1.0. Sierra Club
Position on Construction of the Proposed Co-generation Plant
These comments are a
reaction to the DEIS for the proposed West Campus Cogeneration Facility (WCCF),
PSC docket number 05-CE-121. At this time, the Sierra Club is not prepared to
either oppose or support construction of the proposed cogeneration plant by
MG&E on the UW campus. We believe there are many unanswered questions and
we intend to continue seeking answers to those questions beyond this Friday's
deadline (April 25, 2003) for comments on the draft environmental impact
statement (DEIS).
This DEIS falls short
in its obligation to take a full and fair look at several viable alternatives
and therefore does not provide the public or planners with enough information
to form a reasonable conclusion about the project. Several areas raise
particular concern. These include the following:
·
An inadequate review of potential capacity savings from increased efficiency
and demand-side programs.
·
An insufficient examination of public health, air pollution and water quantity
issues, including the following:
- Air impacts of the
plant, especially in light of the fact that the plant is additional, not
replacement capacity.
- Noise impacts of
the plant, in particular as accumulated with other recent construction in the
west campus area of the University of Wisconsin-Madison (UW) campus.
- Water impacts,
particularly drawdown of water in the watershed and incomplete analysis of
mitigation measures.
- Gift of land by a
public institution to a private utility and thus loss of open space.
We suggest that the
WCCF plan be reconsidered to ensure that legal, social and environmental
commitments are fulfilled and effective mitigation measures are in place if the
project proceeds.
It is apparent that
increasing demand will strain Madison’s electrical capacity in the near
future. New University buildings will
require additional steam and chilled water, and commercial and residential
growth in and around Madison will require more electricity. Generally speaking,
natural gas cogeneration plants are preferable to new coal and nuclear power
plants, but significantly less desirable than increased efficiency and
renewable energy sources such as wind, biomass or solar. There remain
considerable doubts whether the plant as proposed to be constructed and
operated meets the definition of a true cogeneration plant. See section 6.0,
below.
2.0. Timeline of the
Decision-Making Process
The timeline for
public comment has hampered a full public review of the proposed project. While
the project itself was proposed in mid-2002, heightened public scrutiny of the
proposal has coincided with the 45-day period for public comments on the DEIS.
This has not provided adequate opportunity to review the proposal.
It is a compliment to
MG&E, however, to note that the decision-making process is a "moving
target" precisely because MG&E has been responsive to public concerns
and issues which need to be resolved before the plant is constructed.
However, those issues
do need to be resolved. In addition, as a general comment, we believe that
promises made by MG&E and the University should be incorporated into
permits issued to construct the plant, if those permits are issued, as legally
binding conditions. While University officials have mentioned making it a
priority to address citizen concerns about the plant, we believe that there is
no substitute for legally binding conditions to require the completion of all
promises made in an effort to secure authority to construct the plant.
3.0. Impacts and
Mitigation Efforts
There is no dispute
that the plant will have impacts on its surrounding neighbors. While it may not
be one-of-a-kind, it is unique in its setting. It is an industrial facility
proposed to be placed adjacent to a neighborhood that is predominantly
residential, on the edge of a university campus, near a major urban lake. Its
urban setting calls into question how the normal operation of local zoning
powers would affect such a proposal. Because power generation is regulated at
the statewide level, typical local zoning powers are not available to residents
of the community. Therefore, the regulating agencies need to proceed with
extreme caution to fill this regulatory vacuum. It would be wrong to review the
proposal solely in terms of the operational efficiencies of the plant and the
need for steam power and electrical power.
Therefore, in
addition to reviewing the plant in the context of its setting, the regulating
bodies should be receptive to relatively innovative mitigation measures as
well. The imposition of this plant on its neighbors by MG&E and the
University is a unique sacrifice to impose. Those two entities should be
willing to make sacrifices of their own, and change their ways of doing
business, if they wish to win approval for the plant.
4.0. Impacts of the
Proposed Plant
As identified in the
DEIS, the proposed plant has a number of impacts on the surrounding community:
·
Air impacts
·
Water consumption and water quality
·
Noise
·
Gift of land by a public institution to a private utility and thus loss of open
space.
