Author Archives: Rob Danielson

Second Information Request Submitted to Pattern LLC

July 6, 2022

Pattern Energy, LLC Corporate Headquarters
1088 Sansome St. San Francisco, CA 94111
UplandsWind@PatternEnergy.com , community@patternenergy.com info@patternenergy.com

Phillip Ross
Phillip.Ross@patternenergy.com

Allen Wynn
allen.wynn@patternenergy.com

Matt Dallas
Matt.Dallas@patternenergy.com

Dear Pattern Energy,

Please find, attached, questions and information requests that twenty-four co-signees are submitting concerning your intention to build a 600 MW wind power plant entitled Uplands Wind (the “Project”) in Iowa and Lafayette Counties, Wisconsin.

Co-signers ask that Pattern LLC provide written answers to as many of these questions as possible prior to Pattern’s July 12, 2022 Open House in Belmont so that follow-up questions can be asked and answered. Signers may also re-ask questions similar to these at the Meeting. For questions that Pattern cannot answer in time for the meeting, please provide a timeframe for when you will provide written answers to all of the co-signers whose addresses are provided. If there are questions that Pattern feels it cannot answer, please specify the reasons or explain when Pattern will be able to answer.

We thank you in advance for your attention to providing this very important and relevant information to them.

QUESTIONS & INFORMATION REQUESTS

I. Project affects on Real Estate Values

During the May 26, 2022, Zoom Virtual “Public Informational” Session (ZOOM meeting), Pattern representatives stated that the Project would not have a negative impact on local real estate values as demonstrated in studies that have been conducted. Please provide copies of all studies that pertain to property value impacts from all turbine sizes (in MW rating and total height) that Pattern is considering for the Project. Please do not include studies that utilize setback distances from occupied residencies that are greater than the minimum setback distance that Pattern will utilize for the Project.

II. Decommissioning and Disposal Practices

  1. Please provide the names and contact information for contractors that Pattern has previously used to recycle wind turbine blades.
  2. Please provide a description of the recycling practices used by these contractors that Pattern determined to be acceptable.
  3. Has Pattern previously committed to recycling turbine blades in an application to a state regulator before? Does Pattern intend to commit to recycling by including it as part of their decommissioning plan in their application to the Public Service Commission of Wisconsin (PSCW)?
  4. Please describe all Project infrastructure that Pattern will reserve the right to remain on-site above and below ground, after decommissioning of the Project, if the Project is approved and decommissioned? If this information is not available for the Project, please provide sections from existing decommissioning plans for at least three Pattern wind projects describing the rights Pattern retains to leave infrastructure on-site above and below the ground. Provide this information at your earliest convenience.
  5. Please specify if and how Pattern funds are set aside for decommissioning? Please provide examples of decommissioning plans for 3 existing projects, owned and operated by Pattern.

III. Health Effects from Wind Turbines

  1. At the ZOOM meeting, a Pattern representative stated there was no evidence of wind turbines causing negative health impacts. Please provide all available health impact studies reaching this conclusion for all possible setback distances and for all possible wind turbine sizes that Pattern might select for the Project. Please provide these studies at your earliest convenience before the Project application is submitted to PSCW.
  2. Please provide existing audible and infra-sound field analysis that Pattern has conducted or commissioned for existing wind facilities having the same MW rating, turbine heights and setback distances that Pattern could possibly install/apply for the Project
  3. Please describe the accommodations would Pattern make if residents or landowners become ill from living in proximity to the Project?
  4. Has Pattern ever monetarily compensated a resident or landowner that has become ill from living in proximity to a project they owned and operated?

IV. Wind Turbine Siting and Related Information

  1. At your ZOOM meeting, Pattern was asked for a timetable for when exact locations for wind turbines would be presented to affected Townships and to all participating and non-participating landowners for review and comment. The answers failed to provide the requested timetables. Please provide a schedule of when presentations about Pattern’s preferences for exact turbine locations would be made to each affected township, village, city and county to enable feedback and recommendations from local governments, participating and non-participating landowners and the public prior to Pattern making application to the PSCW.
  2. Please inform elected officials and the public of when the range of turbine sizes in total heights and in MW ratings will be presented to each affected township, village, city and county.
  3. For each possible turbine in the range presented (4b above), please provide the absolute minimum setback distances from occupied residences that Pattern would abide by.
  4. For each setback distance (in 4c above), please provide the state law wording or other reasoning used in determining the selected distance.
  5. For each possible turbine in the range presented (4b above), please provide the estimated dimensions of the required foundation structures.

