Author Archives: Rob Danielson

Wind Power Plant Developer and County Secrecies Continue

        There are four, fundamental facts that every community and every landowner approached by a wind power developer wants and deserves to know: 

  • What is the power size in megawatts of each turbine?
  • How tall are the turbines?
  • How many would be installed and over what area?
  • With today’s wind turbines more than twice as tall and 3.6 times more powerful/louder than those at Montfort, Wisconsin[1], the public deserves to know if the company has tested the turbines for noise and air impacts under Wisconsin’s lower standards?[2]

        Three of the multi-national companies pursuing large wind power plants in Iowa, Lafayette and Grant Counties (Wisconsin) have provided none of this information either for the public, at large, or for directly affected landowners or their neighbors. To be specific, this fundamental information was omitted in PRC’s mid-April brochure[3] regarding the Red Barn power plant that would surround Montfort, it was not present in Invenergy’s mid-February notice[4] to Iowa County  and Pattern LLC did not mention it in their interview[5] 1 with the Dodgeville Chronicle this month concerning their Uplands plant proposal aimed at Iowa and Lafayette Counties.

        Further, when counties have received scarce information from developers, they have not informed the public about it or placed it into public records. The seriousness of these omissions becomes evident when one considers that Foxconn’s much discussed $672 million plant proposal has only one-third of the value of Uplands when tax and other incentives are folded in over 40 years. (See p. 2 / note 10, https://bit.ly/uplands-m ) 

     And unlike large factories and farms, the wind power plants would be glaringly obvious to all commuters and vacationers on Highways 151 and 18 all the way from the outskirts of Madison to the Bluffs of the Mississippi River. Day and night.  (See p. 3 / note 16, https://bit.ly/uplands-m  ) 

        Had Invenergy’s February 16, 2021 letter to the Iowa County Board [6] been publicly reported, the citizenry of Southwestern Wisconsin would have found the company’s advice about the County’s out-dated, 2014 Wind Ordinance highly informative. The international power plant builder writes, “We encourage you to leave it in place,” despite the fact that updating it would add protections pertaining to impacts from large turbines and other transparency improvements.

    The outcome of Uplands still rests on landowners not signing lease contracts with Pattern. Those who are approached to sign are encouraged to ask themselves:


Why would Invenergy risk stating this request if the company had no fear of increased public and landowner accountabilities from an updated Wind Siting Ordinance?

      Secrecy on both sides has persisted even as community papers have published a steady stream of citizen concerns and information requests since December. The Iowa County Board has yet to acknowledge that more than fifty citizens formally asked the Board to host an on-record, public information meeting for developers to answer questions received in advance and for citizens to ask follow-up questions.

        Concerns about negative health impacts were furthered at the Iowa County Planning and Zoning Committee meeting last week when Scott Godfrey, a member of the Wisconsin Wind Siting Council, stated that he sees little or no ability for County to stand-up for affected residents should they become chronically sick from wind turbine exposures. In 2010, three Wisconsin families were forced to move from their homes in Brown County, Wisconsin when they were exposed to only eight turbines. Those turbines are two hundred feet shorter and have less than half the power of those aimed at the Livingston, Wisconsin area.[7]

        No one disagrees with Invenergy that outdated and lacking public protections are doing a very good job of, “promoting private property rights.” They have literally placed the future of Southwest Wisconsin in the hands of our neighbors. This is our time; this is our test; we either practice the golden rule or have our lands and local economies ruled by outside interests.

  1. Size data at https://bit.ly/Whitetail-Livingston-5_6MW ; http://bit.ly/WhitetailFAARecords-698ft and http://bit.ly/MontfortWind-Description Official utility records indicate that turbines proposed to surround Livingston, WI would be more than twice as tall as the turbines at Montfort (698′ vs. 328′) and have 3.6 times the power (5.6 MW vs. 1.5 MW). The Livingston Turbines said to be under development by Whitetail would be 58% higher than those more recently installed at Quilt Block near Darlington. 
  2. Distances between the wind turbines and residencies in Wisconsin can be as close as 1250’ compared to 1500’-3750’ in other states. Fully allowable noise levels in Wisconsin can be four times louder than background sound levels. Existing Wisconsin codes have no protections against house-vibrating air pressure pulses that can induce nausea, disorientation, sleeplessness and other serious ailments.  
  3. http://bit.ly/RedBarnBrochure-20210416 
  4. https://bit.ly/InvenergyIntentLetter_20210216 
  5. https://bit.ly/Pattern-DodgevilleChronicle-20210401 
  6. https://bit.ly/InvenergyIntentLetter_20210216 
  7. http://bit.ly/3-Families-Move-Out-ShirleyWind-2014 
No-Uplands.com Bensinger Video Vimeo