·
Location of an industrial facility adjacent to a residential neighborhood.
4.1. Air Impacts
This
EIS appears to be a standard PSC document for evaluating any proposed,
typically rural, energy plant project.
However, this particular project cannot be adequately evaluated using
this standard format. The location of
this project is not a standard rural location.
This is a densely populated urban area. Moreover, this is a densely
populated urban area that is already significantly impacted with unhealthy
levels of air pollutants. This urban
area also is home to more than 2,150 public school children who suffer from
asthma, and to many other private school and pre-school children, as well as
adults, who also suffer from this - or related - chronic respiratory
conditions.
For
many of these young people and adults, depending upon where they live and other
factors, existing levels of pollutants pose an unacceptable and unwarranted
health risk. Yet, this document fails
entirely to disclose these relevant facts.
This failure to disclose this information makes this document inadequate
for its legally mandated purpose under ch. NR 150, Wis. Adm. Code. The DEIS
therefore fails to inform decision-makers and affected citizens of information
that is essential to both regulatory and personal decisions.
The
importance of air pollution on area resident health is demonstrated by medical
epidemiological studies and histological or tissue studies. Some point to
pollutants in the origin of asthma, and scores conclude pollutants cause lung
tissue inflammation that leads to or worsens asthma episodes. Note that the
precautionary principle calls for caution about taking a relatively
irreversible action (here, construction of the proposed plant) in the face of
strong evidence or correlation. It is clear from these studies that relying
only on EPA air quality standards does not adequately protect human health –
especially children/s health.
To
this existing unhealthy level of pollutants in the air our children breathe,
the State of Wisconsin and MGE propose to add still more pollutants.
Even
citizens of Las Vegas, Nevada, a place not typically viewed as a haven for the
health-conscious, are recognizing that people must be better protected from air
pollutants. (They oppose a major commuter highway expansion, due to concerns
over health impacts of traffic pollutants.)
4.1.1. Alternatives to air emissions analysis
The
proposed strategy appears to have been to do only the bare minimum to meet air
quality standards. A model should be performed analyzing the plant with
additional emissions controls or a stack another 25 to 50 feet in height to see
what impact that has.
This
is also a major reason why the most recent air model for the power plant
exceeded the available PM10 pollution increment - there are already too many
cars putting out too much pollution to enable UW to easily site even a
relatively "clean" power plant in the University Avenue corridor.
For
starters, an air study should compare Madison air quality to California
standards and proposals.
Fine
particulates “are able to evade the body’s natural defenses and migrate deep
into the lungs,” where they impair lung function and exacerbate a variety of
respiratory diseases. They can drift
thousands of kilometers and their ability to absorb and reradiate heat from the
sun makes them a contributor to 15% to 30% of the planet’s total global climate
change effect. A National Institute for Environmental Health Sciences study
found that “the number of deaths from lung cancer increases 8% for every
10ug/m3 PM 2.5.”
This
project would add .06 ug/m3 to the existing average annual PM 2.5 pollutant
levels (13.18 ug/m3), yielding a combined annual average of 13.24 ug/m3, when
measured at the Franklin Avenue Madison Water Utility District pump station.
This new annual average concentration would still be below the federal average
annual standard. However, it exceeds the health hazard levels (based on traffic
volumes) identified in numerous studies, and also exceeds the new California
average annual standard for fine particulates (12 ug/m3).
The
proposed project would add .19 ug/m3 to the existing 24-hour concentration
(34.74 ug/m3), yielding a new 24-hour
concentration of 35.93 ug/m3. While
this is within the EPA standard of 65 ug/m3, this exceeds the recommended
24-hour fine particulate level (25 ug/m3) under consideration in California.
Canadian
researchers have proposed a more protective ozone standard of 50 ppb for use in
that nation, compared to the 80 ppb standard in the U.S. The U.S. standard is set in a manner that
does not provide 100% protection to 100% of the exposed population. The Canadian proposed standard is based in part
upon the results of health studies published too late for consideration prior
to the adoption of the EPA standard (1997).
