All posts by Beverly Vaillancourt

CETF and SOUL Petition Wisconsin PSC for Rehearing on Badger-Coulee

The decision by the Wisconsin Public Service Commission to approve the Badger-Coulee Transmission Line was a black mark on the integrity of three commissioners charged with protecting the ratepayers of Wisconsin. A question posed two years ago by then Senator Dale Schultz, “Where is the Public in the PSC?” continues to resonate throughout the state when three commissioners  approve transmission lines that defy what is best for the ratepayers of Wisconsin. Their actions leave the state with a sad legacy of corporate interests first and human and environmental health, the beauty of Wisconsin, and the right of a state to determine its own destiny not even in the game.

Citizens Energy Task Force (CETF) and Save our Unique Lands (SOUL) have filed a petition with the Wisconsin PSC for rehearing. You can read the petition by clicking on this link: CETF/SOUL_BadgerCouleeRehearingRequest

Here’s a link to a second petition for rehearing filed with the PSC on Segment A. Petition for Rehearing / Holland and Segment A


The joint CETF / SOUL press release reads as follows:

Public Intervenors Call Claimed Benefits from Badger-Coulee Transmission Proposal into Question

Public intervenors representing electric customer interests in the controversial Badger-Coulee transmission proposal have petitioned the Public Service Commission (PSC) to re-hear the case.  The project was approved last month and intervenors are asking the commission to determine whether it would have any economic benefit for ratepayers under current trend of flat and declining energy use.

Savings potential from high capacity transmission lines generally declines as energy use drops. The petition submitted by S.O.U.L. of Wisconsin (SOUL) and Citizens Energy Task Force (CETF) cites evidence from the Paddock-Rockdale transmission line approved in 2009 where economic planning shows loses to ratepayers at today’s energy use levels. New information released by the U.S. Energy Information Agency (EIA) and the U.S. Department of Energy (DOE), confirms that energy use in Wisconsin has declined 2% since 2008 with a similar trend regionally and nationally.

Throughout the PSC’s review process, American Transmission Company and XCEL Energy (co-applicants in the case) refused to predict growth rates in their benefit calculations wide enough to anticipate zero and negative growth. Petitioners claim that assuming energy use in Wisconsin will always grow is unsound reasoning. Says Rob Danielson, secretary of SOUL, “There are indications that contrary to terms of PSC approval , the project could make energy cost more than if the line was not built. These costs would be felt in addition to the negative impacts on local economies where the line would be located.”

According to petition citations from the DOE and EIA, the energy reductions are attributable to, “slower population growth, dramatic improvements in the efficiency of household appliances, and a shift in the economy to less energy-intensive industries. ”  The DOE report confirms that economic growth is no longer dependent upon using more electricity and the trend is projected to continue at least through 2040.

“The ability to use less energy and save home, farm and business costs will only improve,“ observes Rob Danielson, secretary of SOUL. “It is highly appropriate for the Commission to ask American Transmission Company and XCEL to demonstrate for Wisconsin ratepayers that Badger-Coulee would prove beneficial as we continue reducing waste.  It is not respectful of Wisconsin’s business climate to envision increasing energy use as a means of building a stronger state economy. Energy efficiency and developing local power were a much preferred direction by hundreds of ratepayers filing comments on this case.”

Two nationally respected engineers with years of expertise in transmission, energy efficiency and distributed generation developed a “No Wires”  alternative to the 150 mile project. They estimate the cost of their alternative to be less than 1/30th of cost of the transmission project and return guaranteed savings from efficiency, community solar and load management several times over.

Jane Powers, a public intervenor from Mauston who supports the petition adds,   “As ratepayers would have to pay for the line whether it is needed or not, we deserve to be able to evaluate all energy options.  So far, the transmission builders have refused to demonstrate that their project can compete money-wise, and provide a complete cost for the line after high interest financing over 40 years is added. I’m not comfortable with the quality of the information ratepayers have received to date.“

In their new report, the Department of Energy is encouraging states to make sure that, “all the benefits of efficiency are realized, including avoiding the expense of building new infrastructure.”

