ACTION ALERT: Support Highland Wind Farm

ACTION ALERT: Support Highland Wind Farm

ACTION ALERT – SUPPORT HIGHLAND WIND FARM
DATE:
February 25, 2013
SUBJECT:
Fate of Highland Wind Farm in St. Croix County Hangs in the Balance
In December 2011, Emerging Energies of Wisconsin filed an application with the Wisconsin Public Service Commission (PSC) for permission to construct the $250 million Highland Wind project in St. Croix County. If built, this 102 megawatt (MW) installation would generate enough zero-carbon electricity from its 41-44 turbines to power 30,000 residences.  Constructing Highland Wind would create more than 100 jobs, while operating and maintaining this facility would require six to eight full-time positions. In addition to its job creation impacts, Highland Wind would pump nearly $1 million each year into the local economy, in the form of both lease payments to host landowners as well as shared revenues to host townships and St. Croix County.
To date, Emerging Energies has invested six years and nearly $2 million on this project.  Highland Wind is the only large wind energy project currently in active development in Wisconsin. 
On February 14, 2013, the PSC issued a preliminary decision turning down Emerging Energies’ application to build Highland Wind.  In doing so, the PSC cited concerns over the level of measurable sound propagated by the turbines that could be detected at neighboring residences.  In a nutshell, the PSC wants stronger assurances that Highland Wind’s wind turbines would be able to operate without exceeding the maximum allowable sound emission levels at any time. The PSC will take up the Highland Wind case again at its next open meeting this coming Friday (March 1st).
On February 22, Emerging Energies filed a request to the PSC to submit additional evidence on the sound propagation issue. The filings came with several affidavits and exhibits to substantiate Emerging Energies’ assurances that the turbines can operate within the sound emissions limits likely to be specified by the PSC. According to Emerging Energies, compliance with sound emission limits will be achieved through the selection of a quieter wind turbine model, one equipped with operational controls that can automatically ramp down output when sensors detect atmospheric conditions conducive to high levels of sound propagation.  Emerging Energies’ filing can be accessed at the link below: http://psc.wi.gov/apps35/ERF_view/viewdoc.aspx?docid=181219
If this filing were accepted into evidence, the PSC would have both the factual foundation and a procedure for approving this project before March 25. As noted in Emerging Energies’ filing, approval of the project by March 25 is necessary to enable the developer to submit the project for consideration in Xcel Energy’s pending solicitation for an additional 200 MW of wind generating capacity.
On Monday February 25th, RENEW Wisconsin will file comments supporting Emerging Energies’ request to have its February 22 filing entered into the case record as evidence. RENEW also supports Applicant’s request to the Commission not to issue a final denial order in this proceeding, as well as its suggested procedures and related time frames for presenting additional evidence in a manner that allows the Commission to issue a final order by March 25.  The text of RENEW’s two-page filing appear below this Action Alert.
March 1st is a red-letter day for Highland Wind. Either the PSC will (1) accept Emerging Energies’ filing and with it documentation substantiating Highland Wind’s capacity to operate in full compliance with sound limits established by the PSC in this case, or (2) finalize its denial of Highland Wind.
If the PSC turns down Highland Wind, it’s a pretty safe bet that Emerging Energies will not submit another application to build in that location. A denial would also send a clear signal to all concerned that Wisconsin’s political climate has become positively radioactive for wind development. 
YOU CAN HELP! YOU CAN LET THE GOVERNOR’S OFFICE KNOW THAT YOU ARE AMONG THE 85% OF WISCONSIN RESIDENTS WHO SUPPORT THE DEVELOPMENT OF ENVIRONMENTALLY RESPONSIBLE RENEWABLE ENERGY PROJECTS LIKE HIGHLAND WIND.
Please contact Governor Scott Walker:  Phone (608) 266-1212 or e-mail  govgeneral@wisconsin.gov
ENVIRONMENTALLY RESPONSIBLE WINDPOWER PROJECTS ADVANCE THE PUBLIC INTEREST. NOW IS A GOOD TIME TO COMMUNICATE THAT MESSAGE TO THE GOVERNOR’S OFFICE.
Thank you for your thoughtful consideration of our request.
+++++++++++++++++++++++++++++++++++++++++++++++++++++++