Arguably,
this Canadian limit is the value that should be used when determining existing
impacts and evaluating additional impacts of the proposed project on human
health in the surrounding residential area, even though it is not currently an
enforceable standard in Wisconsin. Ozone levels in the vicinity of the proposed
project are currently approaching the existing EPA standard and are
considerably above the proposed Canadian standard. Therefore, based on health
impact studies, it is reasonable to expect that residents of Madison and
perhaps other areas of the Dane County Metropolitan Area are currently
experiencing some impairment of lung function and some relatively small degree
of long term respiratory impairment. It also appears from monitoring data that
Madison ozone precursor emissions may be significantly elevating ozone
concentrations in Dodge County and perhaps other counties downwind.
4.1.2. Impacts of Air
Pollution on Nearby Residents
Thousands of children,
families and students live near the proposed plant. Therefore a great area of concern in the DEIS is the discussion
of air pollution. The Clean Air Act
requires several emissions to be regulated as “criteria pollutants.” As described in the DEIS, the WCCF site is
in attainment for all six of these pollutants under National Ambient Air
Quality Standards (NAAQS).
However, the worry
lies more with a pollutant that is not yet completely understood. This
pollutant is particulate matter or soot that is smaller than 2.5 microns (PM2.5).
The EPA is still determining how best to implement a plan to control PM2.5,
but in the meantime they have set standards to 15 ug/m3 for an
annual average and 65 ug/m3 as a maximum daily average.
The current
background level of PM2.5 at the Franklin Street monitoring station
is 35 ug/m3 for maximum daily average and 13.2 ug/m3 for
average annual level. The additional PM2.5
that is forecasted to be produced is 15.27 ug/m3 for the daily
maximum average and 1.16 ug/m3 in the annual average. This brings the maximum daily average to 35
ug/m3 and the annual average to 14.36 ug/m3, only
slightly below the set national standards.
Considering this
fact, we suggest that the emissions from this project be offset by clean-diesel
city buses and other new government vehicles and a commuter train system,
funded partially by MG&E and the state.
4.2.
Water Impacts
4.2.1.
Introduction
The proposed plant
would consume a vast amount of water - some 3.3 million gallons per day. At
present, MG&E indicates that the plan would be to remove water from Lake
Mendota and to restore it downstream in the Yahara River Watershed. The water
restored to the watershed would come from groundwater removed by the use of a
drinking water well, which is proposed to be abandoned.
It remains to be seen
whether or not this solution resolves the issue of water drawdown by the plant.
At a public meeting
on April 21, it was noted that the details of the water drawdown mitigation
plans are not in the DEIS, because MG&E has been crafting solutions
throughout the process. While it is admirable that MG&E continues to seek
to solve the problems with the plant, MG&E should not be allowed the
courtesy of answering unanswered questions without full review by the public. A
supplemental environmental impact statement should be issued providing this and
any other information which has arisen since publication of the DEIS or arises
in the future.
Part of the reason
the plant would consume so much water is that it is not a true cogeneration
plant. Please see section 6.0 below for our analysis of this aspect of the
proposal.
The 3 million gallons
per day quantity of water that will be required by the proposed project in the
summer season will have serious negative impacts on the Yahara River as
outlined in the DEIS. Consequently the
PSC has examined several mitigation alternatives for augmenting water in the
Yahara River during low seasonal flows.
The list of participants in the discussions of alternatives as
well as the different mitigation options weighed show that the PSC did not
fulfill their duty to take a hard look at the facts. The list of participants includes only utilities and government
agencies and clearly lacks input from citizen and conservation groups and
independent experts.
We would suggest that
the mitigation measures be re-examined to include a variety of reliable and
feasible options.