No-Uplands Wind – A Video by Charles Bensigner

Shown above: A 2.5 MW wind turbine being installed for Pattern Wind LLC in New Mexico, the same company that proposing a high visibility wind system across a 250 square mile area in western Iowa and Lafayette counties, Wisconsin.

No-Upands.com is pleased to announce that Milwaukee-based videographer Charles Bensigner has produced a 3 minute video introducing the 600 MW Uplands Wind power plant proposal to the citizens of Wisconsin. With approximately 170 turbines 650 feet in height, the power plant would permeate many Wisconsin views of the world reknown Driftless area and establish the second largest power plant in the Midwest despite the area having far less than optimum wind resources.

In a recent letter to MARIA REDMOND head of Governor Ever’s Office of Sustainability and Clean Energy, Bensinger asks,

I’m wondering if you’re aware of the tremendous tension and public outcry occurring in certain rural Wisconsin communities regarding what appears to be the forcing of local communities to accept the construction of very large solar and wind farms promoted by out-of-state developers?

Bensinger attributes the underlying causes for the community strife,

[Sales a]gents for these developers often operate in a secretive manner to obtain land contract agreements with landowners, often pitting neighbors against each other and their local political representatives. Residents fear they will suffer deleterious health effects, business disruption and significant environmental impacts from wind and solar farms, loss of good farmland, property values, cherished viewscapes and a major reduction in their quality of life.

Bensinger is no newcomer to energy problem solving and the primacy of local economics. His is currently engaged with several projects with helping neighbors in his urban Milwaukee neighborhood improve the energy performance of their homes. He has found that electric bills in his neighborhood are often 2-3 times higher than bills in nearby neighborhoods. As Wisconsin rebates for efficiency and home improvements rank near the bottom of Midwest states, Bensinger believes that asking urban ratepayers to fund remote power plants is counter-productive on two fronts: (1) by adding new costs to bills that would be better directed to larger Focus on Energy rebates and (2) by under-cutting the development of local measures that would make Milwaukee neighborhoods decreasingly dependent on remote renewable power. The former Director of the Alternative Energy and Biofuels Center at Santa Fe Community College believes that, eventually, urban neighborhoods or clusters of 2-10 houses/businesses will be operating on locally owned micro-grids based on small scale generation technologies. He is particularly enthusiastic about Inductance Energy‘s Earth Engine but expects there to be many solutions far more affordable than the costly monopoly expansion model that Uplands Wind promotes.

Bensinger’s commitment to locally produced power applies to rural local economies as well. He called upon his rural ties in New Mexico to obtain photographs of turbines being installed by Pattern LLC, the same company proposing the Uplands power plant,

Through the, Wisconsin Video Hub, Bensigner and his cohort, Daniel Folkman, have documented important conferences and presentations pertaining to Wisconsin’s rural communities. Below is a sampling of the entries from their library:

