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 1^st).

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 25^th, 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 1^st 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.

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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 1^st 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 25^th day of February 2013.