The “most likely
suitable mitigation” would require flow augmentation from MWU’s Well Number 5
in combination with storm water infiltration to replace water from Dane County’s
deep sandstone aquifer. The DEIS
reports that preliminary modeling and monitoring suggest that pumping Well #5
for seasonal flow augmentation would have no affect on near surface water
features. It continues by explaining
that, “while the additional withdrawal from the deep aquifer would have
ultimate impacts on surface water features elsewhere, it is possible to offset
these impacts by providing storm water infiltration at other sites.”[1]
Although, we approve
of the practice of improving storm water infiltration across the Madison area,
we do not believe that it can be solely used as an appropriate mitigation
measure in this case. It is unclear
from the report how much infiltration will be available in the near future and
how it can be implemented as a direct mitigation measure for the WCCF to
provide adequate water throughout the area at low flow.
In addition to
relying upon infiltration, we believe that that an upland water storage system
in the Lake Mendota watershed should be examined.
Therefore, we would
recommend that MG&E and the PSC look at projects that can guarantee water
availability, instead of relying upon plans with uncertain results. We would also suggest that a 3rd
party, such as the Dane County Lakes and Watershed Commission, evaluate and
manage the mitigation project.
4.3. Noise Impacts
The plant will have
an additive noise impact on the surrounding community. Reviewed in isolation,
the plant might not be considered to have a significant impact in terms of
noise. However, the applicant should be required to meet strict noise
thresholds as a permit condition for winning approval to construct the plant.
In addition,
neighboring residents have stated that buildings recently constructed by the UW
on the western end of the campus have had detrimental noise impacts. The new
Pharmacy Building and the Waisman Building have been cited. The cumulative
noise impacts of the University's operations should be part of the
environmental review process for this proposal. The University should be required
to mitigate the impacts of the recently constructed buildings before being permitted to construct the
cogeneration plant.
4.4. Gift of Land by
a Public Institution to a Private Utility and thus Loss of Open Space
The public is being
asked to pay for the plant in several ways. One of the ways is that the land
the plant would sit on is currently publicly owned, by the State of Wisconsin
in the form of the University of Wisconsin. This gift of land is a unique
transfer. The public should receive some kind of benefit in return.
The west end of the
UW campus has been the site of a building boom in recent years. While the
University has a plan to preserve the campus natural areas, the west end of the
campus has until recently been a more spread out part of campus with the feel
of a more rural institution. The addition of the plant places an industrial
facility in an area which is already being impacted by the recent construction
of the two buildings mentioned above, as well as the rapid expansion of the
Medical School complex. The impact of the gift of this land and the cumulative
impacts of the development on the west end of campus is an impact which should
be explored further.
4.5. Location of an
Industrial Facility Adjacent to a Residential Neighborhood.
Nearby residents who
are concerned about the proposal for the WCCF plant have legitimate concerns.
Because electrical generation facilities are regulated by the PSC, the
restrictions of zoning which would apply to any other industrial facility do
not apply to the construction of this facility. While the Sierra Club is not
prepared to oppose construction of the facility in this location for this
reason alone. The proposal for the WCCF
plant must be reviewed in a different context than similar plants might be. We
believe that an unusual level of sensitivity should be used in reviewing the
proposal in view of its location in an area in which other industrial
facilities would most likely not be approved.
5.0.
Alternatives Not Pursued
The proposal for the
cogeneration plant is, in part, a story of missed opportunities. Two missed
opportunities are the failure to aggressively pursue energy conservation
measures, and the failure to seek more renewable sources of energy.
5.1. Energy
Conservation and Efficiency
Meeting the projected
increase in demand for electricity in the next decade will be a challenge.
Therefore it is important to explore different ways in which forecasted
capacity deficits can be met. This must include not only increased supply but a
more aggressive cost-effective effort to improve efficiency.
5.1.1. Energy
Conservation by MG&E
The DEIS lists 4
types of energy conservation. It notes that MG&E did not review all 4
types, and performed a somewhat perfunctory review of the energy conservation
options listed. Public Service Commission (PSC) staff used the methodology
employed by MG&E and completed the analysis. In the opinion of PSC staff,
energy conservation efforts would only supply a small fraction of the energy
needed by MG&E and that which would be generated by the proposed plant.
