A massive sucking machine…coming soon to Lake Michigan?

Not if Clean Wisconsin has anything to say about it.

Derek Scheer

Should energy production in Wisconsin be approved at any cost? Should we sacrifice our human health and the stability of our ecosystems in pursuit of traditional energy solutions when other, safer options exist? Should a brand new coal plant be regulated as if it were an old "grandfathered" facility, with fewer restrictions placed upon it? The answers to these questions are 'no' but We Energies and the Wisconsin Department of Natural Resources (DNR) don't want to hear it.

Open-cycle Cooling System
We Energies (WE) in the Elm Road Generating Station (ERGS) application has proposed an open-cycle (or once-through) cooling system. Open-cycle water-cooling withdraws massive amounts of water from the water source.

The DNR's approval of the open-cycle cooling system is based on faulty earlier decisions by the DNR and the Public Service Commission (PSC), namely, that the proposed pulverized coal-fired power plant is simply an addition to the existing power plant. Based on the determination that this is an existing plant, it is WE's contention that open-cycle cooling represents the Best Available Technology based on a recent EPA guidance on rule 316(b).

In this case, the ERGS facility will suck out more than two billion gallons of water a day for cooling from Lake Michigan; roughly the same amount of water the city of Chicago uses daily. There will be serious problems associated with this withdrawal:

Ecosystem Disturbance
The use of surface water as cooling water has dire consequences for the organisms in Lake Michigan. Aquatic animal populations will be damaged as animals are sucked into the cooling system and basically cooked (called entrainment) or when they are pinned to intake screens (called impingement).

Lake Michigan already suffers from a declining ecosystem stemming from years of damage. The intake structure will kill a significant number of fish, larvae and eggs thereby changing the lake's ecosystem in southeastern Wisconsin. Diporeia, a critical source of food for marine life in Lake Michigan, is already at critically low levels and a Wisconsin favorite, the Yellow Perch, has seen a large decline in its populations. WE's proposal would create a huge sucking machine causing even more problems around Oak Creek's shoreline.

On New York's Hudson River, for example, a cluster of power plants were found to reduce almost 80% of certain fish species populations in certain years. According to the Clean Air Task Force, annual U.S. recreational and commercial fish losses from power plant intakes are estimated at tens of millions of dollars per year.

Heating Lake Michigan (Thermal Discharge)
WE has failed to fully investigate the impacts thermal discharge will have on the Lake. Wisconsin DNR is currently unable to write a permit that effectively addresses thermal pollution – a direct violation of the Clean Water Act.

When the heated cooling water is discharged from the plant back into Lake Michigan the temperature of the water increases around this outflow and causes associated problems to a portion of the lake. The ERGS proposal would put 2.2 billion gallons of water a day back into Lake Michigan significantly warmer than it was taken out. According to Lake Michigan experts, this thermal discharge might serve as a refuge for unwanted exotic species, become an attractant to certain fish, and might create a situation where fish acclimate to warmer temperatures and cannot adjust to sudden declines in water temperature. This thermal discharge will undoubtedly cause changes to Lake Michigan's ecosystem.

Releasing of Toxic Chemicals
Toxic chemicals, including mercury, will be released to the lake as a result of this proposed plant. Once digested (from people eating fish caught in the lake), mercury causes brain, nerve tissue and kidney damage in humans. Like all Wisconsin lakes and rivers, Lake Michigan suffers from elevated mercury levels, which has led to restrictions on fish consumption and health advisories for pregnant women, women of child-bearing age, and children. The main reason the proposed plant's mercury emissions are within EPA regulations is because they will be diluting the mercury into the 2.2 billion gallons of water the cooling system uses.

Alternative Cooling-systems Were Never Considered
The environmentally disastrous open-cycle cooling system is not the only option, and preferable and practicable options have been swept aside. A closed-cycle cooling system would require the siphoning-off of 90% less water than the current proposal. This equates to reducing the amount of water drawn from Lake Michigan by a whopping 1.98 billion gallons each day. Doing so would protect wetlands, the Lake Michigan bluffs and innumerable Lake Michigan organisms. Also poignant to note is closed-cycle cooling would allow better decision making in relation to the needed location of this plant, by nature of removing the main reason for locating it next to Lake Michigan – open-cycle cooling system requirements.

While the proposed plant would be the sixth-largest coal-burning power plant in the country and the largest construction project in Wisconsin history, the Wisconsin DNR and U.S. EPA have allowed WE to circumvent the regulations designed to protect precious marine life and wetlands because of last-minute changes to 316 (b) regulations.

While the water-intake structures would be entirely new construction, they will mysteriously be governed under the relaxed standards for existing facilities. Consistent with its abhorrent pattern of quietly rolling back environmental protections, the EPA modified their definition of "new facility" to exclude plants like this one. Changes to this important regulation happened in behind closed-door meetings between EPA and WE with no public comment period granted to discuss the changes to the 316 (b) regulations. An EPA scientist has voiced concern that WE is not following the proper regulatory procedures regarding 316 (b) changes. There are numerous lawsuits against the EPA over this exact 316 (b) language. With the lack of public comment and input on establishing 316 (b) as well as pending lawsuits over the regulations, it is obvious why we are concerned about how these lax regulations by the EPA will affect us directly through the ERGS.

Combining open-cycle cooling with the quantity of water that the ERGS would use is a recipe for disaster for the portion of Lake Michigan in southeastern Wisconsin. Ignoring other, safer cooling options in building a new facility and then having that facility be regulated as if it were an old one is a crime. Clean Wisconsin and many other organizations like us will continue to oppose We Energy's plan and the DNR's approval of it.