BEFORE THE
PUBLIC SERVICE COMMISSION OF WISCONSIN
Application of Highland Wind Farm, LLC for a
Certificate of Public Convenience and Necessity                                              Docket No. 2535-CE-100
To Construct a 102.5 MW Electric Generation
Facility and Associated Electric Facilities, to be
Located in the Towns of Forest and Cylon,
St. Croix County, Wisconsin
RENEW WISCONSIN’S COMMENTS ON HIGHLAND WIND FARM’S EMERGENCY REQUEST FOR LEAVE TO PRESENT ADDITIONAL EVIDENCE
RENEW Wisconsin respectfully requests the Commission consider the following comments in response to the Emergency Request filed by Highland Wind Farm LLC on February 22, 2013 (PSC REF# 181219). RENEW Wisconsin is an intervener in this proceeding.
RENEW Wisconsin has reviewed the Applicant’s Emergency Request as well as the exhibits and affidavits associated with that filing. Highland Wind’s filings address the central issue—the ability of this project to comply with applicable sound emission limits–that led to the Commission’s motion to deny the Application at its February 14, 2013 open meeting. Applicant’s Emergency Request asks the Commission not to issue a final order denying Highland Wind’s CPCN at its March 1st open meeting. Instead the Applicant asks the Commission to conduct further discussion of the evidence that is already in the record and, if necessary, to also consider the information contained in the Applicant’s filings as a basis for determining whether the Highland Wind project can comply with the sound limits established by the Commission. Based on our review, RENEW believes that this information warrants Commission consideration. We therefore support Applicant’s request for leave to present additional evidence, as well as its request to allow interveners to respond to its request prior to the next open meeting. RENEW also supports Applicant’s request to the Commission not to issue a final denial order in this proceeding, as well as its suggested procedures and related time frames for presenting additional evidence in a manner that allows the Commission to issue a final order by March 25. 
Discussion: RENEW supports the Applicant’s Emergency Request because we believe that operational curtailment is an appropriate and effective mitigation measure to ensure compliance with applicable sound emissions standards. In fact, we believe that operational curtailment is the most effective tool available to a windpower project operator for reducing sonic output from individual wind turbines to allowable levels. Of the many variables and factors that determine what levels of sound might be measurable at a residence near a wind turbine (e.g., wind speed differential at different elevations, barometric pressure, humidity, background sound levels), the only one that is fully under the project operator’s control is power production.  Operational curtailment limits power generation from turbines, which results in a reduction of sound emissions. The Commission is fully cognizant of the role that operational curtailment can play in controlling sound emissions, as demonstrated by the conditions it imposed on the Glacier Hills wind project in its January 2010 order and by the provisions it approved in the development of PSC 128. In the latter instance, PSC 128.14 explicitly allows project owners to use curtailment procedures to maintain sound emissions below the maximum allowable levels.
Many of today’s utility-scale wind turbines come equipped with automated curtailment protocols that are triggered under a variety of atmospheric conditions. The more sophisticated models can ratchet power production when sensors detect atmospheric conditions that could contribute to long-distance sound propagation. As stated in its Emergency Request, Highland Wind is committed to using only those wind turbine models that are programmed to curtail power output based on real-time atmospheric phenomena such as wind shear. This commitment should remove any lingering uncertainty over whether Highland Wind can operate in full compliance with the sound limits specified by the Commission in this proceeding.
Summary: Apart from the question of whether Highland Wind can comply with sound limits modeled for the Commission’s consideration, this project undeniably advances the public interest in terms of stimulating local economic development, diversifying our region’s resource portfolio, enhancing energy security, and reducing pollution caused by fossil generation sources. We believe that the Applicant is correct that the existing record supports issuance of a CPCN with appropriate conditions.  Moreover, the exhibits and affidavits submitted with Applicant’s Emergency Request fully address any lingering questions that the Commission might have about the project’s sound profile. For that reason, RENEW believes that these filings should be entered into evidence and made a part of the record, so that the Commission has a factually solid foundation for rendering a decision on Highland Wind.
Respectfully submitted this 25th day of February 2013. 