  • Limitations of the Midwest Independent System Operator (MISO) Engineer Bill Powers discusses, Midwest Transmission Expansion Planning [MTEP], utility-prejudiced economic analysis used by regional transmission owners under the auspices of The Midcontinent Independent System Operator [MISO]. MISO and MTEP planning are often confused as having governmentally assigned energy planning authorities. Increasingly, SOUL of Wisconsin and citizen intervenors are challenging the false public impressions and MISO’s annual, capital utility spending exercise. 60 min, 2018
  • Negative Impacts of Expansion Transmission Lines Town of Holland Clerk Marilyn Pedretti (La Crosse Co. WI) describes how their town was ill-prepared for dealing with the economic and other negative impacts from the presence of two 345 kV expansion transmission lines. 10 min, Mar 2018
  • More Wires to Serve Less Need? As legal counsel for the Town of Holland, Frank Jablonski describes the need to challenge Wisconsin Utilities and the Public Service Commission (PSC) purported “need” for additional power and power lines. 9 min, 2018
  • Our Distributed, Local-Based Energy Futures Drawing upon his experiences from authoring long term energy planning for San Diego, San Francisco and the state of North Carolina, Engineer Bill Powers describes the rapid progress being made in home, business and municipal developments of solar plus storage. He discusses the additional roles that energy efficiency and load management play in creating a right-sized electrical system. 12 min, Mar 2018

Encouraging Iowa County Official Accountability and Action

Executive Committee Must Approve Ordinance Upgrade Motion at March 9, 2021 Meeting

SOME RECENT HISTORY

At highest levels, Iowa County officials have known about the massive 600 MW Uplands Wind project for more than a year. To date, the County has yet to acknowledge the international developer’s large scale interests and is even on record as instructing inquiring County Supervisors to tell their constituents to phone Pattern Wind LLC for answers to their questions rather than expect the County to attain information.

Whether on purpose or not, County foot dragging furthered the ability of Pattern LLC sales agents to obtain leases from landowners nearly undetected by the public at large. Were these high officials aware that Pattern was getting closer and closer to obtaining the critical number of lease signatures so the massive proposal would clear transmission connection requirements and leap quickly to the review by the state with short review review by the County under an old, incomplete Wind Siting Ordinance? Speaking just for itself, the public record raises reasons for concern.

Through last Fall, the Planning and Zoning Committee ignored requests by Committee members to ask the multi-national developer to hold public information meetings.

To help speed-up the process of bringing the County’s 2014 Wind Siting Ordinance up to current state standards, a citizen intervenor involved with the appeal of the Cardinal Hickory Creek transmission line, drafted an updated Wind Siting Ordinance carefully weaving in missing, allowable protections from PSC Code 128 into the County’s existing document. In early December, the Planning and Zoning Committee, with higher officials present, hardly gave the updated Ordinance a glance. After more delays, the Planning and Zoning Committee voted to table the entire Ordinance update initiative on January 26, 2021.

Having seen enough inaction, 86 citizens “zoomed” into February 15, 2021 Iowa County Board Meeting with more than 20 using the public comment period to voice concerns about the proposed 600 MW Uplands wind power plant proposal. Most emphasized that after months of inexplicable delay, the County must act immediately to update its 2014 Wind Siting Ordinance. Later in the meeting of the full board, a number of County Supervisors clarified these requests by requesting that the Planning and Zoning Committee resume its work updating the 2014 Wind Siting Ordinance.

With citizen caution still running high, on February 25, the Planning and Zoning Committee heard many more, precise and informed requests during the public comment period at the start of the meeting. The Chair of the Committee responded by simply stating that public comments would receive no reply and that Pattern’s proposal and the Ordinance Update were not on meeting agenda and will not be discussed,

Over the course of a year, Iowa County’s silence and inaction has supported Pattern LLC make steady gains towards its for-profit interests while public interests have yet to be acknowledged– not to mention supported or pursued. In September, the County Chair acknowledged that he is employed on a daily basis helping the efforts of wind developers. When letters were sent to County Supervisors by No-Uplands volunteers suggesting it would be appropriate for the Chair to recuse (remove) himself from all discussion of the matter due possible conflict of interest, the Chair responded that the attack on him was unwarranted. He stated that because his work in currently in North Illinois, no conflict in determining wind development regulation in Iowa County exists.

How close is Pattern LLC to attaining landowner signatures for 75% of the land required for the approximate 250 square mile study area in both Iowa and Lafayette County? This is merely one many key questions that citizens have and elected officials, by duty and position are obligated to determine for the sake of public safety, health and long term welfare of the County’s local economies.

