April 25, 2003

The Honorable Jim Doyle
Governor, State of Wisconsin
115 East, State Capitol
Madison, WI 53702

Carol A. Stemrich
Public Service Commission of Wisconsin
P.O. Box 7854
Madison, WI 53707-7854

SUBJECT: Comments of the Village of Shorewood Hills concerning the proposed

West Campus Co- generation Facility (WCCF)

Public Service Commission Docket No. 05-CE-121

Dear Governor Doyle and Ms. Stemrich:

The Board of Trustees of the Village of Shorewood Hills has directed me to
send this letter, following a report that was presented at the Board's
meeting on April 21, 2003, by our Ad Hoc Committee for study of the proposed
West Campus Co-generation Facility (WCCF). We have addressed this letter to
you as potential decision-makers with respect to the question of whether
another power plant should be constructed on the University campus.

The Village asks you to consider the concerns of the Village, both with
respect to the decision-making process, and with respect to the potential
impacts that the facility may have on the environment and the quality of
life of those who live in close proximity to the site of the proposed plant.
In addition, we ask that this letter be made part of any official record
that will reflect your consideration of this matter.

I. Summary

The Village was incorporated in 1927. It is bordered on the east by the
Madison campus of the University of Wisconsin, on the north by Lake Mendota,
and on the south and west by the City of Madison. If the WCCF were approved,
the facility would be located less than a mile from the eastern border of
our Village.

The Village has not taken a position on the ultimate question of whether the
WCCF or a smaller facility ought to be built at the site. However, it has a
number of concerns about both the decision-making process and the potential
impacts that such a facility could have on the environment and the quality
of life of Village residents. These may be summarized as follows:

(1) the Village believes that the Public Service Commission, the University
and the State should each conduct rigorous cost/benefit analyses, with a
high degree of scrutiny, as to whether the WCCF is truly needed, whether the
proposed site is appropriate in view of its close proximity to hospitals and
residential areas, and whether there may be one or more preferable
alternatives that would provide for all or part of the respective needs of
the University and MGE;

(2) while the Village recognizes that the University and the State intend to
make a final decision on the proposed WCCF on about May 7, 2003, in order to
permit provisions to facilitate construction to be incorporated into the
2003-2005 state budget, the Village believes that the May 7 deadline does
not provide sufficient time to ensure that adequate consideration will be
given to the concerns of the Village that are stated in this letter;

(3) if any power plant is built at the proposed site, the Village believes
that there should be no net degradation of the environment, and that any
permits that may be required for the construction or operation of such a
power plant should contain legally enforceable conditions or limits to
ensure the achievement of that goal.

I. General Comments

The plan for the WCCF would place an industrial facility in close proximity
to residential neighborhoods that are located within: (1) the Village of
Shorewood Hills; (2) areas within the Regent Neighborhood of the City of
Madison that include University Heights and the Old University Avenue
Corridor; and (3) portions of the University campus that are devoted to
apartments or dormitories in Eagle Heights, University Houses, and the area
along the shore of Lake Mendota to the east of Willow Creek.

It would also be located in close proximity to the three existing medical
facilities of the University of Wisconsin Hospital and Clinics, the
Veteran's Administration Hospital, and the Waisman Center, as well as to a
proposed new children's hospital.

Accordingly, as noted above, the Village believes that rigorous cost/benefit
analyses should be conducted, with a high degree of scrutiny, as to whether
the WCCF is truly needed, whether the proposed site is appropriate in view
of the close proximity of hospitals and residential areas, and whether there
may be one or more preferable alternatives that would provide for all or
part of the respective needs of the University and MGE .

In considering whether alternatives may be preferable, the Village believes
that consideration should be given to whether all or part of the projected
benefits could be obtained with lower net costs to: (1) state taxpayers; (2)
utility ratepayers; (3) the environment; (4) the health of sensitive
populations in adjacent areas that include children, hospital patients and
the elderly; and (5) the overall quality of life of neighboring residents.

A consultant's report on potential alternatives will not be presented to the
University in final form until April 25, 2003. Given that, the Village
believes that the current deadlines that call for the University to decide
how to proceed by May 1, and for the Department of Administration to choose
between the options proposed on behalf of the State by May 7, are
insufficient to assure that adequate consideration will be given to the
concerns of the Village that are stated in this letter.

If it is determined that a power plant must be built on the proposed site,
the Village believes that the plant should be designed, and mitigation
measures should be required, with the goal of assuring that there will be no
net degradation of the environment.

The Village also believes that any permits that may be required for the
construction or operation of such a power plant should contain legally
enforceable conditions or limits to ensure that there will be no net
degradation of the environment.

II. Water Resources

The draft environmental impact statement (DEIS) states (pp. 107-108) that
the groundwater in the Madison area has been depleted by withdrawals of
water from Madison-area aquifers by wells, and by development that has
reduced the amount of surface water that can infiltrate into the soil to
replace the volumes that have been withdrawn.