Wind farm proposal rejected, developer plans another try

More on the Highland Wind Farm PSC decision: an article by Thomas Content of the Journal Sentinel:

State regulators on Thursday rejected an application to build a new wind farm in St. Croix County, citing concerns about turbine noise the project would generate for nearby homes.

The state Public Service Commission voted 2-to-1 to reject Emerging Energies’ proposal to build the Highland wind farm, which was proposed to generate 102.5 megawatts of power from 41 turbines, or eough to supply about 30,000 homes.

Commissioners said that they were rejecting the proposal “without prejudice,” in essence leaving the door open for the developer to file a new application for the project, after it conducts a new noise study using more conservative assumptions about the background noise in the area.

The $250 million Highland project is the first wind farm to be ruled on by the state commission since Republican Gov. Scott Walker appointed two commissioners, a majority of the three-member panel.

Emerging Energies representative Jay Mundinger said after the vote the developer plans to continue its pursuit of a permit for the project.

Commissioner Eric Callisto, the lone remaining appointee of former Democratic Gov. Jim Doyle, said he would have approved the project but would have attached conditions binding the developer to protect nearby landowners from excessive turbine noise.

Noise studies by the applicant found that 20 homes would experience noise levels above the 45 decibel standard at night, but the commission could work with the developer on “micro-siting” issues after new analysis was done, he said.

The Highland project is the only large wind energy project currently in active development in the state. The state’s utilities have already built enough wind farms to comply with the Wisconsin renewable portfolio standard, which requires that 10% of the state’s electricity come from renewable sources by 2015.

During the commission’s meeting in Madison, commissioner Ellen Nowak said the applicant didn’t prove that all the wind project would result in noise levels below 45 decibels at night, the standard that’s in Wisconsin’s wind siting rule.

As a result, she said she concluded the project was not in the public interest.

In their decision, the PSC commissioners decided not to attach special requirements concerning low-frequency noise, after wind consultants studied the impacts of low frequency noise from wind turbines the same developer built near Green Bay.

Reached after the meeting, Mundinger said Emerging Energies would take the commissioners’ noise concerns into account but was not giving up on the project.

“We believe that sound, from what we’ve heard, is a big concern, and we believe we can address that and we believe we have a pathway to get the (project permit) in short form,” he said. “We want to make sure we address the sound and be able to move this project forward.”

The company has offered not to use the kind of turbine that it used when developing the Brown County wind farm — the tallest towers built so far in Wisconsin. Instead, Emerging Emergies has agreed to use two other turbines that don’t generate as much sound, he said.

PSC commissioners said they would not approve the project if it used the loudest of the three turbines Emerging Energies had been considering.

“The turbines are better than ever before,” Mundinger said. “They’re quieter than the ones just 10 years ago.”

Peter McKeever, attorney for the Forest Voice, a group that mobilized in opposition to the wind farm,said he was pleased with the commission’s decision.

Wind farms are difficult to build in Wisconsin because the state’s dairy farming heritage and land use history resulted in smaller farms being closer together rather than large farms that are farther apart on the Great Plains, he said.

“If we want wind to be a really viable energy source we have to get smart about siting wind farms in Wisconsin,” he said.

The state should be leery of developing projects where homeowners could experience problems similar to those found in the Green Bay area project, McKeever said.

At issue in this case is one of the variables in that model – an estimate of how much sound would be absorbed by the ground when the wind turbines are spinning.

In this case, the commission essentially asked Emerging Energies to assume a worst-case scenario:  That the 45-decibel standard will be met at all times, even when there is totally reflective ground – hard frozen ground with no snow or vegetation on it.

