Public Comment on The Governor’s Task Force on Global Warming Strawman Proposal - June 19
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Public Comment on The Governor’s Task Force on Global Warming Strawman Proposal - June 19

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28 Pages
English

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Public Comment on The Governor’s Task Force on Global Warming Comprehensive Strawman Proposal Received on June 19, 2008 Comments from Page Michele Schuster 1 Dawn Lingo 2 Todd Stuart 3 Karen and John Cleary 5 red judy 6 Dave Dahlberg 7 Terry Hansen 8 Tom Allen 9 Mark F. Dahlberg 9 Dan Kohler  10 Jeff Anthony 11 Kenneth J. Klein  11 Marcia Hartwig 12 Heidi Blankenship 12 John Siegert 13 Jessica Dexter 14 Debra Schneider 14 Robert J Hintz 15 Paul Schneider 15 Don Ferber 16 David Knuti 17 Stephen Steinhoff 18Robert Hill 19 Comments from Wisconsin Religious Leaders 19 David Knuti 21 Kerry Thomas 22 Kevin Kawula 24 Scott Manley 24 Satya Rhodes-Conway 25 CFW Wheelock 25 George Meyer 26 From: Michele Schuster Sent: Thursday, June 19, 2008 5:46 AM To: DNR GLOBALWARM TF COMMENTS Subject: Strawman Proposal Thank you for all the work being done regarding this complex and critical issue! My concern is that the Strawman Proposal does not go far enough, fast enough. My belief, based on my reading and facts given on many scientific PBS programs, is that Global Page 1 of 28 Warming is more advanced and serious than most people in Wisconsin know. Further, impressively researched investigative reports show another important clue - that our Federal Administration has censored the science that has allowed to be reported on Global Warming. As a result, the severity of the threat to life on Earth was minimized. An official ...

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Public Comment on The Governor’s Task Force on Global Warming
Comprehensive Strawman Proposal

Received on June 19, 2008


Comments from Page
Michele Schuster 1
Dawn Lingo 2
Todd Stuart 3
Karen and John Cleary 5
red judy 6
Dave Dahlberg 7
Terry Hansen 8
Tom Allen 9
Mark F. Dahlberg 9
Dan Kohler  10
Jeff Anthony 11
Kenneth J. Klein  11
Marcia Hartwig 12
Heidi Blankenship 12
John Siegert 13
Jessica Dexter 14
Debra Schneider 14
Robert J Hintz 15
Paul Schneider 15
Don Ferber 16
David Knuti 17
Stephen Steinhoff 18
Robert Hill 19
Comments from Wisconsin Religious Leaders 19
David Knuti 21
Kerry Thomas 22
Kevin Kawula 24
Scott Manley 24
Satya Rhodes-Conway 25
CFW Wheelock 25
George Meyer 26


From: Michele Schuster
Sent: Thursday, June 19, 2008 5:46 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: Strawman Proposal
Thank you for all the work being done regarding this complex and critical issue! My concern is
that the Strawman Proposal does not go far enough, fast enough.

My belief, based on my reading and facts given on many scientific PBS programs, is that Global
Page 1 of 28 Warming is more advanced and serious than most people in Wisconsin know. Further,
impressively researched investigative reports show another important clue - that our Federal
Administration has censored the science that has allowed to be reported on Global Warming. As
a result, the severity of the threat to life on Earth was minimized. An official employed by the
Federal Government took the risk of speaking out in a program called "The Age of Warming"
produced by and aired on CBS! That CBS was willing to show such a program might be
significant to anyone who puts most stock in mainstream media. (Unfortunately, it aired during
the Super Bowl.)

Europe and some other areas of the world are far ahead of our country in understanding and
action. I believe that all U.S. citizens and public servants would do well to take Global Warming
as our most serious challenge EVER. We came together as a country during World War II. We
can do it again. Even as the daughter of a WWII Veteran, I believe that Global Warming is a far
more serious situation! Can we all act together? Can we work even harder to put party
differences and business interests aside?