SOME NECESSARY ACTIONS

Patience is no longer an option. The only way the citizens of Iowa County can expect any representation in this upheaval is to phone their county supervisors and use a technique that demands written accountabilities and action. Here is an outline of the proven technique:

1)  Unless one personally knows members of the Iowa County Executive Conmmittee Ron Benish, Dave Gollon, Jeremy Meek, Dan Nankee or Curt Peterson, phone your personal County Supervisor:  https://www.iowacounty.org/media/Directory%202019.pdf

2) Introduce yourself including where you live. 

3) To engage the Supervisor in discussion, prepare and ask 1-3, short clearly stated questions about Uplands details and impacts. Its best to read some materials first and personally determine what missing information is most important to you.  

4) If your Supervisor suggests asking someone else, you have the option to politely say, “OK. I will do that, but as my Supervisor, I want you to experience the difficulty of obtaining factual information and to possess the information you need to make decisions in the best interests of your constituents.”

5) If your Supervisor rattles off information that is not accountable, in writing in the County’s public record, you have the option to politely say, “That is interesting. Can you send me a link to the source for that information? I still want you to research my questions.

6) Tell your Supervisor you will be following up the phone call with your questions in writing in an email. https://www.iowacounty.org/media/Directory%202019.pdf

7) Tell your Supervisor you will phone he or she back in 10-14 days for answers to your questions if you don’t hear from he or she earlier.

8) Conclude the call and the follow-up email by asking the Supervisor to immediately call one of the members of the Executive Committee ( Ron Benish, Dave Gollon, Jeremy Meek, Dan Nankee or Curt Peterson) and ask the member to ask the Chair add a motion to the March 9, 2021 Meeting agenda that would require the County to act immediately to update its 2014 Wind Siting Ordinance to include all available health, safety and other protections allowable in State Code.

SOUL Chronicle Article, Dec. 31, 2020 

Fate of Second Largest Wind Installation in the Midwest in the hands of 50 Wisconsin landowners.

Published in Dodgeville Chronicle, December 31, 2020

Too few residents of Southwest Wisconsin are aware that a Canadian-owned, multinational corporation, Pattern LLC,2 has salespersons on the ground encouraging landowners to sign agree-ments allowing the company to construct at least 1703, industrial-scale wind turbines across Iowa and Lafayette Counties. With heights of around 650 feet, views of the system would permeate the natural horizon from the outskirts of Madison to the bluffs of the Mis-sisippi River4 negatively affect-ing property values over 250 square miles of the Driftless area.5

Were it not for the Federal Energy Regulatory Commission publishing Pattern paperwork in late November6, no one would have learned that the fate of the proposal essentially rests on the signatures of about 507 landowners who are likely to be insufficiently informed. In the experience of Iowa farmer, Mason Fleenor, looking back on his decision observed,

“Nobody knew they were going to be this loud, or hurt our property values or be this big. . . No one wants to build around these windmills so you just cut your economic activity down. . . I just want to see the countryside.”8

Local and state taxes are no longer collected for land with wind turbines. Independent studies estimate property value losses from 15 to 45%.9 Landowners and local officials must stop and consider that the diverted state tax dollar payments to partially cover these losses would fall at least $100 million short over 40 years if only 1% of the affected properties were sold per year at a 10% loss.10

Local tax bases would be forever compromised causing mill rates to soar at the same time compatible, agricultural, residential and business development vanishes.

Keep in mind that unaffected farmland in Wisconsin appreciates in value at the rate of about 4% per year. Landowners pondering the possibility of net income from a 40 year wind turbine lease are encouraged to do the property devaluation math (and get an experienced attorney to carefully review the 60 page contract!). Should the value of one’s land drop at the national average, it would take decades of lease payments to make up for this loss.11 The “option agreement” also forces a landowner to give up rights to determine where turbines, wide access roads and electrical lines would be located12. This uncertainty makes it impossible to accurately in-form neighbors of pending hard ships, not to mention, obtain their informed blessings.

