By Amanda Durish Cook
If politics makes strange bedfellows, then transmission policy can create equally unlikely adversaries when it cuts across the competing interests of different environmental groups inclined to agree on most issues.
An example is currently playing out in Wisconsin, where environmentalists, preservationists and renewable energy advocates are at odds with each other over the pending approval of a major MISO transmission line designed to carry wind energy to population centers. Some are seeking to advance the project as proposed, while others support substitute plans that include adoption of local renewable resources.
The $500 million, 345-kV Cardinal-Hickory Creek project would span about 120 miles from Dubuque County, Iowa, to Dane County, Wisc. Costs for the joint project involving American Transmission Co., ITC Midwest and Dairyland Power Cooperative would be shared on a load-ratio basis across ratepayers in MISO.
The Wisconsin Public Service Commission will hold six public hearings on the project in June. The commission has until Sept. 30 to review the application and decide on the necessity and placement of the line. The project also still faces a regulatory review in Iowa.
The project’s opponents and supporters in Wisconsin have been filing testimony and exhibits daily, and ATC is in the process of deposing witnesses in the case (5-CE-146).
The Cardinal-Hickory Creek line is the last of 17 MISO multi-value projects (MVPs) to enter the state regulatory approval process. MISO originally expected the project — designed to supplant more than a dozen other upgrades to constrained lower-voltage transmission lines — to be operational between 2018 and 2020.
“It’s unfortunate that it’s taken as long as it has to get into the regulatory process. … There are a lot of complicated pieces. But the longer this goes on, the more it’s preventing cost-effective resources from coming online,” Clean Grid Alliance Executive Director Beth Soholt said in an interview with RTO Insider.
The nonprofit is one of a handful of clean energy organizations backing the line’s construction. Its members include energy industry participants such as Avangrid Renewables, Invenergy, NextEra Energy and Vestas, as well as groups such as Union of Concerned Scientists, Iowa Environmental Council and National Farmers Union.
Soholt pointed out that when MISO identified the project as part of the 2011 MVP study process, it concluded the line would provide multiple benefits, including reliability, facilitating an economic market and helping meet public policy goals like state renewable portfolio standards.
“When you really look at ticking off all those pieces, Cardinal-Hickory Creek is the best option. This is the appropriate project,” Soholt said, adding that about 8,000 MW of existing and proposed wind generation needs the line to deliver energy and mitigate curtailments that are occurring today.
Soholt said that even if planners decide to “upset the apple cart” and forgo the project, the area would likely need a substitute that would contain several similarities to the existing proposal.
“For this particular purpose — to move the wind and solar megawatts that are being constructed — there is no other option, particular when you need to move electrons across time and space.”
She pointed out that MISO generator interconnection studies have long assumed Cardinal-Hickory Creek will be built. If the line isn’t built, interconnection customers may have to bear expensive transmission upgrade costs themselves, rendering some generation projects uneconomic and depriving ratepayers of the additional benefits the line will bring, Soholt warned.
“This line has been embedded into the MISO transmission planning and interconnection process for years,” she said. “Not constructing Cardinal-Hickory Creek will have a domino effect and cause restudies. Once you start that domino, it will get internalized into other projects, and some simply wouldn’t go forward,” Soholt said. She pointed to the RTO’s increasingly interconnected grid, shifting resource mix and more frequent emergency conditions as evidence of the need for additional transmission in the footprint.
“I don’t think I can say strongly enough … the need for transmission is only increasing, not decreasing.”
CGA, Fresh Energy and the Minnesota Center for Environmental Advocacy testified that the project will also reduce Wisconsin’s dependence on pivotal suppliers. Grid Strategies Vice President Michael Goggin pointed out that MISO territory in Wisconsin and Michigan’s Upper Peninsula had at least one pivotal supplier about 40% of the time in 2017.
A Distributed Future?
Opponents include the Driftless Area Land Conservancy and Wisconsin Wildlife Foundation, represented by Howard Learner of the Environmental Law and Policy Center. The two groups say a 627-page draft review of the line by the U.S. Department of Agriculture’s Rural Utilities Service neglected to consider alternatives that combine lower-voltage lines and investments in battery storage, solar generation and energy efficiency. The agency said each of those separate approaches was impractical, though it didn’t consider the alternatives as a package.