Please consider (again?) the need for:
* Numeric global warming reduction targets based on the most current, sound science
* MANDATORY early action to reduce global warming pollution
* Home-grown clean energy and energy efficiency solutions to address global warming in
Wisconsin


From: Dawn Lingo
Sent: Thursday, June 19, 2008 7:28 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: Comments regarding task force on global warming
Dear Task Force Members,

I urge you to reconsider the important impact your decisions will have on our childrens' future,
on Wisconsin's future and on the future of our planet. I implore you to consider the following:

1. Oppose the gutting of a past Conservation Priority, the Renewable
Energy and Energy Efficiency Bill (Act 141). Specifically, the Task
Force should:

Leave the definition of renewable energy alone! The recommendations
attempt to change the definition to non-renewable forms of power,
like large-scale hydro and derivatives of fossil-fuels.
Keep green-pricing programs honest! Right now, citizens can enroll
in special programs where they choose to purchase clean, green
energy at a higher rate. Every time they do so, it is green energy
IN ADDITION TO the 10% renewable energy standard required by law.
The Task Force recommendations propose to change that and count the
green energy citizens are paying for TOWARDS the utilities' required
10% renewable energy goal.
Page 2 of 28
Prevent double-counting of renewable energy! Act 141 required a 10%
renewable energy standard by 2015, and provides an incentive for
companies that move quickly towards that goal to sell their
renewable energy credits to other companies who are unable to move
as quickly, with those credits being good for a maximum of 4 years.
The Task Force recommends that the expiration date on the energy
credits be removed, meaning that renewable energy credits could be
counted indefinitely and replace actual renewable energy.

2. Support strong, science-based emission reduction targets by
including a specific pollution reduction timeline and amounts for
those reductions: Stabilize emissions by 2010; reach 2005 levels by
2012; 25% reduction from 1990 levels by 2020; and 80% reduction from
1990 levels by 2050.

3. Support Wisconsin's current nuclear moratorium, which requires
that any proposed nuclear facilities must demonstrate that they have
a plan for nuclear waste storage. The recommendations would remove
this waste storage requirement.

4. Encourage action now, not later, by creating incentives for
small, immediate cuts in global warming gases. The recommendations
include no such incentives which could mean that Wisconsinites see
no reductions any time soon.

Dawn Lingo
Kenosha, WI


From: Todd Stuart
Sent: Thursday, June 19, 2008 7:44 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: WIEG Comments - Strawman Proposal
To: Roy Thilly
Tia Nelson

From: Todd Stuart, Executive Director
Wisconsin Industrial Energy Group, Inc.

Re: Comments on Strawman Proposal

Date: June 19, 2008

The Wisconsin Industrial Energy Group, Inc. (WIEG) submits the following comments
regarding the strawman proposal from the Task Force Co-Chairs. WIEG appreciates some of
Page 3 of 28 new initiatives designed to mitigate costs and industry issues. However, we still have significant
concerns particularly with respect to cost, competitiveness and the process involved.

What kind of economy we’ll have for the next several decades will be determined in the next
couple months here in Wisconsin and in Washington D.C. Given the enormous consequences of
our work on this Task Force, we are puzzled by what appears to be a “take it or leave it”
proposal where we have a week or two to digest and then vote. Due to problems with the
modeling and the speed at which this Task Force is moving, nobody has a good idea of: a) how
much this strawman proposal will cost, b) what kind of economic benefit will be created, and c)
how much Greenhouse gas emissions will be reduced in Wisconsin. Task Force members should
demand a better understanding of these questions before approving the strawman. Is there any
harm in getting a better handle on the consequences before pressing forward?

There is no commercially available control technology to eliminate or store carbon at this time.
When we created regulations to fight Acid Rain, there was readily available, off the shelf
technology. Even completely switching our fleet to natural gas would not get Wisconsin to the
carbon reduction goals outlined in the Executive Order. Under the strawman, Wisconsin would
be investing billions over the next several decades to obtain emission reductions that are sure to
be negated by China alone within only a few weeks.

Industrial customers need reliable electricity at affordable rates. We are primarily concerned
about economic survival. Quite frankly, we are struggling to absorb the rising costs of fuel and
the existing mandates and controls. We are going to see billions in increases just from the costs
of the current 10% RPS in addition to CAIR, CAMR, etc. These existing costs will mean
double digit increases. The question is – do we add fuel to that fire by going above and beyond
the coming federal standards?