V. Lease Agreements

  1. For participating Properties, please describe the types of controls that the lease agreement allows Pattern to exercise over the entire property.
  2. Is there language in the Pattern’s lease agreements for Uplands Wind that prohibits the landowner from sharing information with others regarding the lease agreement or other aspects of the project? Please include the language used in the lease agreement that prohibits the landowner from sharing Project information with others.
  3. What information, specifically, is the landowner prohibited from sharing?
  4. If for any reason, Uplands Wind is not built, will Pattern retain the lease agreements or will they nullify the lease agreements, releasing landowners from the leases? For prior projects has Pattern ever retained lease agreements for a project they have not built and if so, what was the final disposition of the lease agreements?
  5. If Pattern retains the lease agreements, could they sell them to another developer?

VI. Community Concerns

  1. Does Pattern have a plan to ensure that Med Flight helicopters can reach residents within or in proximity to the Project? Please provide documentation of Pattern’s Med Flight Plan that would be included with their application for the Project. If a Med Flight Plan for the Project is not available yet, please provide one from an existing project. If Pattern does not ensure that Med Flight helicopters can reach residents in proximity to the Project, please explain the reason for this.
  2. Is money set aside within the Project budget for local road repairs?
  3. Before the application is submitted does Pattern plan to have an in-person public information meeting with a presentation by Pattern where follow-up questions can be asked and answered before the entire audience in attendance?
  4. During the Zoom meeting, Pattern representatives used the phrase “prior to permitting” in answering some questions relating to when specific information would be available. Does “prior to permitting” mean: prior to pre-application notification; prior to application to the PSCW; prior to the end of the PSCW CPCN proceeding, or; prior to construction (after the PSCW CPCN proceeding has ended)?

Sincerely,

Marie Baker, 5318 Weaver Rd. Dodgeville, WI 53533
Kim and Roberta Barham, 275 County Road K, Blanchardville, WI 53516
Deirdre Birmingham and John Biondi, 7258 Kelly Rd. Mineral Point, WI 53565
Michelle Citron, 5175 Country Rd ZZ, Dodgeville WI 53533
Jan Day, 148 Commerce Street, Rewey, WI 53580
Kerry McDermott, 776 County Rd. J, Mineral Point, WI 53565
Rob Danielson, S3897 Plum Run Road, La Farge, WI 54639
Steve Ferrell & Sheila Fry, N2221 Asmus Road, Monroe, WI 53566
Carrie Honerbaum, 523 Blacks Grove Rd., Dodgeville, WI 53533
Jackie and John Howard, 21755 Search Rd., Blanchardville, WI 53516
Ronald and Ronna Heftman, 3648 County Road M, Dodgeville, WI 52533
Lillie Jewell, 3362 County Road B, Dodgeville, WI 53533
Marcia Jewell, 3362 County Rd B, Dodgeville, WI 53533 (Linden Township)
Chris Klopp, 4283 County Road P, Cross Plains, WI 53528
Tom and Judith Kordus, 2025 Survey Rd. Mineral Point, WI 53565
Ron and Jean Luecke, 521 Blacks Grove Rd., Dodgeville, WI 53533
Ed Michalski and Mary Michalski, 17900 O’Neil Rd., Mineral Point, WI 53565
Matthew Michalski, Bik Wong, Milo Wong & Lily Wong,17950 O’Neil Rd., Mineral Point, WI 53565
Jason Neton, W5725 County Road H, New Glarus, WI 53574
Allen Pincus, 7836 Lakeview Road, Barneveld, WI 53507
Cyra Polizzi & Richard Paro, 1317 Chandler St., Madison, WI 53715
Frank and Barbara Polizzi, 5381 State Road 39, Mineral Point, WI 53565
George A. Schwarzmann Jr., 21791 Sand Hill Rd, Platteville WI 53818
Lila Zastrow & Dave Hendrickson, N5399 French Rd. Seymour, WI 54165-8352

Wisconsin Farmer: “Biggest Regret I’ve Ever Experienced”

In 2011, Wisconsin farmer, Gary Steinich of Cambria Wisconsin, sent this letter to Better Plan, Wisconsin, asking that it be published.  It is re-printed here with appreciation to both Mr. Steinich and Better Plan, Wisconsin.