While the groundwater normally would help to recharge the waters of area
lakes, the DEIS states (p.108) that Lake Mendota currently recharges the
groundwater across the southern two-thirds of its lake bed, and that Lake
Monona recharges the groundwater across the entire area of its lake bed.

The Village understands that the current plan for the WCCF includes a design
of the plant, and proposals to mitigate withdrawals of ground water, that
would be consistent with the view of the Village that there should be no net
depletion of groundwater in the Madison area as a result of the operation of
a power plant on the site.

Potential mitigation projects are under consideration at four sites (see
DEIS at 120-123), which would encourage surface water to infiltrate or
percolate into groundwater aquifers to replace groundwater that would be
withdrawn from a well near Mud Lake. A plan for storm water management
measures that would promote infiltration within the Willow Creek watershed
has already been created as the result of the work that was done, with
Village participation, by a multi-jurisdictional storm water task force in
2001.


On the basis of that work, and on the presentation set forth in the DEIS,
the Village believes that the implementation of plans for infiltration
projects at one or more of these sites should be required as a condition for
building the WCCF or an alternative plant, and that priority should be given
to the proposed locations at Rennebohm Park and the Hill Farms State Office
Building in the City of Madison.

In addition to assuring that there would be no net depletion of ground water
resources as a result of the WCCF, the proposed infiltration projects at
those sites could help to alleviate periodic flooding at the intersection of
University Avenue and Midvale Boulevard, and in the University Avenue
corridor to the east of that intersection, which was a concern of the 2001
storm water task force.

III. Noise Levels

The noise level survey that MGE commissioned for the DEIS (p. 168) does not
contain any measurements of ambient noise levels within the Village and
fails to reflect the results of any modeling that would predict the
potential impact of the WCCF on noise levels within the Village.

MGE subsequently issued a paper stating that it had monitored background
noise levels of 47 dBA at two locations within the Village, and predicted
that the potential sound of the WCCF "is expected to be" 31 dBA at one of
those sites, and 27 dBA at the other, which led MGE to conclude that the
WCCF "will not have a cumulative effect on background noise in Shorewood
Hills."

However, many Village residents have complained that the current levels of
noise that are emanating from the West Campus area are unacceptably loud and
intrusive, particularly the noise that emanates from the ventilation systems
of the new Pharmacy Building and the recent addition to the Waisman Center.

The DEIS notes (p. 166) that a change of 3 dBA is barely perceptible to the
human ear, that a change of 5 dBA is perceptible, and that a change of 10
dBA is perceived as either twice or half as loud. The DEIS also points out
(p. 166) that noise level scales "are logarithmic rather than linear," which
means that the noise levels emitted by two different noise sources "at the
same dB level would have a combined noise impact of 3dB greater than either
source alone."

Representatives of the Village have asked the University to take steps to
abate or mitigate the noise levels that are emanating from the Pharmacy
Building and the Waisman Center addition, but to date, efforts to secure an
abatement or mitigation of that noise have not been successful.

In view of the difficulty of securing mitigation or abatement of noise
levels emitted from existing sources, the Village believes that the final
EIS should be based on additional monitoring of existing noise levels and an
independent evaluation by the Department of Natural Resources, or other
appropriate agency, as to the potential impact of the WCCF, in order to
ensure that the existing problems will not be exacerbated.

In this context, the DEIS notes (p. 172) that mitigation measures could
include "acoustical hoods or boots for interior parts of the plant or
barriers erected or suspended on the outside at strategic

locations." If a power plant is built on the site, the Village believes that
the plant should be designed and/or mitigation measures should be required,
with the goal of assuring that there will be no audible noise from the
WCCF--which would degrade the quality of life for the residents of adjacent
neighborhoods and hospitals--even if the existing levels of noise from the
Pharmacy Building and the Waisman Center are abated or mitigated at some
point in the future.

IV. Light Pollution

The development of the West Campus has resulted in a sharp increase in
sources of ambient light that are visible to residents of the Village. The
Village believes that the proposed WCCF should be required to comply with
the terms of Dark Skies Initiative, with the minimum amount of lighting that
may be necessary, and light fixtures that will focus any necessary light
downward.

V. Air Quality

As noted above, the WCCF would be an industrial facility that would be built
in close proximity to hospitals and residential neighborhoods. The DEIS
points out (pp. 94-95 and 98-99) that the WCCF would emit several regulated
pollutants, including sulfur dioxide, nitrogen oxides, carbon monoxide,
particulate matter and certain other air pollutants that the Environmental
Protection Agency has identified as hazardous.

The DEIS also points out (p. 100-101) that children and the elderly are
particularly susceptible to certain air pollutants, which indicates that
there could be higher societal costs from operation of the WCCF on a site
that is in close proximity to hospitals and residential neighborhoods.

The WCCF would support further expansion of the West Campus area, which has
already created quality of life issues for Village residents in the form of
increased noise, increased traffic, and increased light pollution, as well
as an indeterminate degradation of air quality as a result of the heavier
traffic, the use of more chemicals in West Campus facilities and
laboratories that may escape into the ambient air, and the increased burning
of fossil fuels at the existing Walnut and Charter Street plants to meet the
needs of West Campus buildings for steam and chilled water for heating and
air conditioning.