Readers with any doubt that turbine noise thoroughly shatters natural soundscapes and peaceful living are encouraged to spend some time internet searching for personal video testimony about “wind turbine noise.”13 Wisconsin state code allows turbines to generate 45 dBA sound levels during the night and 50 dBA during the day.14 The turbine sound described as a “hovering plane”15 is about four times louder than quiet sounds that comprise natural sounds.16 The resulting sleeplessness, nausea, disorientation and depression has forced Wisconsin families to vacate their homes and farms with turbines half the size of those being proposed.17 Follow this search with “wind turbine shadow flicker,” an equally disruptive experience that Wisconsin code also allows households to endure. 18

Video maker Jim Harmon with property owner, Alan Haas, describing changes in community relations after the addition of 88 wind turbines, three on his property in 2008, “Even sweet little, old ladies get angry as hell now;, and that’s no joke either.”

And there are better alternatives for address of climate change and for our pocketbooks.

Wisconsin already has more electrical power plants than we can use.19 (Table 2). As electric customers, we must pay the high interest debt on existing and added power plants over 40 or more years whether fully utilized or not. Pattern’s inferred electric bill savings from the “zero fuel costs”20 of wind power compare very poorly to directly addressing our CO2 and economic challenges with familiar alternatives. If the approximate, 40 year, $1.8 billion cost21 for the 600 MW Uplands wind power plant was invested, instead, into dramatically increased Focus on Energy rebates for efficiency and solar power improvements for our homes, farms and businesses, this would eliminate about 115 million metric tons of CO2 emissions over 40 years compared to 58 million metric tons from the intrusive power plant.22 (Table 3). Alternatively doubling the home/business solar panel incentive to 52 cents of the approximate $2.50 per watt cost could empower about 450,000 households to “go solar” and save an average of $143 per month.23 Creating attractive appliance and equipment rebates for Wisconsin families and businesses would enable long overdue efficiency and dwelling improvements with the superior environmental results.24

The federal report also confirms that the 600 MW wind system is fully dependent on building the Cardinal Hickory Creek 345 kV expansion trans-mission line which Iowa and Dane Counties are trying to appeal in court. 25 26

Immediate sharing of these findings is critical as Pattern salespeople are working daily to get the 50 additional contract signatures before February 24, 2021.27 Hopefully, both the Iowa and Lafayette County Boards will act quickly to at least add the minimal, still insufficient protections from state code to their Wind Ordinances.28

The additional signed agreements from landowners would allow Pattern to take their power plant proposal directly to the PSC for likely approval as state laws do not require such plants to be evaluated for need or require that benefits from alternative investments be compared.29

— by Rob Danielson, Secretary, SOUL of Wisconsin
PO Box 146
La Farge, WI 54639
608.625.4949
info@SOULWisconsin.org

FOOTNOTES

1 The 162 Megawatt (MW) Glacier Hills Wind power plant is Wisconsin’s largest. https://en.wikipedia.org/wiki/Wind_power_in_Wisconsin Only the 801 Megawatt (MW) Meadow Lake power plant near Chalmers, Indiana would be larger in Midwest states. https://en.wikipedia.org/wiki/List_of_wind_farms_in_the_United_States

2 Pattern LLC financials: https://investors.patternenergy.com/financial-information See also: https://www.prnewswire.com/news-releases/pattern-energy-enters-agreement-to-be-acquired-by-canada-pension-plan-investment-board-300950682.html

3 According to Pattern’s filing to the Federal Energy Regulatory Commission in 2020, the Uplands wind system would be 600 Megawatts (MW). https://bit.ly/FERC-ER21-30-000-20201005 The estimated minimum number of turbines was determined by dividing this number by 3.5 MW assumed to be the size of the largest, modern turbines. (600 MW / 3.5 MW = 171.4 turbines)

4 See map of the Uplands project area, above, and as inserted into a highlands area view scape map at p.4 of https://bit.ly/Uplands-editorial Pattern LLC has not yet publicized turbine height information. October 2018 materials distributed to prospective property participants near Montfort, WI concerning the Red Barn wind power plant, specify turbine heights ranging from 459 to 656 feet. Viewed from highland positions, objects that are 650 feet high can be seen for 38.7 miles, line of sight. https://planetcalc.com/1198/ Nocturnal visibility from highland locations would extend more than 30 miles based on lights mounted at a rotor hight of 410’. For reference, the smaller, 2 MW wind turbines at Quilt Block in the Town on Seymour in Lafayette County can easily be seen from Montfort, Wisconsin, 24 miles away.