“There are out-of-state environmental groups supporting the line, but the in-state environmental and conservation groups in almost all cases are opposing a large transmission line that would cut a wide swath through the scenic Driftless Area,” Learner said in a phone interview with RTO Insider.
In an agricultural impact statement last month, the Wisconsin Department of Agriculture, Trade and Consumer Protection declined to recommend a specific route for the line, saying all proposed routes would “impact significant acres of farmland.”
U.S. Sen. Tammy Baldwin (D-Wisc.) recently joined opponents in criticizing the environmental review by the RUS, calling for a “meaningful analysis” of project alternatives and different routes for the line to cross the Mississippi River.
Wisconsin State Sen. Howard Marklein (R) also questioned the need for the project and asked the PSC for a clear and public justification for the project if the commission votes to approve it.
Learner said such a large line is unnecessary and takes issue that the project was never studied in isolation by MISO.
“When the transmission line was included in the MVP package in 2011, it wasn’t studied individually; it was studied as a portfolio with the other MVPs,” Lerner said. “Secondly, the world and electricity sector has obviously changed since 2011.”
In testimony provided by the Wisconsin PSC, electrical engineer Alexander Vedvik said that while the MVP portfolio “as a whole does in fact create benefits greater than the costs of the portfolio, it is entirely possible that one or more projects included in the MVP portfolio have benefits that are lower than the costs.” Using ATC’s models, the PSC found negative economic benefits were possible in several of the hypothetical cases it studied.
Despite changes over intervening years, MISO still expects benefits from the line. According to the RTO’s 2017 triennial review of MVPs, eastern Wisconsin would see a benefit-to-cost ratio of 1.9-2.9:1, while western Wisconsin would achieve a ratio of 3.2-4.8:1.
“Wind deployment in Iowa, Minnesota, North Dakota and South Dakota has greatly exceeded the already high level that the MVP projects were designed to serve. As a result, the benefits of and need for the Cardinal-Hickory Creek project are even greater than when MISO’s MVP planning process determined the project was needed and provided large net benefits,” Goggin said.
But Learner said at the time the MVP portfolio was approved, grid planners were forecasting a 1 to 1.5% annual growth. Since then, electricity sales and demand have flattened.
Learner also said the line was first studied when “solar energy was only a blip.” Last month, the Wisconsin PSC approved about 450 MW worth of solar development. If realized, the projects will lead to an almost five-fold increase in utility-scale solar generation in the state.
“That’s how fast solar is rapidly accelerating in Wisconsin,” Learner said. “To some degree, this case is about the old energy system versus the newer, cleaner distributed grid.”
No Need, Opponents Argue
Learner said the line will cost ratepayers a total $2 billion to $3 billion locked into rates over a 40-year revenue requirement period “at precisely the time” the industry is rapidly shifting. He likened the energy industry to the telecom industry at the point when cell service was rapidly superseding landlines.
“The world is changing. There’s no credible argument that there’s a need for imported power in Wisconsin to keep the lights on. I don’t think anybody is arguing that Wisconsin needs more imports in order to ensure reliability,” Learner said.
Energy companies in Iowa, Minnesota and the Dakotas are building more wind power, Learner argued, but utilities in those states are not shutting down existing fossil fuel plants, leading to excess generation.
Learner also said the line will support an “unspecified mix” of coal, wind, nuclear and gas-fired generation, not just wind.
The smaller line upgrades that Cardinal-Hickory Creek will render unnecessary, Learner argues, should be proposed on their own if they’re needed for local reliability. “If you need to fix local lines, fix local lines. … Don’t force people to pay billions for an entire transmission line,” he said.
But Soholt maintains that even a multifaceted alternative strategy isn’t a proper substitute for the project. While she foresees growth in distributed resources, she said a major transmission line compared to a distributed solution are “apples and oranges.”
“We can’t use energy efficiency, distributed resources or other local alternatives to move megawatts in time and space across the MISO footprint. There is just no cost-effective and timely substitute for the existing and future wind and solar projects relying on this line,” Soholt said.
“Bringing in distributed resources won’t solve the problem. It doesn’t deliver the megawatts that are being bottled up right now. It doesn’t facilitate the renewable megawatts that are in MISO’s interconnection queue right now,” Soholt said. “You need a grid to be able to move those resources to where they can be used. The idea that we can do this is without high-voltage transmission is not realistic. The grid is going to become more important as we get more distributed resources.”