There will be 1,000 jobs lost just in the paper industry alone this year. There are over 1,000 jobs
lost in the automotive sector recently. Other big name, major manufacturers have announced
thousands of job cuts this year. With oil well over $100 a barrel and gasoline topping $4 a
gallon, we are urging extreme caution with the strawman recommendations.

WIEG has the greatest concerns with respect to the cap & trade proposal and the expanded RPS.

Cap & Trade: The stated preference of the strawman was for a federal cap & trade system,
with a second choice of a regional cap & trade. WIEG believes a regional cap & trade should
not be an option as it is a policy doomed to failure. In order to have a successful market, there
needs to be economies of scale for buyers and sellers. WIEG prefers an international program
for cap & trade, or at minimum, a federal program.

Expanded Renewable Portfolio Standard: WIEG has consistently opposed this proposal due
to the overall cost and infeasibility. Some Wisconsin utilities are finding the current 10% RPS to
be problematic. We have some utilities building wind when their demand requirements are met
for the next decade. Traditional regulatory arguments of cost, need and even the priorities statute
are trumped right now for the existing 10% RPS. No one has a good idea how much the new
25% RPS proposal will cost, but it is probably safe bet that it would be a billion annually using
Page 4 of 28 existing technology. WIEG would propose having the PSC open a study docket on the issue (we
have several others from this Task Force already in progress) to get a better understanding of the
costs and benefits of this proposal.

If further study of an expanded RPS is unacceptable, then we respectfully ask that the Act 141
offramps be strengthened. For example, the current language calls for delays if there are
“unreasonable” rate impacts. This could be replaced with specific percentages - such as 1%
increases.

WIEG has other concerns with the strawman proposal including the impact on rates of greatly
expanding Public Benefits program. Further, the strawman also includes vague language that
appears to support decoupling, feebates and environmental dispatch of generation – initiatives
that industrial customers generally oppose.

WIEG appreciates some of the initiatives included in the strawman proposal that were designed
to mitigate costs. These proposals include: levelization of cost recovery, securitization
programs, crediting of early action, expansion of self-directed programs and industrial boiler
replacement. We have a lot of questions as many of these initiatives are brand new. WIEG
would like to get more details on how these ideas would work in practice and make suggested
refinements. We feel these are positive efforts and that they were made in good faith by the Co-
Chairs. However, these positive elements are most likely far outweighed by the massive new
costs that will be incurred with other new programs like the 25% RPS, cap & trade and others.

These are very real costs that will have very real economic consequences. Rising energy costs
have already provided a significant incentive to reduce energy consumption. Sales of electricity
to industrial consumers have been flat or declining in Wisconsin in recent years meaning there is
greater energy conservation but also the loss of high paying jobs. The policies under discussion
place Wisconsin at great risk of demand destruction and worse -- an economic death spiral.

Wisconsin is number one in the world for papermaking. We are number two per capita for per
capita employment in manufacturing. And we are among the highest states for the percentage of
coal used to generate electricity. Therefore our current prosperity as a state is directly
threatened. If our high paying manufacturing jobs are lost to countries that care far less about the
environment, then we have collectively failed in our vision of creating a better economy with
better air quality.

Todd Stuart
Executive Director
Wisconsin Industrial Energy Group, Inc.
Madison, WI


From:
Sent: Thursday, June 19, 2008 8:22 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: Task Force Report ...
Page 5 of 28 Membership:

We are against nuclear power as an option. I support the continued moratorium on the building of
a multi-billion dollar nuclear power plant creating nuclear waste with a life span of 10,000 years. How
dare we!

Do not include our voluntary extra monthly utility dollars supporting renewable sourcing in the 10%
renewable energy requirement of the utilities.

The Safe Climate Act was locked in committee in the presently configured WI State Legislature. Are we
waiting for a Federal Government Law? If Wisconsin does not decrease its CO emissions, Wisconsin 2
deserves its future. Nature bats last and Nature owns the stadium. While you wait and see, please read
a few books on the subject.

Could we hedge our bets and devise incentives for decreasing global warming gases?

The words are “Renewable Energy”. Keep the definition.