5 The measurement of 250 square miles is an approximation based on Pattern’s Uplands study area map in the company’s August, 2020 presentation to the Iowa County Planning & Zoning Committee. A larger view of the blue outlined area is embedded in the middle image on page 5 at http://bit.ly/UplandsPowerpointForIACo202008

6 FERC’s publication is accessible at https://bit.ly/FERC-ER21-30-000-20201005

7 FERC’s publication indicates the Pattern LLC reported to have signed about 15,000 acres of property under “site control” of the 30,000 acres required by regional transmission owners under the auspices of MISO. https://bit.ly/FERC-ER21-30-000-20201005 According to the Wisconsin Department of Agriculture, the size of the average farm in Wisconsin is 221 acres. https://datcp.wi.gov/Pages/Publications/WIAgStatistics.aspx Dividing the remaining 15,000 acres into 221 acre sized parcels suggests an average of 67.8 agricultural property owners would be involved. The estimation of 50 assumes the company will focus on property owners with larger parcels for greater siting flexibilities and fewer affected neighbors.

8 Video interview by Zach Boyden-Holmes with Mason Fleenor (Ida Grove, IA) from Des Moines Register article, “Is wind power saving rural Iowa or wrecking it?” by Donnelle Eller, and Kevin Hardy, April 20, 2017 http://bit.ly/WindWreckingIowa_DesMoinesRegister

9 See comparison of utility-funded and independent studies of wind turbine impacts on property values collected by McCann: http://bit.ly/WindTurbinePropertyValueImpactKielischMcCann Utility studies pose there are modest negative impact on values while those conducted by independent evaluators show very significant range of losses from 15-45% with an average of 29%.

10 See summary table “Tab 2,” on spreadsheet https://bit.ly/Uplands-StateTaxPayment_v_PropertyDevaluation

11 See Tab 1 – Adjusted Lease Income With Property Devaluation table at spreadsheet with calculations at: https://bit.ly/Uplands-StateTaxPayment_v_PropertyDevaluation

12 “Section 2.2 Wind Energy Conversion Systems . . . The exact location of such wind energy conversion systems shall be determined by the Developer in its sole discretion. . . ” and discretionary location rights in Section 2.3 Transmission Facilities and Roads with 80’ easement strips for electrical lines and up to 20’ widths for access roads. The contract also enables the Developer to add transformers, battery storage facilities and relocate equipment at sole discretion.

13 For Wisconsin landowner testimonials, see collection of video interviews at https://bit.ly/WI_Wind_Interviews

14 PSC Code PSC 128.14(3) https://docs.legis.wisconsin.gov/document/administrativecode/PSC%20128.14(3) Dr. Robert Rand discusses the sub-sonic phenomena starting at 1 hour, 27 minutes into this video: https://www.youtube.com/watch? v=2kvoZO-DEho&feature=youtu.be

15 See Elizabeth Eberts interview at 1:54 https://bit.ly/WI_Wind_Interviews

16Assumes nocturnal, rural background ambience of 25 dBA and daytime ambience of 30 dBA. 10 dBA is assumed as perceived doubled loudness. https://www.quora.com/How-many-dB-decibels-represent-a-doubling-or-halving-of-the-sound-volume?share=1

17 Wisconsin Wind Turbines Declared Health Hazard First of its kind ruling; similar to Michigan situation, By Jack Spencer, November 8, 2014, Michigan Capitol Confidential https://www.michigancapitolconfidential.com/20690

18 See Shadow flicker limits. PSC 128.15(2)(2) https://docs.legis.wisconsin.gov/document/administrativecode/PSC%20128.15(2)

19 See Table, Wisconsin Power Plants Excess Capability, pdf p. 5, https://bit.ly/Uplands-editorial Data in the table compiled from announced new power plants and retirements in Wisconsin Public Service Commission 2020-2026 Strategic Energy Assessment https://apps.psc.wi.gov/ERF/ERFview/viewdoc.aspx?docid=390854 , new plants sought in the MISO Interconnection Queue https://www.misoenergy.org/planning/generator-interconnection/GI_Queue/gi-interactive-queue/ US Department of Energy (EIA) Form 861 and SEDS records for WI, US census and inflation data.

