November 6, 2014 The final Environmental Impact Statement (EIS) on the proposed Badger Coulee regional high-voltage transmission line leaves significant questions unaddressed and continues to skirt important issues, according to Citizens Energy Task Force (CETF) and Save Our Unique Lands (SOUL of Wisconsn).
In the document released Nov. 5, the PSC says need for the proposed Badger Coulee project has yet to be determined. Applicant testimony conveys the primary need for Badger Coulee is to deliver economic benefits, but SOUL and CETF say the EIS fails to analyze who profits and by how much or to tally all economic and environmental costs that would be borne by Wisconsin citizens.
According to CETF and SOUL, there is cause to pause. With only potential slim savings and expansion planning with no focus on net carbon emission reduction, the groups ask if it’s worth the risks to our environment and our health. “Regional transmission protects centralized utilities which, when combined with policies that suppress alternatives, unfairly limits free market choice,” said Debra Severson of CETF. “Wisconsin energy decisions should benefit the public, not special interests.”
Negative economic impacts on tourism, land use and property values have not been captured in the financial analysis and the PSC admits it lacks the data to do so, “ said Rob Danielson of SOUL. “One has to question such a review process.” Similarly, positive economic and environmental impacts of non-transmission alternatives, such as energy efficiency and local renewables, were not compared to the high voltage option.
Wisconsin has the legal right to assess need and deny approval if in-state ratepayer benefits are not proportionate to Wisconsin ratepayers’ costs or if other solutions better serve us. Without capturing all costs, benefits and risks, the groups say, an accurate assessment is impossible and the PSC cannot fulfill this obligation.
Wisconsin legal statutes give priority to energy conservation, efficiency and renewable generation. Decision criteria states that if the PSC finds any of these options, or a combination of them, constitute a cost effective and technically feasible alternative, the PSC must reject all of or a portion of the project. Despite this, the EIS fails to compare the reliability, cost, carbon reduction and job creation benefits of alternate solutions.
“More than 2,000 citizens, 90 municipalities and 12 legislators have asked the PSC for a complete, unbiased analysis comparing alternatives to building the high voltage transmission option,” said Danielson. “These requests continue to go unanswered despite statutes that recommend description of alternatives in time for ratepayer input in the EIS.”
The applicants claim Badger Coulee will deliver public policy benefits related to renewables, but the EIS fails to report in-state benefits or to compare the benefits to alternate policy directions. In addition, it does not consider the public policy benefits of avoiding environmental and health risks with non-transmission alternatives, fails to assess the health and migratory impacts of corona induced UV and ionizing radiation, and does not address likely irreversible damage that will linger despite remediation efforts.
While not yet addressed in the final EIS, the groups will continue to ask the PSC to assess inherent reliability risks and costs associated with maintaining a centralized grid, and to evaluate if transmission planning and utility policies are suppressing technologies in a monopolistic manner that does not serve the best interests of Wisconsin citizens, communities and businesses.
Public hearings to comment on the EIS and other considerations are scheduled for December 8-15. [See data breakout on next page.]