“This is an open letter to Wisconsin farmers who are considering signing a wind lease to host turbines on your land. Before you sign, I’d like to tell you about what happened to our family farm after we signed a contract with a wind developer.

In 2002, a wind developer approached my father about signing a lease agreement to place a MET (meteorological) tower on our land. My father was in his 70’s at the time. The developer did a good job of befriending him and gaining his trust.

He assured my father that the project wasn’t a done deal and was a long way off. They first had to put up the MET tower to measure the wind for awhile.

He told my father that if the project went forward there would be plenty of time to decide if we wanted to host turbines on our farm. There would be lots of details to work out and paperwork to sign well before the turbines would be built. The developer said my father could decide later on if he wanted to stay in the contract.

In 2003 the developer contacted us again. This time he wanted us to sign a contract to host turbines on our land. We were unsure about it, so we visited the closest wind project we knew of at the time. It was in Montfort, WI.

The Montfort project consists of 20 turbines that are about 300 feet tall and arranged in a straight line, taking up very little farmland with the turbine bases and access roads. The landowners seemed very satisfied with the turbines. But we were still unsure about making the commitment.

We were soon contacted again by the developer, and we told him we were undecided. Then he really started to put pressure on us to sign.

This was in March of 2004, a time of $1.60 corn and $1200 an acre land. It seemed worth it have to work around a couple of turbines for the extra cash. We were told the turbines would be in a straight line and only take up a little bit of land like the ones in Monfort.

And we were also told that we were the ones holding up the project. That all of our neighbors had signed, and we were the last hold-outs. It persuaded us.

What we didn’t know then was the developer was not being truthful. We were not the “last hold-out” at all. In later discussions with our neighbors we found out that in fact we were the very first farmers to sign up. I have since found out this kind of falsehood is a common tactic of wind developers.

My father read through the contract. He said he thought it was okay. I briefly skimmed through it, found the language confusing, but trusted my father’s judgment. We didn’t hire a lawyer to read it through with us. We didn’t feel the need to. The developer had explained what was in it.

The wind contract and easement on our farm was for 20 years. By then my dad was 75. He figured time was against him for dealing with this contract in the future so we agreed I should sign it. A few months later, my father died suddenly on Father’s Day, June 20th, 2004

After that, we didn’t hear a whole lot about the wind farm for a couple years. There was talk that the project was dead. And then in 2007 we were told the developer sold the rights to the project. A Wisconsin utility bought it.

After that everything changed. The contract I signed had an option that allowed it to be extended for an additional 10 years. The utility used it.

The turbines planned for the project wouldn’t be like the ones in Monfort. They were going to be much larger, 400 feet tall. And there were going to be 90 of them.

They weren’t going to be in a straight row. They’d be sited in the spots the developer felt were best for his needs, including in middle of fields, with access roads sometimes cutting diagonally across good farm land. Landowners could have an opinion about turbine placement but they would not have final say as to where the turbines and access roads would be placed. It was all in the contract.

Nothing was the way we thought it was going to be. We didn’t know how much land would be taken out of production by the access roads alone. And we didn’t understand how much the wind company could do to our land because of what was in the contract..

In 2008 I had the first of many disputes with the utility, and soon realized that according to the contract I had little to no say about anything. This became painfully clear to me once the actual construction phase began in 2010 and the trucks and equipment came to our farm and started tearing up the field.

In October of 2010 a representative of the utility contacted me to ask if a pile of soil could be removed from my farm. It was near the base of one of the turbines they were putting on my land. I said no, that no soil is to be removed from my farm.

The rep said that the pile was actually my neighbor’s soil, that the company was storing it on my land with plans to move it to another property.

Shortly afterwards I noticed the pile of subsoil was gone.

In November of 2011 I saw several trucks loading up a second pile of soil on my land and watched them exiting down the road. I followed them and then called the Columbia County Sheriff. Reps from the company were called out. I wanted my soil back.

A few days later the rep admitted they couldn’t give it back to me because my soil was gone. It had been taken and already dispersed on someone else’s land. I was offered 32 truck loads of soil from a stockpile they had. I was not guaranteed that the soil would be of the same quality and composition as the truck loads of soil they took from my farm.