20 From Uplands Wind FAQ, “How does wind energy affect the cost of energy? The cost of electricity from wind energy is predictable and stable because there are no fuel costs, unlike conventional forms of energy where the cost of fuel can fluctuate significantly over time. Once a wind farm project is built, the price of electricity from the project is set for the duration of its power purchase agreement.” https://uplandswind.com/faq/

21 See itemized estimated, comprehensive expenses rows 32-46 of spreadsheet, https://bit.ly/CompareEndUserAlternative

22 See table, Uplands 600 MW Wind System vs. Accelerated FOE Incentive, pdf p. 5 https://bit.ly/Uplands-editorial and associated spreadsheet, https://bit.ly/CompareEndUserAlternative

23 See calculations on spreadsheet, https://bit.ly/CompareEndUserAlternative

24 Energy and CO2 reduction benefits sourced from Focus on Energy Calendar Year 2016 Evaluation Report Volume I May 19, 2017 https://www.focusonenergy.com/sites/default/files/Evaluation%20Report%20-%202016%20Volume%20I.pdf and correspondence with EPA staff regarding use of the AVoided Emissions and geneRation Tool (AVERT).

25 From pdf p. 2 FERC November, 2020 communication, “Pattern Energy Wind states that, on June 22, 2020, it submitted two generator interconnection requests to MISO to interconnect the Project via two queue positions: (1) an interconnection to American Transmission Company’s Hill Valley to Cardinal 345 kV line; and (2) an interconnection to the Hill Valley 345 kV substation.” https://bit.ly/FERC-ER21-30-000-20201005 Note: The Hill Valley substation near Montfort does not exist today. It is a central component of the Cardinal Hickory Creek 345 kV transmission line.

26 Dane, Iowa counties challenge power line approval, says regulators abused discretion, by Chris Hubbuch, Wisconsin State Journal Dec 13, 2019, https://madison.com/news/local/govt-and-politics/dane-iowa-counties-challenge-power-line-approval-says-regulators-abused/article_d8c2abb0-c86c-51c7-97fe-44d3bd94b426.html

27 See FERC discussion of extension including time for MISO transmission owners to complete site control review, pdf p.7,8, https://bit.ly/FERC-ER21-30-000-20201005

28 Iowa County Draft Updated Wind Ordinance starting on pdf. p. 68 https://evogov.s3.us-west-2.amazonaws.com/meetings/107/attachments/9206.pdf Contact information for Iowa and Lafayette County Wind Ordnance matters: Iowa Co. Supervisor Districts, map: https://www.iowacounty.org/media/Districts.pdf Iowa Co. Supervisors contacts: https://www.iowacounty.org/departments/countyboard/county-board-members Iowa County Planning & Development 222 N. Iowa St. Dodgeville, WI 53533 608-935-0398; Lafayette County Planning and Zoning Committee: 626 Main Street, Darlington, WI 53530, 608-776-3836 Lafayette Co. Map of Supervisor Districts: http://lafay.maps.arcgis.com/sharing/rest/content/items/2c8f689496e3499aaea639ffd2fac00d/data Lafayette County Supervisor contacts: https://www.lafayettecountywi.org/bos

29 Pattern LLC is considered a non-public utility or “merchant” developer. Proposals by merchant power plant developers do not have to prove need to meet power inadequacies or evaluate alternatives such as electric customer investment in home and local energy improvements. State laws also allow merchant power plant developers to take their proposals directly to the PSC for review and approval after obtaining 75% of the necessary land or “site control,” “Option Agreements” with landowners. For more on MISO site control policy, see .pdf p. 20, 21, Generation Interconnection Business Practices Manual BPM-015-r21 Effective Date: OCT-16-2019 https://drive.google.com/file/d/1UzsdEJQqiky-6rxIxIXTfbEtDjF0WKm4/view?usp=sharing