Thank you,
Karen and John Cleary
Appleton, WI


From: red judy
Sent: Thursday, June 19, 2008 8:32 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: Global Warming
It is time to take action. As a member of the Democratic Resolution committee we submitted a
resolution that would have established criteria to bring emission levels down by more than
twenty percent by 2012. Unfortunately that resolution was combined and merged with additional
global warming resolutions and the emission levels were omitted.
It is most urgent that we set the most stringent standards and take immediate action to reduce ing pollution by the most intense rigorous and expeditious methods possible.

It is paramount that we keep the inflexible standards set by the Global Warming Task Force,
follow those guidelines which must contain:
• Numeric global warming reduction targets based on the most current, sound science
• Mandatory early action to reduce global warming pollution
• Home-grown clean energy and energy efficiency solutions to address global warming in
Wisconsin
These rigid established standards are equivalent to the guidelines set by European countries
which have goals of forty percent reduction in twelve years. We must do as well to be a nation
that is a leader. We must set high standards if we are to have a global existence for our children
and grandchildren.
Adopting the standards established by the Global Warming Task Force is overriding dominant
principal.
Page 6 of 28

From: Dave Dahlberg
Sent: Thursday, June 19, 2008 10:09 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: Comments on the GTFGW Strawman Proposal
Dear Co-Chairs Tia Nelson and Roy Thilly;

North Central Power Co., Inc. (NCP) has several comments regarding the recommendations of the
Governor’s Task Force on Global Warming. I had written previously to Mike Swenson, Senator Plale, and
Rep. Montgomery regarding my concerns (see attached letter) about the rules implemented under
Wisconsin Act 141 and their effect on the ratepayers of NCP. We are even more concerned for our
customers after reading the recommendations of the GTFGW. With your permission, NCP will lay out our
issues again.

Background on North Central Power
NCP is a small investor-owned utility serving electric customers in southern Sawyer and northern Rusk
counties. Because of the rural make-up of our customer base, we have the second highest rates for an
investor-owned utility in the state. As you know, Wisconsin Act 141 requires that all utilities in the state
increase the portion of energy sales derived from renewable sources such that 10% of all energy sold in
the state comes from renewables by 2015. Each utility developed a baseline percentage of renewables
based on energy sales in 2001-2003. The statewide average was 4% renewables and, as a result, each
utility must increase their renewable portfolio by 6% to achieve a statewide average of 10% by 2015.
NCP has the highest baseline renewable percentage of any investor-owned utility in the state at 33%,
which means that NCP must have 39% of their sales come from renewable energy by the year 2015.
NCP does not own any renewable generation facilities so 100% of our renewables are purchased under
power purchase agreements. Because of the small size of NCP, any construction of a significant
renewable generation facility would be very costly to our customers.

NCP has incurred additional expense because of the vagaries of hydro production. Because of drought
conditions in 2007, NCP had to buy Renewable Resource Credits (RRC’s) in the market to cover over
25% of its renewable requirements.

Renewable Requirements
Under the proposed changes to Act 141 outlined in the Co-Chair’s ‘strawman proposal’, all utilities would
need to increase their renewables such that the energy sales are comprised of 13% renewables by 2015,
20% renewables by 2020, and 25% renewables by 2025. The strawman proposal also states that all
other aspects of Act 141 that are not specifically addressed would remain the same. This implies that the
mechanism for achieving these percentages would not change and all utilities would be required to
increase their renewables by the same percentage from their baseline. This means that NCP would need
to raise theiwables by a total of 21% (from the present 4% statewide average to a 25% statewide
average) along with the other utilities and would ultimately need to have 54% of their energy sales come
from renewable energy by the year 2025. This would be a significant burden for NCP’s 4,000 customers
to bear. NCP would suggest that the proposed changes incorporate an exemption such that any utility
with renewables already exceeding 25% is not required to increase their portofolio. This exemption could
be limited to any utility whose sales are less than 5% of the statewide total energy sales.