The commission adopted a more stringent noise requirement than it did when it approved its most recent wind farm, the We Energies Glacier Hills Wind Park, in 2010, said Katie Nekola, general counsel at the conservation group Clean Wisconsin. However, in that case, there was no challenge to the assumptions used by We Energies in its turbine noise modeling.

She expressed hope that the decision would be a temporary setback for the Highland project.

See the original posting of this article here.

Legislators set to speak at Powering Positive Action

Neither encouraged nor discouraged by state legislative election results, RENEW Wisconsin will hold its second annual energy policy summit to shape policy initiatives that will increase customer-driven renewable installations in 2013 and beyond.  Register now!

Set for Friday, January 11, 2013 in Madison, RENEW Wisconsin’s  summit, called Powering Positive Action, will synthesize the ideas and aspirations of business leaders, elected officials, and clean energy advocates into an achievable policy agenda.

This year a bipartisan legislative panel will outline their energy policy goals and identify specific initiatives that can move forward in the upcoming session.

Senators Dale Schultz (R-Richland Center) and Jennifer Shilling (D-La Crosse), and Representatives Chris Taylor (D-Madison) and Gary Tauchen (R-Bonduel), and Chris Schoenherr, Deputy Secretary of the Department of Administration, have agreed to take part in the legislative panel. 

Other plenary sessions will focus on policies and practices that advance jobs and economic development through in-state development of renewable energy.  One promising initiative vigorously promoted by RENEW, called Clean Energy Choice, would allow businesses and residential households to directly access clean energy produced on their premises from third party-owned systems.

We would like policymakers to hear company representatives discuss the fit between on-site renewables and their ability to remain competitive in a period of great energy transition.

Over the lunch hour, RENEW will recognize a host of pioneering businesses that are advancing renewable energy use in Wisconsin.  This year several businesses and nonprofits took the reins of the renewable energy marketplace, and we wish to honor their outstanding achievements.

Former Colorado governor Bill Ritter will deliver the keynote address.  During his two terms, Ritter championed several innovative policies that are now fueling one of the healthiest energy economies in the nation.

Click to see registration details and other information about RENEW’s 2013 Energy Policy Summit.

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RENEW thanks our current Summit sponsors:

Breakout Sponsors
DVO | Anaerobic Digesters – Bioenergy Session      
American Wind Energy Association – Wind Session            

Champion Sponsors                                    
Cullen Weston Pines and Bach
Organic Valley
W. W. Williams

Advocate Sponsors
Danfoss
Madison Solar
Michael Best and Friedrich, LLP
Prairie Solar Power & Light
Stantec
Western Technical College
         
Supporter Sponsors
Baker Tilly
Clean Wisconsin
C.R. Boardman
Michels Corporation
Midwest Renewable Energy Association
Sierra Club – John Muir Chapter
Werner Electric Supply

Commentary: How Wisconsin regulators 'tax' renewable energy

Michael Vickerman’s commentary in Midwest Energy News on the recent changes in WI renewable energy. Find the original post here.

Commentary: How Wisconsin regulators ‘tax’ renewable energy

RENEW Wisconsin’s Michael Vickerman

Starting next January, the price of purchasing renewable energy voluntarily through monthly utility bills will spike to all-time highs, thanks to recent decisions rendered by the Public Service Commission of Wisconsin (PSCW) on two popular “green pricing” programs.

The thousands of Madison Gas & Electric (MGE) customers participating in the utility’s Green Power Tomorrow program will see their premiums jump from 2.5 cents/kWh to 4 cents/kWh. That’s an increase of 60 percent. To translate this into dollars and cents, an average MGE customer consuming 500 kWh of electricity per month and subscribing at the 100 percent level will pay $90 more in 2013 for the same amount of renewable kWh sold this year.

Residential customers of Milwaukee-based We Energies (WE) will see an even larger percentage increase next year. In that utility’s rate case, the PSCW jacked up the premium paid by Energy for Tomorrow subscribers by nearly 73 percent, from 1.39 cents to 2.4 cents/kWh. Energy for Tomorrow has more than 20,000 subscribers.