I was informed by the lawyer for the utility that I had until April 30, 2011 to decide to take the soil. There would be no other offer. Take it or leave it.

I contacted the Public Service Commission for help. The PSC approved the terms of project and I believed the utility was violating those terms. The PSC responded by telling me they could do nothing because the issue involved a private contract between myself and the utility.

They told me my only option was to sue the utility.

My father and I both worked those fields. Watching the way they’ve been ripped apart would sicken any farmer. But what farmer has the time and money it would take to sue a Wisconsin utility?

By signing that contract I signed away the control of the family farm, and it’s the biggest regret I have ever experienced and will ever experience. I have only myself to blame for not paying close enough attention to what I was signing.

We had a peaceful community here before the developer showed up, but no more. Now it is neighbor against neighbor, family members not speaking to one another and there is no ease in conversation like in the old days. Everyone is afraid to talk for fear the subject of the wind turbines will come up. The kind of life we enjoyed in our community is gone forever.

I spend a lot of sleepless nights wishing I could turn back the clock and apply what I’ve learned from this experience. Now corn and bean prices are up. The money from the turbines doesn’t balance out our crop loss from land taken out of production. The kind of life we enjoyed on our family farm is gone forever too.

I would not sign that contract today. As I write this, the utility is putting up the towers all around us. In a few months the turbines will be turned on and we’ll have noise and shadow flicker to deal with. If I have trouble with these things, too bad. I’ve signed away my right to complain. These are some of the many problems I knew nothing about when I signed onto the project.

If you are considering signing a wind lease, take the contract to a lawyer. Go over every detail. Find out exactly what can happen to your fields, find out all the developer will be allowed to do to your land. Go through that contract completely, and think hard before make your decision.

I can tell you from first-hand experience, once you sign that contract, you will not have a chance to turn back.

·
Update:  June 5, 2011, Gary Steinich contacted Better Plan to let us know he and the utility have reached an agreement on his soil restoration.

Comments:

  1. Comment by Anonymous on 08/13/2011 at 6:17 pmIt’s reassuring to know there are still people who are brave enough to speak up against.big business. I grew up in the Cambria area and understand the strength of the community. It is unfortunate this project has affected life-long friendships and local business opportunities. Thank you for sharing your story to enlighten others.
  2. Comment by Anonymous on 12/06/2011 at 7:58 amI unfortunately am a non participating neighbor to the wind turbines. So, although my neighbors are making money for the disruption to their land and life, I am not! We have already noticed TV and radio resception problems. We have noticed the noise from the turbines during the warm months. Now that the windows are closed up, that is not an issue. Family members have been woken in the mornings from the shadow flicker.I too have watched the turbines and, between the blades and the shadow movements, it made me feel sick. I don’t know what the long-term health effects will be, and don’t like that I am, against my will, being forced to find out.My biggest concern is the value of our home, now that we have turbines all around our home. What loss will be have when we try to sell our home?Editor’s reply. Real estate appraisers generally estimate the property value loss is anywhere from 20 to 40 percent. There are numerous articles on our website by certified real estate appraisers (by Michael McCann, in particular); I suggest you read them.

38 UNANSWERED QUESTIONS ABOUT UPLANDS WIND

Above Image: View from a 4.6 MW Wind Turbine. Pattern LLC has announced the possibility of larger turbines for their proposed 600 MW Uplands wind power plant inIowa and Lafayette Counties, Wisconsin.

Update: As of Novmber 21, 2021, On November 4, rather than respond to the 38, precisely-stated questions and documentation requests, Pattern LLC sent a letter to one of the questioners with general information about the proposal. On November 17, the recipient responded to Pattern asking the company to please send the letter to the other 73 questioning co-signers whose addresses they possess. ACTIONS: Each Co-signer of the orginal request has the option to consider emailing Pattern asking the international power plant builder to answer the provided questions, as promised, and to send all correspondence on the matter, personally, to them.Other persons can email and join the request for answers and ask the company to add to thieir name and addresss to the list of the original 74 requesters. Feel free to cc info@no-uplands.com in your correspondence.

Update: As of October 25, 2021, despite their promises, International, wind power plant builder, Pattern LLC, has not supplied a single answer to the questions posed by 74 landowners. The time has come to contact your local and state elected officials and ask them to help the residents Iowa and Lafayette counties in Wisconsin get accountability from Pattern LLC!

