Michigan Public Service Commission
P.O. Box 30221
Lansing, MI 48909

Mr. Bryce Feighner, Acting Permit Section Supervisor
DEQ, Air Quality Division
P.O. Box 30260,
Lansing, Michigan, 48909-7760.

Re:      MPSC Case No. U-16000, PTI # 317-07, Electric Generation Alternatives Analysis for the Proposed Wolverine Coal-Fired Power Plant – Rogers City, Michigan

Dear Executive Secretary Kunkle and Acting Permit Section Supervisor Feighner

This letter provides initial comments on the Alternatives Analysis for the Wolverine Rogers City Proposed Coal Plant (“Proposed Coal Plant”).  Based on this analysis submitted, the Draft Permit for the Proposed Coal Plant must be denied.  The information provided does not establish the need for the plant or the lack of alternatives to the plant.  To the contrary, the publicly available evidence does demonstrate that there is no need for this, or any, new coal-fired power plant in the State of Michigan.  Electric demand in the State of Michigan is level or even decreasing.  Due to this deficient Alternatives Analysis, the PSC and DEQ should reject the Alternatives Analysis as deficient and recommend the denial of the permit or, alternatively, suspend the public comment period and renotice the comment period when an adequate Alternatives Analysis is submitted.

First, all data that is publicly available shows that there is no need for this plant.  Wolverine own public documents indicate that they would be overbuilding this plant by at least 300 MW.  Wolverine itself has acknowledged that it does not have a need for the full 600 MW of generating capacity, but intends to use one of the 300 MW boilers as redundancy for the other boiler.[1] In addition, projections for electric demand in the state show there is no need for any new plant.  The 21st Century Energy Plan “low load growth” scenario approximated the current Michigan electric sales outlook. It indicates no new coal plant is needed until 2021.[2] Wolverine’s current customer base is greater than 80% residential. Consumers Energy (which overlaps much of Wolverine’s service area) forecasts a decline in their residential electric sales 2008 – 2018.[3] Reasons Consumers Energy gives for this decline are: declining Michigan population through 2016, central air conditioning saturation is maturing, new air conditioners are more efficient, energy efficiency, load response and demand response at peak.[4]  The Energy Information Administration 2009 forecast for US electric sales growth (2007 – 2030) has been revised down to only 1% a year and coal generation is expected to decline.[5] 

Second, there are cleaner alternatives.  Even when demand starts growing again, increased demand can easily be met with cleaner alternatives.  Consumers Energy’s and Detroit Edison’s recent Energy Optimization and Renewable Energy cases before the PSC documented the ready availability and cost competitiveness of renewable energy and energy efficiency in the state. Detroit Edison is contracting for wind energy at a price of $108/kWh. Energy efficiency, in turn, can be delivered at ½ to ⅓ of the cost per kilowatt hour compared to electricity from coal. The combination of renewable energy and energy efficiency have a lower life-cycle cost than a new coal plant.  Numerous parties testified in the PSC Energy Optimization and Renewable Energy proceedings that additional sources of available and affordable renewable energy are being overlooked or omitted.  Finally, under MEPA, an alternative can be rejected on the basis of cost only if it is prohibitively expensive; the fact that an alternative may substantially increase production costs is not enough to reject that alternative.  A similar standard should apply under the Clean Air Act Section 165 alternatives requirement.  Consequently, Wolverine has not demonstrated any basis for rejecting cleaner alternatives.   

In sum, there is no need for this plant in the State of Michigan, the Alternatives Analysis must be rejected as inadequate, and the Proposed Permit must be denied.

Sincerely,