Transmission above picnic bench at Memorial Park lookout

(Incomplete — a work in progress)

The Draft Environmental Impact Statement for Wisconsin’s Cardinal-Hickory Creek transmission line (southern part of MVP 5) was issued at the end of the month. I’m representing Jewell Jinkins Intervenors in this project, and it’s time to wade through the DEIS and see what’s what. What I learned first was that my clients, Jewell Jinkins Intervenors, hadn’t been listed in the DEIS. Then I checked the list on the 2nd Prehearing Conference Memorandum, nope, not there. So then I checked the 1st Prehearing Conference Memorandum, and not there either. Well, I was there, heard intervention granted to the “Group 3” intervenors (Tr. p. 37, l. 14-15).

And then I discover that the Agricultural Impact Statement, Appendix G of the DEIS, is not an AIS, but is a Summary, the Summary is only a draft, and although it says that an AIS “has” been completed, it’s not done. How are we supposed to comment on it, comments due April 14, when the real AIS is not planned to be filed until PSC testimony, April 26th? What will it get to get this timeline in order?

Part of environmental review is “alternatives,” both “system alternatives” and “route alternatives.” A big PR flurry early last week about the “SOO Green Renewable Rail” transmission project caught my attention. It’s claimed to be a “wind” transmission project, though it interconnects the MVP 4 line at the Killdeer substation, taking on whatever energy is there.

Killdeer is in the ITC (blue) part of MVP 4

Oh, but wait… the Cardinal-Hickory Creek is the southern part of MVP 5, with Badger Coulee the northern part.

MVP 3, 4, and 5 (Cardinal-Hickory Creek is “southern 5”

Remember the so-called “benefits” of the MVP 17 project portfolio? Here’s their latest claim in MISO’s MVP report:

Here’s their previous claim:

Wisconsin law requires consideration of “alternatives to an action.” Wis. Stat. 1.11(2)(c)(3). Where do alternatives come from? ” Scoping is an aid to help the commission identify all of a project’s relevant environmental concerns and reasonable alternatives. ” Wis. Code PSC 4.30(2). Then, the EIS must include, “[a]n evaluation of the reasonable alternatives to the proposed action and significant environmental consequences of the alternatives, including those alternatives that could avoid some or all of the proposed action’s adverse environmental effects and the alternative of taking no action. ” Wis. Code PSC 4.30(3)(c).

Now, take a look at the:

The “system alternatives” are all the “applicant’s system alternatives.” Really… Do a search. And the “applicant’s system alternatives” is very limited, artificially limited so that only the applicant’s project “works” and alternatives are rejected.

Are there some “system alternatives” that should be considered that weren’t? Ja, you betcha.

(… manana… this “block” format is royal PITA)

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