The Public Service Commission has 30 days to consider the request of the intervenors before responding. The Town of Holland near Holmen, Wisconsin is preparing a formal appeal of the proposal as well.




CETF and SOUL to Challenge Badger Coulee Decision

Challenge to PSC Approval of the Badger Coulee Regional Transmission Line in the Works

April 23, 2015 Citizens Energy Task Force (CETF) and Save Our Unique Lands (SOUL) convey they will ask the Public Service Commission of Wisconsin (PSC) to reconsider today’s formal approval of the Badger Coulee regional transmission

Filing a Petition for Rehearing with the PSC is a defined part of the official administrative hearing process. Filing a Petition for Judicial Review with the circuit court to challenge the legal validity of the PSC decision is also a next step afforded in the process should the PSC elect to deny or ignore the Petition for Rehearing request.
The 68-page order approving Badger Coulee conveys, “The opposing intervenors (CETF and SOUL) did not provide credible
evidence that a near-zero or negative load growth scenario would be a reasonable future for the applicants to consider.” The groups contend they relied on utility forecasts showing a lack of growth, which makes them credible. Also, since the close of the hearings, the declines in Wisconsin electric consumption have been reported by the US Department of Energy, with 2014 declining .1% and 1.8% respectively compared to 2013 and 10 years ago, and a dramatic January 2015 decline of 3.8% versus 2014.

“In addition to not seeing economic projections of the line at flat or declining growth rates, we’ve not seen an analysis of viable cost effective alternatives,” says Debra Severson of CETF. “During the Badger Coulee technical hearing, engineer Bill Powers demonstrated how local wind, solar and energy efficiency were more cost effective solutions for Wisconsin ratepayers. Powers also demonstrated the chicken and the egg issue of how the utilities desire to increase the transfer of electricity from the west into and through Wisconsin is the both the purpose of the Badger Coulee and the cause of the reliability issues it was approved for.”

Severson does not hold great hopes that the PSC will give just and reasonable consideration to the groups’ appeal, stating, “The bias and disregard for citizen concern were rampant during the Commission’s verbal approval and we’ve issued appeals in the past only to be denied and outright ignored. But the words of Margaret Mead – ‘never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has’ – encourage us to continue to work toward energy policy that is environmentally sustainable and in ratepayer’ best interests.”

Almost five years ago citizens, communities and elected officials began asking for proof of ratepayer need and benefits, and to have the costs and benefits of the Badger Coulee project compared to alternatives. Despite laws stating analysis of alternatives must be done, Severson says, the analysis never materialized — not in response to petitions, resolutions, letters from legislators, or a request by PSC staff. And while CETF agrees that Badger Coulee is an economically driven project, we maintain that the economic benefits go to utilities while ratepayers will be saddled with massive unneeded debt and the health, environmental and quality of life consequences that come with these unsightly, unnecessary lines.

Commissioner Eric Callisto ended his term in February 2015 and, in objecting to a December 2014 decision in a case related to local renewables stated, “I think we should slow down…and open up a generic investigation…[to] 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.” CETF agrees.

For More Information Please Contact: Debra Severson
608.269.6218 or 305.299.1400 (mobile)

Wisconsin PSC Approves Badger-Coulee Transmission Line Northern Route


Citizens Energy Task Force (CETF) is appalled, but not surprised, by the Wisconsin Public Service Commission’s approval of the Badger Coulee regional transmission line.

$9 billion dollars in annual reported lobbying is spent to influence US policies, with the fossil fuel industry one of the dominant players and Wisconsin a poster-child state for corporate influence.  Never has the need to change what drives our policies been so evident.

During the March 26 public hearing, the PSC Commissioners read from scripts that sounded like advertisements for the utilities.  Repeating statements claiming that the process was thorough, Commissioners glossed over gross, documented omissions.