As the DEIS notes,
the energy conservation analysis by MG&E was incomplete and flawed. A more
enthusiastic pursuit of this avenue would turn up additional savings that would
have a more bountiful payoff in terms of reductions in the amounts of energy
consumed by MG&E's customers.
· The primary tool that was used in the DEIS to assess potential
gains in efficiency was the Statewide Technical and Economic Potential (STEP)
study, which examined economic potential of efficiency based on three
categories: conservation, load management, and fuel switching.
· The most optimistic results found 6 MW of savings annually
through 2004, which is less than half the 18 MW shortfall that MG&E has
forecasted.
· However, the Public Service Commission (PSC) explains that
the STEP plan was developed in 1994 and therefore is outdated. The STEP study is also described as not
adequately addressing industrial energy efficiency, a potential major source of
efficiency improvements.
· In addition, under Wis. Stat. sections 1.12(4) and 196.025,
if the PSC finds that energy conservation or efficiency can substitute
cost-effectively for the proposed generating facility, the PSC’s decision must
ensure by law that the energy conservation measures are implemented.
· If the Commission truly believes that, “from an
environmental perspective, energy efficiency is the best option for meeting
energy needs,”[2] then it is
unacceptable that more current and complete information is not available
concerning energy efficiency options.
· The analysis that was completed by MG&E and the PSC
shows little or no effort on the part of either party to use independent input
from either conservation groups or consultants. It is dubious whether either MG&E or PSC seriously examined
the potential savings from energy efficiency programs.
· Useful examples of such alternative programs include the
Environmental Law & Policy Center’s report entitled “Repowering the
Midwest,” and Alliant Energy’s Shared Savings program. In a recent assessment of the Shared Savings
program, Global Energy Partners determined that in 2001 alone, the Shared
Savings program was responsible for lowering demand by over 16 MW. Partial public support for such a project
would undoubtedly generate even more results.
We propose that both
MG&E and the PSC should not only recalculate their efficiency data after
consulting with an independent expert but should also seek to implement an
aggressive plan for improving efficiency in the Madison area.
5.1.2.
Energy Conservation by UW
The UW needs to take
responsibility for its energy conservation. The rationale for location of the
plant in the proposed location is, after all, the energy needs of the campus.
Those energy needs need to be examined closely.
Prior to issuing any
permits, the PSC should require the UW to fully implement its energy
conservation plan and apply measures that have a 15 year, rather than the
current nine year payback. Madison residents have observed that UW is a
profligate consumer of electricity and other power sources. Actions which would
reduce energy consumption include the following:
· Shutting lights off at night and when not in use.
· Closing doors to ensure that heat does not vent to the
outdoors during the winter nor does cool air vent to the out of doors in the
summer.
· Taking measures to
reduce the reliance of faculty, staff, and students on the automobile as a
means of transportation.
5.1.2.1. Light
Pollution on the UW Campus
Residents who live
near the UW campus cite the University as a tremendous source of light
pollution. Casual observations reveal that buildings are illuminated throughout
the night. Besides being a tremendous waste of energy, this is makes UW a bad
neighbor to nearby residents.
In addition to
impacts of light pollution on nearby humans, light pollution has broader
impacts as well. Astronomers cite the impact of unnecessary lighting as a real
source of diminished opportunities to observe celestial phenomena. In addition,
light pollution disrupts the natural habitat of wildlife. Nearby campus natural
areas harbor a surprising variety of wildlife. In residential areas of Madison
not far from UW, coyotes and turkeys are among the animals observed.
Nearby residents have
observed that light pollution from the UW campus is not necessarily accidental
or due to negligence. Rather, it appears that certain buildings are illuminated
at night to please the architects who designed the building. One nearby
resident reported that when he complained about unnecessary lighting of a
building, an employee responsible for that building's operations had been
unaware of the light. It turned out that the lighting was on a rooftop, on
which no activities take place.
In addition,
directing lighting downward and reducing glare can reduce the consumption of electrical
power while actually increasing visibility at night.