Back in 1999, the year both programs were launched, MGE and WE customers paid an extra 3.33 cents and 2.04 cents/kWh, respectively, for the renewable energy they sponsored. Come January 1st, MGE and WE will likely share the dubious distinction of being the only utilities in the country offering renewable energy at a higher rate than they did in the 1990’s. So much for progress.

Adding insult to injury, renewable program subscribers will be subject to general rate increases approved by the PSCW this November. The utilities sought higher rates to recover the costs of retrofitting older coal-fired power stations with modern pollution controls. The fact that the renewable generators leveraged by program participants will never need pollution control retrofits is wholly disregarded in determining the size of the premium.

This is unquestionably a subsidy that flows from program participants to all ratepayers.

How did this happen?
Since 1999, renewable generation costs have tumbled, while productivity has improved.
A frustrated program subscriber might well ask: If base utility rates are going up, and the cost of renewable electricity is declining, why are premiums going up instead of down?

The short answer is that wholesale electricity prices have sagged in recent years, owing to a combination of unsustainably low natural gas prices, stagnant demand, and rapid expansion of wind power displacing higher-cost generation. In contrast, the price of renewable energy procured under long-term contracts held steady. When prices dropped in the wholesale market beginning in late 2008, the gap between system energy and renewable sources widened.

Though accurate, the above explanation is deeply unsatisfying, because the wholesale “market” is concerned about one thing only: the marginal cost of producing electricity into the grid. Nothing else matters, including the expenditures approved by the PSCW to reduce emissions from older generators. Even though retail customers wind up footing the bill for those upgrades, the wholesale market does not treat pollution control retrofits as marginal costs. Not one cent paid by ratepayers for these expenditures is reflected in the prices that renewable generators compete against.

The net effect of this disconnect is to artificially suppress the price of electricity from older and dirtier generators relative to newer and cleaner electricity producers. Real markets factor in the cost of upgrading and replacing capital equipment that manufacture the product bought by customers. What we have instead is an artificial contrivance that sacrifices long-term considerations like clean air, resource diversity and regulatory risk for the short-term reward of low prices.

Indeed, it would be difficult to design a more punitive market structure for renewables than the one we have at present.

‘Swimming up a waterfall’
Pricing renewable energy against a market operating in real time also undermines a valuable attribute of renewable energy, namely its inherent price stability. In this environment, the only way a customer can directly benefit from a fixed-price energy source like solar is to self-generate at his or her premises to reduce consumption of grid-supplied electricity.

In setting the premium size, the PSCW relied on pricing data at a time when the regional wholesale market was near its cyclical bottom. Electricity prices are now edging upward as forward prices of natural gas have rebounded from historic lows earlier this year. It’s a safe bet that wholesale electricity prices will continue to increase in 2013.

This sets up the very real possibility that WE and MGE will collect more revenue than is necessary to cover the cost spread between system energy and the renewable energy supplies servicing their customers. Unfortunately, the next time the base premium for each utility can be adjusted is January 1, 2015.

For at least a century now, fossil fuels have been the default resource option for most utilities. Against this institutional bias, switching to renewable energy is akin to swimming upstream. But given how far backward the PSCW bent to accommodate utilities’ continued reliance on coal and natural gas, quite a few renewable energy subscribers may balk at the prospect of swimming up a waterfall.

In fairness to MGE and WE, the price hikes approved by the PSCW went well beyond the incremental increases proposed by the two utilities. That’s because the agency relies solely on the wholesale “market” metric described above that filters out all societal benefits from the equation. To the agency, renewables are another source of electrons that deserve no special consideration. And, in reaching its decision, the PSCW disregarded the potential impact that abrupt price hikes might have on customer participation.

Programs outliving their usefulness?
A significant loss in subscribership would be a regrettable outcome if the programs were still viable vehicles for leveraging new sources of renewable energy. Sadly, that is no longer the case.