Almost five years ago citizens, communities and elected officials began asking for proof of ratepayer need and benefits, and to have the costs and benefits of the Badger Coulee project compared to alternatives.  Despite laws stating analysis of alternatives must be done, the analysis never materialized — not in response to petitions, resolutions, letters from legislators, or a request by PSC staff.  And while CETF agrees that Badger Coulee is an economically driven project, we maintain that the economic benefits go to utilities while ratepayers will be saddled with massive unneeded debt and the health, environmental and quality of life consequences that come with these unsightly, unnecessary lines.

CETF and Save Our Unique Lands (SOUL) are considering filing a Petition for Rehearing with the PSC and/or a Petition for Judicial Review with the circuit court to challenge the legal validity of the PSC decision.  These options are part of the official administrative hearing process.

While the bias and disregard for citizen concern were rampant during the Commission’s approval, the words of Margaret Mead encourages us to continue, “never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.”




For More Information Please Contact:                    Debra Severson

608.269.6218 or 305.299.1400 (mobile)

Badger-Coulee decision to come March 26th.

It should not come as a surprise that, with little notice to the public, the Wisconsin Public Service Commission plans a decision on the Badger-Coulee line on March 26, 2015.

With hundreds of We the People voices expressing discontent with the project, it will be very interesting to see if the Wisconsin PSC hears the voice of the people, or falls back on bad habits of approving projects with study wanting.

Sandra Paske has confirmed that the PSC will make decisions on both Badger Coulee and the route adjustment for CapX2020 tomorrow(Thursday 3.26).

The PSC agenda states:

19. 5-CE-136 – Joint Application of Dairyland Power Cooperative, Northern States Power Company-Wisconsin, and Wisconsin Public Power, Inc., for Authority to Construct and Place in Service 345 kV Electric Transmission Lines and Electric Substation Facilities for the CapX Twin Cities-Rochester-La Crosse Project, Located in Buffalo, Trempealeau, and La Crosse Counties, Wisconsin Proposed Transmission Line Route Adjustments (suggested minute) (JJR/KR memorandum of 3/18/15)

20. 5-CE-142 – Joint Application of American Transmission Company LLC and Northern States Power Company-Wisconsin, as Electric Public Utilities, for Authority to Construct and Operate a New Badger-Coulee 345 kV Transmission Line from the La Crosse Area, in La Crosse County, to the Greater Madison Area in Dane County, Wisconsin (discussion of record)







March 13, 2015  Two of the groups questioning need for the Badger Coulee regional transmission line, which would run from Holmen to Madison, have created a petition asking the Wisconsin Public Service Commission (PSC) to deny the application.

The PSC is expected to make a decision on the application for the high-voltage transmission line in April.  The project’s primary goal is to increase the regional west-to-east transfer of fossil-fuel and wind generated electricity into and through Wisconsin.

“By approving Badger Coulee, ratepayers in and out of Wisconsin will be saddled with unnecessary debt, and our nation tethered to an antiquated, monopolistic business model that rewards utilities for increased consumption and increased infrastructure,” the petition states. “Instead, denying the line would save money, protect property rights, and create jobs through locally generated energy and efficiency.”

The petition, offered by Citizens Energy Task Force (CETF) and Save Our Unique Lands (SOUL), says, “There is cause to pause and no valid ratepayer reason to rush forward. A few pennies a month of unguaranteed savings aren’t worth the risks to health, environment, and quality of life.”

Calling a system based on remote central generation and long-distance transfer of electricity unreliable, inefficient, and vulnerable to attack by man or nature, the petition says transmission supports increased consumption of all sources of electricity including coal and fracked gas.

By comparison, it says a less centralized system using local (distributed) generation and energy management tools enables reliability, resiliency, ratepayer cost savings, and environmental sustainability.

Wisconsin law requires the PSC to deny all or part of an application for new infrastructure if an alternative higher in the state’s energy priority list proves to be financially and technically feasible solution. Energy efficiency and conservation is number one on that list, and renewables are number two.  CETF and SOUL contend the PSC has not yet done a cost/benefit analysis between the proposed line and non-transmission alternatives despite requests by thousands of ratepayers, a dozen legislators and nearly 100 municipalities.

To sign and share the petition, click here.

