There were few surprises in the reply briefs filed April 6 in response to the Public Service Commission of Wisconsin’s (PSCW) hearings on the proposed Alma-La Crosse CapX2020 line (Docket No: 05-CE-136).
With one exception, the reply briefs were filed by project opponents who, in the main, restated the positions expressed in their initial briefs filed in March.
Northern States Power Company-Wisconsin filed a reply brief on behalf of itself and coapplicants, Dairyland Power Cooperative, and WPPI, that restated the companies’ support for the line. “None of the issues raised in other parties’ briefs diminishes the need for the project or precludes selection of any of the eight routes under consideration,” the applicants stated in their brief, which asked the PSCW to grant a certificate of public convenience and necessity (CPCN) for the project as proposed.
Project opponent Clean Wisconsin changed its approach from its initial brief, shifting from its original assertion that the “PSCW does not have enough information to grant the project a [CPCN] under Wisconsin statutes,” to the statement that “regardless of route, this project is not justified on the basis of either local or regional need, [and] its cost is excessive relative to its purported benefits.”
While the Citizens Utility Board (CUB) began its reply brief by stating that it would “endeavor not to repeat points it already made in its initial brief,” it restated its previous assertions that the project was “unreasonably excessive for local needs” in the La Crosse area, and does not provide regional benefits. The CUB also repeated its request that the PSCW instruct the applicants to study a 345-kV/161-kV hybrid alternative that was discussed during the hearings.
As with their initial brief, NoCapX2020 and Citizens Energy Task Force filed a joint reply brief in which the two groups restated their position that the project is excessive. The groups also claimed that the project would benefit energy markets, but said it “does not provide benefits to the state of Wisconsin ratepayers sufficient to justify approval of the project.”
In its reply brief, the Wisconsin Department of Transportation (WisDOT) restated its position that it has “specific federal and state statutory authority and obligation to protect its scenic easements along Great River Road,” an alignment preferred by the applicants. However, WisDOT restated that there were “four viable and buildable routes [that] comply with WisDOT’s required execution of its authority and obligations and are, as stated by [the applicants] themselves, viable and buildable.”
The PSCW is required to take action on the application for a CPCN by June 4.