April 25, 2003

Carol A. Stemrich
Public Service Commission
610 Whitney Way
Madison, WI  53707

Re: Comments on Draft Environmental Impact Statement MGE-UW West Campus Co-Generation Facility

Dear Ms. Stemrich,

The Regent Neighborhood Association welcomes this opportunity to comment on the Draft Environmental Impact Statement prepared by the PSC and DNR concerning the proposed 150 megawatt co-generation facility on the UW’s West Campus.  Others with more expertise will be commenting on and questioning specific aspects of the scientific analysis of this project, but this power plant would be located next door to our residential community, and neighbors have many concerns about their health and welfare living so close to such a facility.  We hope that the following concerns can be more fully addressed in the Final Environmental Impact Statement.

Health and Safety Issues   It is important to the neighborhood that the analysis of this project be very carefully and thoroughly done concerning potential health risks to people living and working in the immediate area.

1.      The census data provided for the surrounding area does not include the populations of the two hospitals, two public schools, five day care centers or any of the UW employment centers or residential buildings near the project nor does it include the number of commuters who pass by every day on foot, on bicycles or in vehicles.  These figures must be included to provide a more complete description of the populations (whether normal, sensitive or vulnerable) that will be most directly affected by the emissions from the new facility.

2.      A number of hazardous chemicals will be stored on the site and neighbors are aware that there was an explosion at a power plant in Wisconsin earlier this year.  Please require MG&E to provide its emergency procedures plans, including a Risk Management Plan.

3.      It has been suggested that building a smaller facility would result in greater emissions and water usage than the proposed project.  Please explain why this might be true.

4.      Although HAP regulations may not apply to the proposed project because it will burn Group I fuels, please include a listing of whatever Hazardous Air Pollutants will be produced by WCCF when it burns both natural gas and ultra low-sulfur fuel oil.

5.      There have been periods of non-attainment of air quality standards in recent years.  Please provide information on how when these periods have occurred, and explain the basis for this determination.

6.      New, more stringent, regulations on particulate matter are being promulgated which will take effect in the near future.  Please explain whether the PSC will hold the proposed project to these standards, and why or why not.

Noise and Vibration – The neighborhood is concerned about other problems that may
be caused by a new energy facility at this location.   
  1. The sound level analysis does not account adequately for the topography of the neighborhood to the south (and there is plainly more than 50 feet of difference in elevation between the proposed site and the residence highest on the hill).  Please provide a more detailed sound analysis including these factors.

  2. The neighborhood believes that sound mitigation strategies for various aspects of the facility must be implemented, not merely considered.  Please consider making sound mitigation measures a condition of PSC approval.

  3. Analyze the noise profiles for the three types of start-ups  (cold, warm, and hot) that may be utilized for the combustion turbines proposed for the new facility.

  4. Construction activities will have to meet local ordinances with respect to sound  level and hours of operation.  Please include these requirements in the Final EIS.

  5. Please analyze how local geology may influence the potential for vibration caused by mechanical components of the project.
Water Issues   The water usage sections of the DEIS does not address all of the options being proposed for the WCCF project, and the neighborhood expects to see a more complete analysis of all the options in the Final EIS.  In addition,
  1. Stormwater management plans and details need to be provided by MGE for this project before construction begins, including a clarification of the routes that stormwater is planned to follow in Figure 6-23.  Please analyze how these fit
    with the UW’s plans for stormwater management on the West Campus.

  2. The impact of MGE’s Blount Street power plant should be included in the final analysis of watershed issues.

Historical & Archeological Sites   The West Campus area includes natural areas which occupy a very special place in the heart of the community.  It is very important that this project not disturb significant sites.

  1. Until the surveys of historical and archeological sites in the area have been completed, no construction activity should be allowed to proceed.  Please include the complete findings of these surveys.

  2. Table 7-1 should be revised to include the findings of these surveys and also the Lakeshore Path site, which is not included in the current version.

Full Build Out   The project as it has been analyzed does not appear to include an addition for chillers that is planned for the northwest corner of this site.  The final configuration of the facility has implications for land use and architectural concerns as well as overall emissions and water usage.

  1. If another EIS is not required at whatever time this addition is proposed, 
    please include an analysis of the fully completed facility in the Final EIS for this application.

  2. Please require the applicant to provide an architectural rendering of the fully
    built-out project with stacks extended to their new height (see Figure 6-30)
    and add this information to the simulations (Figures 6-31, 6-33,  6-37 and 6-39).

  3. Include a shadow study that is based upon the facility at full build out dimensions.

Underlying assumptions  Certain basic assumptions affect the determination of electric, steam and chilled water needs. Please consider the following:

  1. There is concern that the heat and chilled water needs of new buildings have been over-estimated. Please describe the basis for estimating these needs in the final EIS. If the needs are not estimated using best modern energy conservation practices, please include those estimates as well.
  2. Contrary to a statement on page 55, a majority of labs could operate on reduced air flow when unoccupied at a substantial energy savings. Most unoccupied times are at night, therefore, partial shutdown of laboratories combined with the use of ice storage could substantially reduce peak chilled water needs, hence peak electricity needs. Please address this possibility.

Thank you for addressing these issues in the Final EIS this summer.  We look forward to the PSC’s staff further analysis of this very important project and expect to be involved in the public hearing stage of the process as well.

Sincerely,

Elaine Friedman Glowacki
Board President
608-238-7103
efg@msn.fullfeed.com