A Fresh Look at Utility Regulation

Sharing the News!

New York Just Reached A Major Landmark in Electricity System Evolution

Two weeks ago New York State came one step closer to creating the electricity system of the future when the New York Public Service Commission (PSC) adopted its first major Order as part of the Reforming the Energy Vision (REV) proceeding. This is a significant milestone on the path to create a cleaner, more affordable, more modern, and more efficient energy system in New York by harnessing distributed energy resources (DERs) such as demand response, rooftop solar, energy efficiency, and microgrids…

Read the entire article here.

Judge Sides With Citizens Groups in Utility Attempt to Strike Public Comments



Judge Sides With Citizens Groups in Utility Attempt to Strike Public Comments

March 3, 2015: The Wisconsin Public Service Commission will be able to consider public comments on the proposed Badger Coulee regional high-voltage transmission project under a judge’s action Monday overruling utilities’ objections. PSC Administrative Law Judge Michael Newman denied all motions by applicant utilities to strike portions of reply briefs filed on behalf of Citizens Energy Task Force (CETF) and Save Our Unique Lands (SOUL). The reply briefs are final arguments filed in opposition to the utilities’ application.

“The utilities tried to exclude public comments and a summary of these comments that shows overwhelming opposition to the line and a desire to see alternatives evaluated,” said Marcel Olivera, legal counsel for CETF/SOUL. “The Judge’s affirming the rights of the public to be heard is a victory for the thousands of citizens, communities and businesses that have been asking for information and analysis for years but feel they’ve been ignored.”

According to Olivera, applicant utilities had also filed a Motion to Strike portions of CETF and SOUL’s initial briefs or arguments including public comments expressing concern for health, reliability and security risks that were ignored in both the Environmental Impact Statement and application. The judge allowed the majority of the comments to remain, after asking for clarification and further citations.

Applicant utilities claim they exercised substantial diligence in reaching out to the public to hear and address their concerns. If this was the case, CETF and SOUL asked, how can they be unaware of issues brought to the attention of Applicants and the PSC and then try to get record of public conveyed concerns thrown out of the record?

Public comments cited conclusions from and to current yet unaddressed research that demonstrate health risks generally and beyond the right-of-way that utilities would purchase for the proposed transmission project. Comments and research were also provided demonstrating how local (distributed) generation could address reliability and national security risks associated with transmitting electrons from remote centralized generation to distant use centers.

Even if the public had not expressed concerns and cited research, CETF and SOUL said, it seems a company should keep abreast of health, environmental and national security risks associated with their product. Because of the Judge’s order, the majority of these will remain in the record so the Commission may consider them.

The judge also allowed the record to show the calculation of average monthly Wisconsin ratepayer benefits derived from utility projected energy savings. According to the CETF brief, the net present value amounts to between 1.5 and 3 cents. This range includes growth rates higher than the PSC determined as reasonable and does not account for any costs the public will bear such as decreases in property value.

The $540-580 million Badger Coulee high-voltage transmission line is being proposed by ATC and Xcel Energy. If approved, Badger Coulee would plug into CapX2020 facilities, which span from the Dakotas and end in the La Crosse, Wisconsin area. From there, the line would extend to Madison to enable increased capacity to transfer wind and fossil fuel based energy to markets south and east of Wisconsin.

Opponents offered testimony in the case showing how increased transfer capacity causes avoidable reliability issues, and how solar and local wind provide economic advantages over high voltage transmission expansion. The lack of utility analysis of alternative solutions or any guarantee that ratepayers would save money were cited in briefs filed by SOUL and CETF as not in line with statutory criteria to approve a line not in the public interest.

For more information contact: Deb Severson; or Rob Danielson;
608.269.6218 or 305.299.1400 (mobile) 608.625.4949


Care2 Petition Active

CETF and SOUL have collaborated on circulating a petition to raise awareness of the need to consider alternatives to transmission lines for energy management.

With the Wisconsin PSC weighing the application for the Badger-Coulee transmission line, this petition has an immediate need. However, there are many long term economic, health, and environmental considerations, as well.