5.1.2.2. Energy
Conservation by UW
The UW campus is
larger than many cities. As a result, it is no surprise that the campus
consumes a vast amount of energy. If windows and doors are shut when heating or
air conditioning is in use, that energy consumption will be kept relatively in
check. Sometimes windows are kept open at inappropriate times because buildings
are kept too cool in the summer or too hot in the winter. The UW should
implement the results of its energy audit, which revealed many of these
inefficiencies and provided a blueprint for the campus to correct these
inefficiencies.
In addition, the
campus is continuing to undergo an aggressive building program. Part of the
mission of the energy audit is to determine which older buildings require
retrofitting to increase energy efficiency. Once identified, these buildings
should be placed on a list of future building projects to receive necessary
renovation to reduce the waste of energy.
Finally, "green
building" (LEED) criteria exist by which new construction projects are
evaluated for energy efficiency and other environmentally friendly aspects.
Often these criteria result in increased comfort of those who live, work, or
study in the buildings. The University should take advantage of its building
program to become a leader in employing green building techniques and achieving
the highest possible scores for meeting green building standards.
5.1.3. Use of
Renewable Energy Sources by MG&E
MG&E sees itself
as a leader in the use of renewable energy resources. To a large extent, this
self-image is deserved. MG&E was early and aggressive in developing wind
energy as a source of electrical generation. Wisconsin's sometimes brutal
winters have the advantage of making the state a great source for wind power
generation.
MG&E needs to
redouble its efforts to develop renewable sources. The proposal for the WCCF
plant appears to be a relatively conventional source of new power while
MG&E's efforts to develop renewable sources appear to have languished.
MG&E should rededicate itself to developing sources of renewable energy,
including, but not restricted to, wind energy generation.
6.0. Operation of the
Plant as Proposed Would Not be a True Cogeneration Plant
The
water use from the plant under summertime high‑load conditions is quite
high compared to many large power plants (e.g., 3.3 million gallons per day to
produce 150 MW versus 7 million gallons per day to produce 550 MW at a combined‑cycle
natural gas baseload power plant). This
should not be the case for a true "cogeneration" plant, for reasons
outlined below. The water consumption
owes to the wet cooling towers used to dissipate the "waste"
heat. In reality, the "waste"
heat is also wasted energy because the chemical energy in the fuel that does
not produce electricity, steam or chilled water is discharged to the atmosphere
with the cooling tower. Cogeneration
plants should beneficially use most of the heat that results from combusting
the fuel. In this case, the
cogeneration at this plant is intermittent, and cogeneration is not used in the
summer when it would be most beneficial. The cogeneration apparently occurs in
the cold season where the "waste" heat is used to heat the campus
buildings. A quick check of the web
shows that many places like the University of Chicago and Stanford use
absorption chillers.
In
general, even though it only operates partially in the cogeneration mode, this
natural gas plant will still be twice as overall efficient as current sources
of our electricity (Columbia Energy Center in Portage), and infinitely cleaner
than old coal plants (mostly owing to the fact that natural gas is so much
cleaner than coal, no mercury, no acid rain, ˝ to 1/4 of the greenhouse gas per
MW, etc.), and since it is located where demand is, it does not require new
transmission lines. They should use absorption chillers to make this a full
cogeneration plant in the summer when the water consumption is highest. Also, if the waste heat load in the summer
is dramatically reduced using absorption chillers, the remaining waste heat can
be dumped using dry or hybrid cooling towers and further reduce the water
consumption. Which brings up the other
component that can be changed: the cooling towers.
This
plant uses a hybrid wet cooling tower that dumps heat into the atmosphere by
evaporation, leading to consumptive water use.
The ancient Blount street plant uses once‑through cooling which
simply pumps water to the plant, it goes through a radiator, and then back out
to the lake. Although no water is
"consumed" these once‑through systems have to move much higher
volumes of water than wet cooling towers (because the evaporation of water
provides a huge cooling effect) and therefore would impact wildlife (they
cannot survive the pumping). The plant
should not use once‑through cooling, even though it would lead to no net
water consumption. It should, however,
explore alternative cooling tower designs.