Baseline Calculations
Act 141 and subsequent discussions defined the method for calculating each utility’s baseline percentage
of renewables. Act 141 did not, however, address what happens to the baseline if generation that is part
of the calculation is retired, has reduced output, or is no longer under contract. NCP’s baseline
renewables come primarily from hydro generation that is owned by Flambeau Hydro Company. This
power purchase agreement expires on April 30, 2010. NCP will make every effort to renew this contract
but there is no guarantee. Additionally, one of these units, the Winter hydroelectric project, was recently
Page 7 of 28 relicensed at the Federal Energy Regulatory Commission. The license now includes new minimum flow
requirements that will reduce the energy output by over 25%. Because Act 141 has no provision for
adjusting the baseline percentage, NCP’s customers face the cost of replacing this renewable energy
source in addition to increasing their percentage to 54%. NCP would suggest that the proposed changes
include a provision for adjusting the baseline renewables percentage when plants are retired, have
reduced output, or a power purchase agreement expires.

Summary
In summary, NCP agrees with the majority of the recommendations of the Task Force, as long as the
costs for implementing these changes are not detrimental to the economy and livelihood of NCP’s
customers and the citizens of Wisconsin. However, we have grave concerns regarding the cost impacts
of requiring NCP customers to purchase 54% of their energy from renewable resources. NCP serves less
than 0.2% of the investor-owned utility customers in the state and so any additional costs are heavy on
such a small group. We recognize that Act 141 has provisions for utilities to apply for exemption from the
renewable requirements (the Off-ramp). However, the Off-ramp process is very vague and untested, and
the process may be costly to undertake for our ratepayers. Therefore, we respectfully recommend that
any utility (perhaps only those utilities with less than 5% of total Wisconsin energy sales) be exempt from
the target requirements if their renewables already exceed 25% of sales. We also recommend that
provisions for adjusting the baseline renewables percentage be included. Thank you for your time.

I would be happy to meet with any Task Force members or the appropriate committee to discuss this
further.

http://dnr.wi.gov/environmentprotect/gtfgw/comments/PDF/Dahlberg_comments.pdf [PDF 22KB]

Dave Dahlberg
Vice President
North Central Power Co., Inc.
Grantsburg, WI


From: Terry Hansen
Sent: Thursday, June 19, 2008 10:27 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: Your efforts are of great importance
Thank you for all your efforts on the urgent issue of global warming. State and local action is of
great necessity since our federal government fails to act. I understand that compromise is a part
of politics, but I am deeply concerned that compromise here and elsewhere will dilute policy to
the point where it is ineffective.

I know that many are worried that measures to prevent global warming may ruin the economy. I
am concerned that global warming may ruin the planet, and our economy depends upon the
planet and upon nature.

Nicholas Stern, former chief economist of the World Bank has stated that climate change is “the
biggest market failure that the world has ever seen.” He said this because costs are being
transferred to others – huge costs are being shifted to future generations.

In her book Field Notes from a Catastrophe: Man, Nature and Climate Change, Elizabeth
Kolbert writes, “To refuse to act, on the grounds that still more study is needed or that
Page 8 of 28 meaningful efforts are too costly, or that they impose an unfair burden on industrialized nations,
is not to put off the consequences, but to rush toward them.”

Sincerely,
Terry Hansen
Franklin, WI


From: tallen
Sent: Thursday, June 19, 2008 11:59 AM
To: DNR GLOBALWARM TF COMMENTS
Subject: Global warming
Global warming is out of control don’t bankrupt Wisconsin.

Tom Allen
Brown Deer, WI


From: Mark Dahlberg
Sent: Thursday, June 19, 2008 12:11 PM
To: DNR GLOBALWARM TF COMMENTS
Subject: Governor's Task Force on Global Warming Comments
Dear Co-Chairs Tia Nelson and Roy Thilly;

Northwestern Wisconsin Electric Co., Inc. (NWE) has several comments regarding the recommendations
of the Governor’s Task Force on Global Warming (GTFGW). We are very concerned for our customers
after reading the recommendations of the GTFGW. With your permission, I will lay out the reasons for
this concern.