On August 13, 2021, following Pattern LLC‘s July 29, Public Information Meeting in Belmont, WI concerning the 600 MW Uplands wind power plant, the company was presented with an extensive set of questions co-signed by more than 50 potentially affected residents in Iowa and Lafayette Counties, Wisconsin and 24 supporting citizens across the Midwest.

All private individuals, businesses and governmental units have the option to consider following-up these requests with questions of their own. For record keeping purposes. it is best to attach a signed letter via email to these addresses: UplandsWind@PatternEnergy.com Matt.Dallas@patternenergy.com community@patternenergy.com info@patternenergy.com Pattern Energy Corporate Headquarters 1088 Sansome Street San Francisco, CA 94111


Its very possible reading through the 38 questions submitted will prompt some ideas about information you are interested in:

1. Does Pattern agree that if 5.6 MW turbines were installed in Uplands, it would likely be the first time or one of the first times that such technology has been installed, on land, in the US?

2. Of the various types of studies (health, economic, property value, etc.) that Pattern plans to include or cite in its application for Uplands, please name/identify all that specifically pertain to 3.0 MW or larger turbines and apply to a setback of 1250′ or less.

3. It was stated by Pattern personnel at the Public Information Meeting that Pattern’s land lease contract with property owners requires Pattern to individually meet with all turbine-hosting property owners to go over turbine and other siting details before Pattern’s plan becomes final and that this meeting includes opportunity for the landowner to make suggestions. Please provide text from the contract or other document where these requirements are described.

4. Please describe all, pre-application meetings that Pattern will conduct with property owners living adjacent to turbine-hosting property owners to go over turbine and other siting details before Pattern’s plan becomes final and explain whether the meeting includes opportunity for the landowner to make suggestions

5. Please provide an estimated date for Pattern publicizing its final turbine size selections (MW size) and specify whether this date would be before Pattern makes it application to the Wisconsin Public Service Commission.

6. Please indicate whether Pattern has ever been involved with a law suit concerning these physical impacts on humans:

6A) Alleged audible noise level from one or more Pattern turbines;

6B) Alleged shadow flicker from one or more Pattern turbines;

6C) Alleged nausea, anxiety, sleep loss, disorientation or headaches from one or
more Pattern wind turbines; and,

6D) A combination of these impacts from one or more Pattern wind turbines.

7. If law suits have been received by Pattern, please provide the associated MW size and setback distance conditions for each of the lawsuit allegation types, above.

8. Does Pattern plan to provide counties and local governments evidence from other Pattern Projects of a 100 MW or larger wind power plant resulting in net gain in local government revenue after factoring in payments per megawatt, tax revenue impacts, property valuation changes and other expenses factors over an operation period of at least 3 years? If yes, please explain whether the evidence will be submitted before an application for Uplands is submitted allowing for public input. If no, please explain why Pattern will not be providing this evidence.

9. Pattern’s FAQ estimates payments to counties and local governments only over the first 30 years and describes them, as “stable, long-term funding.” Please explain why 30 years is considered long term when contracts with landowners are longer. Please explain why funds at the discretion of state lawmakers are described as, “stable.”

10. Does Pattern plan to provide local economies potentially affected by Uplands a comprehensive economic study of a completed Pattern wind power plant project 300 MW or larger? If so, please indicate whether the study will address these factors:

10A. Tax revenue impacts for all directly impacted municipalities by comparing historic (15 years prior) and after turbine operation annual property tax collection totals.

10B. Impacts on new business and residential development by comparing historic (15 years prior) and after turbine operation annual tax base additions by type, number and assessed values for all directly impacted municipalities.

10C. Impacts on real estate activity and property values by comparing historic (15 years prior) and after turbine operation sales including a list of annual property transactions, the sale value of each transaction and description of the property including its tax number. A comparison of this data to comparable, municipal government units beyond the view scape of the turbine project and other, wind installations.

10 D. Potential Impacts on population and average income levels by comparing historic (20 years prior) and after turbine operation census data.

11. How many acres, per MW, on average, does Pattern expect would be removed from local taxable rolls for the Uplands project?