Please consider signing this petition. Thank you.

Stop Utilities from Investing Our Money in Obsolete Systems that Protect Their Profits

Badger Coulee Transmission Line Draws National Attention

by Deb Severson, Citizens Energy Task Force

The Center for Biodiversity, a national organization dedicated to protecting endangered species and wild lands, had learned of regional transmission expansion impacting Wisconsin after the deadline to intervene. The Center used the public comment opportunity to share concerns regarding deficiencies in the Public Service Commission’s Environmental Impact Statement.

The project cannot meet requirements under Wisconsin laws requiring PSC-approved facilities not have undue adverse impact on environmental values including ecological balance, public health and welfare, historic sites, geological formations, aesthetics of land and water, and recreational use, staff attorney April Rose Sommer said in the Center’s comment.

Construction and operation of the Badger Coulee line would result in the death of protected bird species, clear-cutting thousands of acres of unique and fragile habitat including wetlands and forests, impact hundreds of waterway, and have ongoing adverse impacts on wildlife and wildlands and the people who enjoy them, she said.

The PSC’s Environmental Impact Statement on the Badger Coulee fails to evaluate the effects of the proposed project and alternatives as required by Wisconsin law, Sommer wrote, contending either the PSC, Wisconsin Department of Natural Resources or applicant had time to conduct the required studies. Failure to accurately describe the project or affected environment violates the Wisconsin Environmental Policy Act (WEPA) and deprives the public of the right to make meaningful comment on the project, she said.

The proposal will have a “tragic affect on Wisconsin`s birds,” especially its eagles and cranes, Sommer predicted. Singling out “the plan to sandwich the Holland Sand Prairie State Natural Area, the largest remaining grassland bird habitat in this region, between two transmission lines; to construct a crane and waterfowl death trap in between the foraging and rousting grounds of Leopold-Pine Island IBA; and to run the line through the Kickapoo-Wildcat IBA, home to 25 percent of Wisconsin`s over-wintering golden eagle population,” she said “these will have a devastating and permanent impact on the state`s birds and runs afoul of the Migratory Bird Treaty Act and the Bald Eagle Protection Act.”

Though noting that the project applicants belong to the Avian Power Line Interaction Committee (APLIC), Sommer said they have “demonstrated an abject disregard for avian protection,” concluding “the project should not be approved based on the certainty of high level of bird death by collision and electrocutions.”

The EIS also doesn’t tell the total acres that will be clear-cut, in violation of WEPA, or describe herbicide application in right-of-ways, the center’s comment says.

“It is unclear,” Sommer said, “why the PSC has expended significant resources on processing an application for a project that, by its own terms, is impossible as described.”

ATC Confirms No Guaranteed Ratepayer Savings with Transmission Expansion

January 11, 2015 American Transmission Company witnesses admitted during technical hearings last week at the Wisconsin Public Service Commission (PSC) that they could not guarantee ratepayers’ bills will decrease if the proposed Badger Coulee regional high-voltage transmission line is built. Ratepayer advocacy groups SOUL of Wisconsin and Citizens Energy Task Force have been critical of the economic benefits claimed based on this, and the lack of comparison to no-wire alternatives.

Witnesses from applicant American Transmission Company (ATC) and the Midwest regional grid operator (MISO) said if and how cost savings in the purchase of wholesale energy would be passed to ratepayers would be determined by distribution utilities. Both organizations conveyed they didn’t break down numbers to that level and could only produce totals.

Terry Henn, ATC project manager in charge of Badger Coulee, confirmed that, while the application defines economic benefits as the savings in cost of electricity for Wisconsin, Applicants could not guarantee savings to the ratepayers. According to Henn, “The savings of the project are to our interconnected utilities. How they pass those savings on to the ratepayers is … within their tariff and pay structures and things of that nature…” Henn also confirmed that the application doesn’t identify profits to the applicants.

