No Data Center Gas Plants

Comments on the Red Oak Ridge (9837-CE-100) and Foundry Ridge (9835-CE-100) gas plants

I am writing to you to ask that you do two things in the CPCN dockets for the Red Oak Ridge (9837-CE-100) and Foundry Ridge (9835-CE-100) gas plants. I’d like you to 1.) deny CPCN approvals for the gas plants as they would be detrimental to Wisconsinites and our environment and 2.) if you do grant the CPCNs, ensure that Wisconsinites will not bear any additional costs. In the recent WEC Very Large Customer docket, as well as the applications for both gas plants, it is clear that the demand and need for these plants is being driven by power-hungry data centers. Commissioner Nieto said in the tariff docket, “We need to do everything within our jurisdiction to make sure data center customers will pay their own way, fully and transparently, and other customers will be held harmless.” If you do grant the CPCN, please ensure that, as a bespoke resource for a large data center customer, the CPCN includes a requirement that the data center customer pay the full cost of the plant and its operations, or that you deny We Energies’ application to buy the plant. Foundry Ridge is “estimated to use up to approximately 38.3 gpm of water (up to 55,152 gallons per day) at maximum load” and the Red Oak Ridge will use a maximum withdrawal rate to be 335,000 gallons/day. In 2024, thermoelectric power production was already responsible for 73 percent of the state’s water usage. Wisconsin’s clean water provides drinking water to millions of people and support critical ecosystems brimming with native species. These gas plants would undermine our ability to stop the worst impacts of climate change. The World Health Organization, the United Nations, and Governor Evers’ Task Force on Climate Change have made it clear that we must move off of fossil fuels in order to prevent the worst impacts of climate change. A report by the United States Senate Committee on the Budget found that Big Oil companies have laid out a plan to to position natural gas as a “bridge fuel” between coal and cleaner, renewable energy, while enmeshing natural gas in the U.S. energy economy for the long-term; seek to portray natural gas as a green, climate-friendly fuel, while internally acknowledging that there is significant scientific evidence that the lifecycle emissions from gas are as bad as coal and are incompatible with scientific emissions reduction targets. Allowing Red Oak Ridge and Foundry Ridge to be built will secure Big Oil’s plan to lock in gas infrastructure, undermining our ability to stop the worst impacts of climate change. These gas plants will make people sick, especially young children in nearby communities. Methane gas use has been shown to increase health harms such as cardiovascular and respiratory diseases, as well as cancer, kidney, and neurodevelopmental disorders. Fossil fuel power plants have been directly linked to higher rates of asthma, negative outcomes for fetus and infant health, and early death. A report by the Climate Solutions for Health Lab at the University of Wisconsin-Madison found that particulate matter would increase due to the plants and that “these elevated PM2.5 concentrations could cause 118 excess premature deaths across the United States.” Ozone pollution is already an issue, as the region is already a serious nonattainment area for ozone pollution. Wisconsin's Energy Priorities Law requires that the Public Service Commission prioritize non-fossil fuel projects if there are cleaner alternatives that would be cost-effective and technically feasible. Several reliable and cheaper options should be maximized, including energy efficiency, demand response, and renewable energy. Granting the CPCNs for these plants without substantively considering these alternatives directly contradicts the Energy Priorities Law.