12. The Pattern FAQ states, “Pattern Energy began developing the project in 2020.” Please provide the year and month that Pattern or a subcontractor for Pattern acquired its first signature on a lease option for Uplands.

13. Please provide the dates and documentation for Pattern’s official notice of intent to build a power plant to Iowa & Lafayette Counties.

14. Do other states require Pattern to formally notify government officials of intent to build a large wind power plant before seeking signatures from private landowners?

15. Does Pattern encourage Iowa or Lafayette Counties to update their existing Wind Siting Ordinances to include all state of Wisconsin regulations under PSC 128?

16. Pattern’s FAQ states that during construction, there will be additional traffic and heavy equipment in the area including bulldozers, graders, trenching machines, concrete trucks, flatbed trucks, and large cranes. Does Pattern plan to provide the local governments potentially affected by Uplands, contact information for elected officials at a minimum of five governmental units to discuss the construction period activity of a Pattern wind power plant 300 MW or larger? For 100 MW or larger?

17. Please explain whether Pattern’s estimated annual payments to landowners have changed more than 15% and describe the reasons for the changes.

18. Is there a protection in the Uplands landowner contracts that prevents the new owner from affecting changes in contract terms or acquiring additional rights? If so, please provide the section in the contract where these protections exist.

19. Stated in years after initial operation, how soon could a participating property owner discontinue hosting a turbine on their property?

20. If Uplands is not built, what are Pattern’s plans for the land contracts? Would Pattern keep them? Sell them to other developers? A combination of these?

21. Has Pattern ever transferred control of contracts they have gotten from property owners to other utilities?

22. Please provide a list of Pattern wind projects by name and location that are operating in in a ridge-valley landscape where ridges are primarily used for corn, bean and hay cropland and the valleys are heavily forested.

23. Please provide a list of Pattern wind projects by name and location that are operating on Karst geology.

24. Please provide written documentation describing effective preventative measures that Pattern has taken in the past to minimize bird and bat kills.

25. Does Pattern plan to provide comprehensive, third party analysis of the estimated bird and bat killings from Uplands in its application materials to the Wisconsin Public Service Commission? If not, please explain why.

26. Does Pattern plan to provide before and after impact studies on livestock from 300 MW or larger wind systems that Pattern has already built? If not, please explain why.

27. Does Pattern plan to provide potentially impacted residents before and after impact studies of radio signal interference from 300 MW or larger wind systems that Pattern has already built?

28. Does Pattern plan to provide residents before and after impact studies of aerial crop treatment interference from 300 MW or larger wind systems that Pattern has already built?

29. Would Pattern consider proposing a privately owned transmission line in Wisconsin?

30. Will Pattern be providing a list of necessary added transmission and distribution lines with locations to the public for review and comment upon before submitting the Uplands application to the Wisconsin Public Service Commission? Please provide all applicable MISO Project ID numbers.

31. Please provide accounting over five of more years from two, existing Pattern wind power plants showing the percentage and values of total project related expenses that went to local businesses and the percentage and values disbursed to persons businesses residing out of state.

32. How many total wind turbines has Pattern decommissioned with land restored to original use in the United States? Please provide the complete written, decommissioning plans for these turbines.

33. Please explain whether it is Pattern’s intention to return impacted land to its full, former use after the wind turbines are removed? If so, please provide a contract section where this assurance is highlighted. How does Pattern assure that the quality of the restored topsoil is as good or better than before?

34. Pattern’s FAQ states that Wisconsin ratepayers would likely be isolated from paying costs associated with Uplands. Please provide written materials from at least two, prior Pattern wind power plants demonstrating the impacts on state ratepayers over the first 6 years of operation and explain how the same conditions would be applicable to Uplands.

35. Pattern’s FAQ states that Uplands could lower electricity rates. Please provide documentation showing how Pattern wind power plants reduced retail customer electricity rates and explain how similar conditions would be applicable to Uplands

36. Has Pattern been in contact with Wisconsin utilities regarding possible power purchase from Uplands? Please provide a list of these entities.

37. Would Pattern seek Federal Investment Tax Credits for Uplands? Please provide documentation showing how these credits impacted the costs of two, existing Pattern wind power plants over the first 3-7 years of operation.

38. Would Pattern seek Federal Production Tax Credits for Uplands? Please provide documentation showing how these credits impacted the costs of two, existing Pattern wind power plants over the first 5 years of operation.

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