The DEIS states (p. xix) that "modeling conducted by DNR staff concludes
that the proposed project would result in a net increase in fine particulate
and other pollutant concentrations in the vicinity of the plant, compared to
those measured at an existing monitoring station located near the
intersection of University Avenue and Franklin Street."
While the Village is not in a position to question or validate the air
quality analysis that is set forth in the DEIS, or the overall conclusion
that the facility would meet existing federal air quality standards for
regulated pollutants, the Village is concerned about the conclusion of the
DEIS (p. 100) that "there will be an increase in emissions" of particulate
as a result of the proposed project, and accordingly, "some additional
likelihood that sensitive individuals may experience increased symptoms as a
result of
this project."

In this context, the Village understands that the results of monitoring at
one location close to the proposed site of the WCCF have indicated that the
City of Madison may be close to violating the National Ambient Air Quality
Standards (NAAQS) for particulate matter, and that the WCCF could produce up
to 50 pounds per hour of particulate matter for short periods when fuel oil
may be used for combustion.

The Village also understands that the City of Madison may be close to
violating the applicable Ambient Air Quality Standards for sulfur dioxide
and ozone. The Village is particularly concerned that the additional
emissions of particulate, when combined with additional emissions that may
be anticipated from other sources as the Madison area continues to develop,
could contribute to a violation of the NAAQS in the future.

On that point, the Village believes that necessary permits should contain a
limit or condition that would impose a legally enforceable requirement that
natural gas be used for 99 per cent of operations, in order to limit the use
of fuel oil for combustion to one per cent of operations or less.

In addition, the Village understands that there have been some discussions
about mitigating the potential for additional particulate emissions by
funding natural gas powered vehicles to reduce the levels of particulate
that are currently emitted in the area by diesel trucks and buses, and
believes that such this type of mitigation alternative could also be made a
condition of necessary permits.

The Village also believes that the proposed WCCF should be considered in a
broader context, not merely in isolation as a facility that would comply by
itself with existing air quality standards, but instead as one of many
sources of potential for additional pollution that could contribute to a
violation of the applicable NAAQS at some future time.

In this context, the Village understands that the University may have the
ability to select and use cleaner burning fuels at the existing Walnut and
Charter Street plants, which may provide an opportunity to assure, or to
help assure, that there would be no net degradation of air quality as a
result of the WCCF.

Under these circumstances, the Village believes that there ought to be
consideration of the extent to which mitigation measures may be implemented
at the other power plants in the central Madison area that are operated by
MGE, by the University, or by the State of Wisconsin, in order to determine
whether the implementation of such mitigation measures might wholly or
partially offset the anticipatedincrease in emissions of both particulate
and other regulated pollutants that would result from building the WCCF.

In short, if a power plant of any size must be built on the proposed site,
the Village believes that the plant should be designed, and mitigation
measures should be required, with the goal of assuring that there will be no
net degradation of the air quality in the central Madison area that includes
the Village of

Shorewood Hills.

VI. Errors in the DEIS

The DEIS contains an error at p. 154, where it is stated that "The Village
[of Shorewood Hills] does not have a Master Plan." The Village does have a
master plan for the commercial corridor along University Avenue that was
adopted in the early 1990's. In addition, the Village is in the process of
developing a Comprehensive Plan in compliance with Wisconsin's new Smart
Growth law (Wis. Stat. 66.1001).

It appears that there is another error in the DEIS at p. 108, where it is
stated that the Blackhawk Golf Club uses 1.87 MGD (million gallons per day)
of water from Lake Mendota. Monroe Miller, the Greens Superintendent for the
Club, supplied the following data on water usage at the Club during the past
six years. We calculated the gallons used per day by assuming the Country
Club irrigates the course on average 81 days per year--approximately 3
times/week from May 1 to October 31. The actual number of days water is
withdrawn for irrigating will vary considerably each year, depending on
weather conditions.

Year Total Gallons Used/Year Total Gallons Used/Day
1997 12,457,000 153,790
1998 19,979,000 246,654
1999 14,138,000 174,543
2000 10,278,000 126,889

 2001 13,422,000 165,704
2002 14,875,000 183,642
AVERAGE 14,192,000 175,204


VII. Conclusion

The Village appreciates your consideration of these comments. Please let me
know if you have any questions or would like any additional information.


Sincerely,

Peter Hans
Village of Shorewood Hills President



cc:

Senate Fred Risser
Representative Spencer Black
Chancellor John Wiley, UW

Alan Fish, UW
Lynn Hobbie, MG&E
Steven Ugoretz, DNR
Supervisor Al Matano, Dane County Board
Mayor Dave Cieslewicz, City of Madison
Elaine Glowacki, President, Regent Neighborhood Association

Secretary Marc Maratta, DOA