantly, these costs would be recovered through energy costs savings and still leave profits for utilities to keep paying down debt on past investments. Powers’ energy planning closes down, instead of stimulates new fossil fuel power plants.
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One can see why most states are turning down expansion transmission line as old-school energy planning28. Utility planning for CHC, embraced by Commissioners assumes added costs of about $85 billion over 40 years and CO2 emissions increasing. The difference in job creation potential is also breathtaking because energy efficiency and small scale solar installations create from 3-6 times as many jobs per million dollars spent compared to transmission and other utility-scale building.
7. Keeping the Lights On, Affordably
After the Commissioners steered clear of the PSC staff’s, high-performing, $900,000, Low Voltage Transmission Alternative (BWARA)29 in their public discussions on August 20, there was great anticipation of how Commissioners would account for BWARA in their final decision. The decision contains only two mentions, the second concluding, “the base with asset renewal alternative has also not been developed or studied in any detail other than as a modeling comparison to the project. Therefore, the Commission does not have any certainty based on the record that such an alternative is truly feasible or implementable.”
It is hard to imagine a solution more straight-forward, more substantially studied, feasible or implementable; and it presents no new, negative environmental impacts. The Base With Asset Renewal Alternative (BWARA), poses slightly early rebuilding three,1950 era transmission lines at a cost of 1/360th of the CHC project. Rebuilding older lines is so routine that several were being re-built at the moment Commissioners penned their decision.
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The Commissioners also excluded BWARA from their discussion about future reliability. By its omission, Commissioners did not have to engage the sticky fact that the staff's alternative has comparable reliability performance to CHC at 1/360 of the cost.
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8. Conclusion
Let history properly read that on September 26, 2019, after four, painstaking years of tireless public initiatives, the PSCW Commissioners, going against the advice of their own staff, tried to render these public interests futile for all time. The ploy lasted about 40 seconds after their approval when citizens in attendance rose immediately to their feet. Risking arrest, each spoke one, simple sentence of fact from a lengthy list.
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The survival of our communities depends on regular people like these with good memories and strong will. No amount of clever language, omission and gaming can hide the accountabilities citizens are demanding and the legacies they are protecting.
Commissioner Heubsch is right in that, CHC, even when successfully appealed, will not be the last, intrusion of many types proposed. The future will not become ours until we have established the rigors of accountable planning.
State lawmakers, county supervisors, town chair persons, school teachers, newspaper editors, accountants, farmers, students, clergy, and community business persons, stand up, brush off your clothes and relish the common call. We have no choice. We are, in fact, defending our communities, our lands and our local economies.
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