Testimony by Dale Burmester, ATC’s Manager of Economic Planning, and Xcel Energy’s Amanda King-Huffman demonstrated the Badger Coulee line’s dependency on future projects, and their costs. Badger Coulee’s projections, since 2005, have assumed CapX2020 was in place, Burmester said. The Hampton-Rochester-La Crosse CapX2020 segment was approved by the PSC in May 2012.

Burmester had previously testified that Badger Coulee would be less expensive for Wisconsin ratepayers than the Low Voltage Alternative because Badger Coulee costs would be shared with other states. During the hearing, he confirmed that, in addition to Badger Coulee, Wisconsin ratepayers would also share in costs for other “Multi Value Projects” (MVPs). King-Huffman recalled how Badger Coulee and subsequent MVP projects had been discussed during the 2012 CapX2020 Wisconsin review process, but that their costs were not. King- Huffman also conveyed how this portion of CapX2020, whose costs are primarily paid by Wisconsin ratepayers, is not an MVP portfolio project.

King-Huffman testified that Badger Coulee would not be needed for local reliability in the La Crosse area until 2055 using a load growth of 1.2%. She also confirmed that Xcel did not compare costs and benefits for alternatives for the La Crosse area, she said.

Testimony submitted on behalf of Citizen’s Energy Task Force and SOUL of Wisconsin by engineer Bill Powers demonstrated how the no-wires alternatives of demand response, energy efficiency and distributed generation were less costly solutions to address reliability. Responding to ATC’s Burmester testimony that reliability issues that could occur due to bulk power transfer, Powers explained how there would be no reliability issue if there were no increases in power flow from west to east and that relying on all this imported power was compromising Wisconsin’s transmission system.

Powers also pointed out that wind generation did not match energy use patterns as well as solar, and that increases in fossil fuel based electrons, including lignite coal, would increase as transfer capacity increased. The impact of this was evident in discussions of how five of six scenarios presented by applicants showed increases in carbon emissions.

Henn and other ATC witnesses acknowledged that ATC received requests for a cost/benefit comparison between the high voltage transmission option with alternatives prior to submission of the application. He said ATC took no further action based on them, contending ATC had already done the analysis.

Henn acknowledged perceptions regarding losses in property values, tourism and business, and health and safety concerns but said ATC did not study them because only costs that will come out of the pocket of the project owners are included in cost calculations. This would include payments to affected communities and to landowners to acquire right-of-way easements but not for decreases in property value or the cost of measures to cope with negative impacts of the line such as relocating livestock.

Attorneys for the applicants claimed to have taken damage to the Amish culture into account, but did not provide evidence of doing so. Asked if they have budgeted for possible relocations of Amish families, Henn said he did not believe the company has budgeted for any relocations for those who would move to avoid the line. ATC’s real estate manager conveyed lack of awareness that one of the proposed routes would cross an Amish community, even after driving the route through the state’s largest Amish community outside of Cashton.

In November 2013, the PSC informed applicants that their discussion of the high voltage transmission option and alternatives did not provide a comprehensive summary that would allow the public to better understand the need for the proposed project. Based on this, the PSC asked Applicants revise and expand the application to include a comprehensive discussion of need and alternatives. Concerns were raised during both the technical and public hearings that these requests by the PSC, citizens, municipalities and legislators have not been adequately addressed.

PSC Commissioner Eric Callisto, who did not participate in the public hearings because his term is set to expire in February, objected to a December rate case decision, conveying, “I think we should slow down…and open up a generic investigation…[to] 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.”

Questions regarding the Environmental Impact Statement (EIS) closed the technical hearings. PSC staff recalled citations on health risks not considered in the EIS, with health risks related to corona not included. Applicants also acknowledged not taking this into account. PSC staff admitted that studies on socio-economic impacts were not completed, and that there will be negative impacts with a project of this magnitude.

Over 2,000 comments on the draft and final EIS were received. Well over 90 percent were critical, and the call to comprehensively compare the costs and benefits of the proposed project to alternatives was strong.

Parties involved in the hearings will provide closing arguments by January 30. A decision matrix will follow, and a decision is anticipated by March or April of this year.

For more information contact: Deb Severson; or Rob Danielson;