Earlier this decade, WE and MGE pulled the plug on a popular feature of their programs, specifically the special solar energy buyback rates that were funded with participant dollars. This innovation, which spurred the installation of hundreds of solar electric systems in their territories, succeeded in elevating MGE and WE’s stature while achieving the aims of their participating customers. However, when the utilities eliminated their solar incentives, they also removed the principal rationale for subscribing to their programs.

It seems quite clear that the current crop of voluntary renewable energy programs have outlived their usefulness. They are stagnating under a market structure that distorts and amplifies their true costs as well as a regulatory climate that greatly discounts their benefits to ratepayers. What were once dynamic vehicles for increasing supplies of renewable energy are now little more than feel-good marketing exercises running on autopilot. The value proposition to customers just isn’t there anymore.

There is nothing out there to prevent utilities from revitalizing their green pricing programs and making them useful once again. Such an undertaking, however, would require them to do something they haven’t done before: present an affirmative case for adding more renewables into their energy mix.

To do that effectively, utilities would need to recognize that the fossil energy path leads to a dead-end and that renewables ought to be the default resource option going forward. From that starting point, designing a program in which modest customer premiums actually result in additional supplies of renewable energy should be a simple and straightforward exercise.

It’s the very least a responsible utility should do to reduce the impact of generating electricity on the one planet we are privileged to call home.

Michael Vickerman is program and policy director of RENEW Wisconsin, a sustainable energy advocacy organization. RENEW Wisconsin is a member of RE-AMP, which also publishes Midwest Energy News.

Find the original article post here.

RENEW Wisconsin’s Energy Summit Plans Policy Actions for 2013

Immediate release:                                              
December 5, 2012
               
More information:
Michael Vickerman
608.255.4044, ext. 2
mvickerman@renewwisconsin.org

RENEW Wisconsin’s Energy Summit Plans Policy Actions for 2013

Neither encouraged nor discouraged by state legislative election results, RENEW Wisconsin will hold its second annual energy policy summit to shape policy initiatives that will accommodate customer-driven renewable installations in 2013 and beyond.

Set for Friday, January 11, 2013 in Madison, RENEW Wisconsin’s  summit, called Powering Positive Action, aims to synthesize the ideas and aspirations of business leaders, elected officials, and clean energy advocates into an achievable policy agenda.

“This year a bipartisan legislative panel will outline their energy policy goals and identify specific initiatives that can move forward in the upcoming session,” said Michael Vickerman, RENEW Wisconsin’s Director of Policy and Programs.

Senator Dale Schultz (R-Richland Center), Representatives Chris Taylor (D-Madison) and Gary Tauchen (R-Bonduel), and Chris Schoenherr, Deputy Secretary of the Department of Administration, have agreed to take part in the legislative panel.

Other plenary sessions will focus on policies and practices that advance jobs and economic development through in-state development of renewable energy.  One promising initiative vigorously promoted by RENEW, called Clean Energy Choice, would allow business and residential customers to directly access clean energy produced on their premises from third party-owned systems.  “We would like policymakers to hear company representatives discuss the fit between on-site renewables and their ability to remain competitive in a period of great energy uncertainty,” Vickerman said.

Over the lunch hour, RENEW will recognize a host of pioneering businesses that are advancing renewable energy use in Wisconsin.

“This year businesses and nonprofits took the reins of the renewable energy marketplace, and we wish to honor their outstanding achievements,” Vickerman said.

Former Colorado governor Bill Ritter, will deliver the keynote address.  During his two terms, Ritter championed several innovative policies that are now fueling one of the healthiest energy economies in the nation.

Registration details and other information about RENEW’s 2013 Energy Policy Summit are posted at www.renewwisconsin.org.
         

— END —

RENEW Wisconsin is an independent, nonprofit 501(c)(3) organization that acts as a catalyst to advance a sustainable energy future through public policy and private sector initiatives.  More information on RENEW’s Web site at www.renewwisconsin.org.