Background on Northwestern Wisconsin Electric
NWE is a small investor-owned utility serving electric customers in Burnett and Polk counties. Because of
the rural make-up of our customer base, our rates are among the highest for investor-owned utilities in
the state. As you know, Wisconsin Act 141 requires that all utilities in the state increase the portion of
energy sales derived from renewable sources such that 10% of all energy sold in the state comes from
renewables by 2015. Each utility developed a baseline percentage of renewables based on energy sales
in 2001-2003. The statewide average was 4% renewables and, as a result, each utility must increase
their renewable portfolio by 6% to achieve a statewide average of 10% by 2015. NWE has the third
highest baseline renewable percentage of any investor-owned utility in the state at 12.48%, which means
that NWE must have 18.48% of their sales come from renewable energy by the year 2015. NWE does
not own any renewable generation facilities so 100% of our renewables are purchased under power
purchase agreements. Because of the small size of NWE, any construction of a significant renewable
generation facility would be very costly to our customers.

Renewable Requirements
Under the proposed changes to Act 141 outlined in the Co-Chair’s ‘strawman proposal’, all utilities would
need to increase their renewables such that the energy sales are comprised of 13% renewables by 2015,
20% renewables by 2020, and 25% renewables by 2025. The strawman proposal also states that all
other aspects of Act 141 that are not specifically addressed would remain the same. This implies that the
mechanism for achieving these percentages would not change and all utilities would be required to
increase their renewables by the same percentage from their baseline. This means that NWE would
need to raise their renewables by a total of 21% (from the present 4% statewide average to a 25%
Page 9 of 28 statewide average) along with the other utilities and would ultimately need to have 33.48% of their energy
sales come from renewable energy by the year 2025. This would be a significant burden for NWE’s
12,000 customers to bear. NWE would suggest that the proposed changes incorporate an exemption
such that any utility with renewables exceeding 25% is not required to increase their portofolio. This
exemption could be limited to any utility whose sales are less than 5% of the statewide total energy sales.

Baseline Calculations
Act 141 and subsequent discussions defined the method for calculating each utility’s baseline percentage
of renewables. Act 141 did not, however, address what happens to the baseline if generation that is part
of the calculation is retired, has reduced output, or is no longer under contract. NWE’s baseline
renewables come primarily from hydro generation that is owned by Flambeau Hydro Company. This
power purchase agreement expires on April 30, 2010. NWE will make every effort to renew this contract
but there is no guarantee. Because Act 141 has no provision for adjusting the baseline percentage,
NWE’s customers face the cost of replacing this renewable energy source if a contract can not be
renewed in addition to increasing their percentage to 33.48%. NWE would suggest that the proposed
changes include a provision for adjusting the baseline renewables percentage when plants are retired,
have reduced output, or a power purchase agreement expires.

Summary
In summary, NWE agrees with the majority of the recommendations of the Task Force, as long as the
costs for implementing these changes are not detrimental to the economy and livelihood of NWE’s
customers and the citizens of Wisconsin. However, we have grave concerns regarding the cost impacts
of requiring NWE customers to purchase 33.48% of their energy from renewable resources. NWE serves
less than 0.5% of the utility customers in the state and so any additional costs are heavy on such a small
group. We recognize that Act 141 has provisions for utilities to apply for exemption from the renewable
requirements (the Off-ramp). However, the Off-ramp process is very vague and untested, and the
process may be costly to undertake for our ratepayers. Therefore, we respectfully recommend that any
utility (perhaps only those utilities with less than 5% of total Wisconsin energy sales) be exempt from the
target requirements if their renewables exceed 25% of sales. We also recommend that provisions for
adjusting the baseline renewables percentage be included. Thank you for your time.

I would be happy to meet with any Task Force members or the appropriate committee to discuss this
further.


Mark F. Dahlberg
President
Northwestern Wisconsin Electric Co., Inc.
Grantsburg, WI


From: Dan Kohler
Sent: Thursday, June 19, 2008 1:05 PM
To: DNR GLOBALWARM TF COMMENTS
Subject: Comments on 'strawman' proposal
Co‐Chairs Tia Nelson and Roy Thilly, 
 
Thank you for your tireless work on the global warming task force.  And thank you for the opportunity to 
submit comments on the ‘strawman’ proposal.  The attached comments are from Wisconsin 
Environment, Wisconsin League of Conservation Voters, Midwest Environmental Advocates, Wisconsin 
PSR and Environmental Law & Policy Center.   
Page 10 of 28