Therefore,
the lack of cogeneration in the summer is a problem. The plant should employ
absorption chillers, not electric chillers. Alternative cooling technologies -
dry towers - should be considered.
7.0. Mitigation
Because the WCCF
proposal is relatively unique, relatively unique solutions should be employed to
offset its impacts. The plant provides new generating capacity, and not
replacement capacity, and is sited in an urban area. Therefore, MG&E and UW
should go above and beyond what is required to mitigate the impacts of the
plant.
To offset the impact
of a new power plant, MG&E and UW should seriously explore the potential to
shut down the older plants located on Walnut, Charter, and Blount Streets. At a
minimum, they should commit to a timeline for the cleanup or shutdown of these
facilities.
In addition to its
own plants, MG&E could look into the possibility of replacing the steam
generating capacity of the Capitol Power Plant. Given the public-private
partnership which the WCCF plant entails, this should not be too much of a
reach.
To help mitigate the impacts
of increased air pollution from the new facility, MG&E should work with the
UW, the City of Madison, and Dane County to convert all publicly owned diesel
fuel vehicles, including Madison Metro buses, to cleaner, low-sulfur diesel
fuel with soot traps. This action would reduce pollution from these vehicles by
more than 90 percent, contributing greatly to air quality mitigation efforts.
The University should
abandon its proposal for the west campus parking ramp and establish a “No Net Parking Increase” policy on the UW
campus. The proposed construction of the planned Lot 76 ramp capacity - a
possible increase of some 1,200 parking spaces in the immediate area of the
proposed power plant - is a step backwards in local transportation
options. It will have the impact of exacerbating already serious traffic woes
on University Avenue and increase air pollution resulting from traffic.
Additional
transportation options which could be explored might be a park-and-ride
facility at the proposed commuter rail stop in Middleton. Other options might
be parking at outlying sites such as shopping malls, which are largely
underutilized until after 4:00. Hilldale Mall is owned by the UW Foundation.
Other malls include; Westgate, West Towne, and East Towne.
The
University should employ more aggressive and detailed policies for energy
conservation should be employed in the construction of new buildings (LEED
certified). These are measured through the use of "green building"
criteria. This must include conserving energy in getting people to these
buildings, by eliminating 1 or more parking spaces elsewhere on campus for
every space included with each new or remodeled building.
As previously
indicated, the UW should aggressively pursue energy conservation measures,
including simple steps like shutting lights out at night and closing doors to
save heating and air conditioning. These efforts should be quantified through
an independent energy audit of campus operations.
MG&E should renew
its commitment to renewables and energy conservation. The utility should add
new sources of wind generation and other renewable sources.
UW
and MGE should cooperate with Madison and Dane County on planning and financing
a cost-effective, fast and efficient rail transit system that will result in a decrease
in transportation pollutants in the University Avenue corridor. MG&E and UW
could also collaborate with Dane County to pursue setting a maximum number of
commuter parking spaces county-wide to limit transportation pollutants. The
commuter rail system is a step in the right direction, but at the same time as
the start-up system is getting rolling, its air quality and congestion
mitigation benefits would be vastly overwhelmed by UW's BioStar parking
construction alone, within 3 to 7 years - possibly before the initial rail
system even begins operations.
The
applicant could work with Dane County to commission a quick-study paper on
energy conservation - especially focusing on the energy use that has the
greatest detrimental impact on Madison kids - the energy used in moving people
from home to work and back.
8.0. Conclusions
The
PSC and MG&E must re-examine the WCCF project to ensure that it fulfills
legal, social and environmental commitments.
Energy efficiency, air pollution, and water quantity concerns will
require a more comprehensive assessment before a reasonable conclusion can be
reached. We believe that realistic
solutions exist and should be implemented prior to building this or any other
power plant.
Respectfully
submitted on behalf of the Sierra Club,
Alfred
Matano
Wisconsin State Bar #1027918