Fact-checking the WE Energies Letter to Ixonia Residents
In response to Save Ixonia’s successful campaign to inform the community on the dangers of LNG, on August 20, WE Energies sent a marketing letter to the residents of Ixonia to help us understand why their Category 1 Hazardous material holding facility for LNG might in fact be good for the town.
We were disheartened at first, being that this letter riddled with half-truths might be the first piece of information that many Ixonia residents read about the facility. We also take no pride in questioning another organization’s integrity (even if they have a financial incentive to be dishonest), but the impact of letting their statements go unchallenged is too great of a risk for our community to bear.
So we have spent the past two weeks researching and fact-checking the statements from their marketing letter. We consulted with LNG experts, read WE Energies’s own Public Safety Commission (PSC) submissions, reviewed dozens of governmental studies, and examined firefighting standards.
Below is a section-by-section fact check of their letter:
In June, we submitted to the Public Service Commission of Wisconsin our proposal to build a liqueﬁed natural gas (LNG) facility in the town of Ixonia. The project is needed to enhance the reliability of natural gas supply throughout southeastern Wisconsin, provide signiﬁcant customer savings and allow greater independence from interstate pipelines. This investment in the community also would provide an additional source of revenue for the town of Ixonia and Jefferson County.
The half-truth: “The project is needed to enhance the reliability of natural gas supply throughout southeastern Wisconsin, provide signiﬁcant customer savings and allow greater independence from interstate pipelines.”
The whole truth: This project will not directly serve Ixonia customers. Most in Ixonia are not on natural gas, particularly those who are most close to the facility. The WE Energies customers in Ixonia will not benefit from the storage in their own backyard. Source: “The LNG facility near Ixonia will serve customers in WG’s greater Milwaukee service area by way of the Ixonia lateral.” (PSC REF#: 393071
confidential, PSC REF#: 393072 public)
Since our ﬁling, we have had the opportunity to talk with many residents and present our plans at the Ixonia Plan Commission meeting in July. Enclosed for your review is an overview of the project. In addition, we would like to update you about our proposal and address some of the misinformation that has surfaced.
The half-truth: “We have had the opportunity to talk with many residents.”
The whole truth: While we don’t have the ability to fact-check this in its entirety, through Save Ixonia, we have been able to interact with over 600 residents from Ixonia. None of them had spoken with WE Energies, and the majority of them had not received a letter prior to their August 20 marketing letter. We assume the “many” residents WE Energies is referring to is the five town board members who have had several closed discussions with them.
Safety is always our ﬁrst priority
We have operated similar facilities for over 50 years without an incident. While the type of facility we are proposing is common across the country, this project will incorporate state-of-the-art safety and monitoring features that minimize risks to the public and exceed federal, state, local and industry standards. In addition to regular inspections and 24/7 monitoring, specialized instrumentation is used to detect any potential issues and allow activation of the emergency shutdown system.
The half-truth: “We have operated similar facilities for over 50 years without an incident.”
The whole truth: It depends on what the definition of “incident” is for WE Energies. The Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) list a series of incidents resulting in over $1 billion in environmental and safety fines in the last twenty years.
The proposed project is being sited on a property that provides a setback from the community in accordance with the Department of Transportation and Pipeline and Hazardous Materials Safety Administration requirements to keep any incident contained to our property. We anticipate the project will take up approximately 25 acres of the approximate 165-acre site. This allows for enhanced security and safety measures, including berms, a tank containment area and fencing.
The half-truth: “The proposed project is being sited on property that provides a setback from the community in accordance with the Department of Transportation and Pipeline and Hazardous Materials Safety Administration requirements.”
The whole truth: In order for this statement to be true, all safety components would need to have been verified. However, in documents dated June 1, 2020 sent by WE Energies to the Public Service it states that safety limits will be calculated as part of the engineering design. Being the design has not yet been completed, WE Energies statement that appropriate setbacks have been provided cannot be true.
The PSC documents state that the nearest residence is located 520 feet from the proposed facility. Section 18.104.22.168 identified the Vapor Dispersion Limits for the proposed LNG facility have not yet been calculated, but will be done as part of the final design. Based on this information, it is not possible for WE Energies to guarantee that the proposed setbacks will actually protect those residents nearest the site from vapor dispersion during plant operation.
A study on LNG dispersion indicates that an unrestricted LNG vapor cloud has the ability to travel through air at a speed of 5.91 feet/second. Using a vapor barrier device slows the speed down to 1.84 feet/second. This data is critical in determining what duration of release it will take for vapors to reach the nearest home, thus providing the potential for explosion. In the event of an LNG release of 282 seconds, or 4.7 minutes, the vapor cloud would reach the nearest home located 520 feet away. While the facility may be constructed with the most advanced electrical safety response devices, there is no guarantee that these devices will work 100% of the time and stop a vapor release in time to protect residents.
NFPA Standard 1710 requires emergency responders to reach 90% of all incidents within 5 minutes and 20 seconds. In the event of a plant malfunction of a safety device resulting in a vapor release the cloud will have traveled over 588 feet before emergency crews are even on site thus overtaking the nearest home. Each second thereafter the cloud is moving another 1.84 feet on its way to the next structure. A gas release of 35 minutes, the cloud reaches WI State Highway 16 and begins to overtake Ixonia Elementary School. Based on this information there is no guarantee that the setbacks being used by WE Energies to construct the LNG facility will contain all potential disasters within the property it is constructed upon.
The half-truth: “We anticipate the project will take up approximately 25 acres of the approximate 165-acre site.”
The whole truth: In the WE Energies initial proposal to the PSC, the 165-acre site offered a strategic advantage to the company because “the project allows for expansion of capacities and thus provides a physical price hedge against future interstate pipeline expansion costs.” The expectation is that while the project is only taking up 25 acres now, there is an option to expand that acreage. (PSC REF#:392400)
We want to correct the inaccurate information being shared that there is a predetermined “evacuation zone” that could potentially impact properties a mile or more away. This is not true. Our footprint has been appropriately sized to provide a safety setback at our site. As is standard with all of our energy infrastructure, including other LNG facilities, we take steps to protect our neighbors and our employees in all we do.
The half-truth: “We want to correct the inaccurate information being shared that there is a predetermined “evacuation zone” that could potentially impact properties a mile or more away.”
The whole truth: This is true! But it’s an odd truth to extol, since what this is really saying is WE Energies has not completed any analysis to determine an evacuation zone.
There are environmental aspects that would affect the travel of a vapor cloud during release. Wind speed and direction being the two most influential. The exact evacuation needs would need to be determined in the field at the time of the incident as this is the only way to incorporate all of the environmental unknowns
However, using the best industry benchmarks of recent LNG facility explosions and governmental studies would leave us to believe that the lethal zone for an incident would be between .75 - 1.5 miles (certainly enough to “catastrophically impact” Ixonia Elementary and many residential homes), and the evacuation zone possibly up to two miles.
In addition, this facility will be staffed 24/7, and our personnel will coordinate with local emergency responders to provide education about our operations and any specialized training needed.
The half-truth: “Our personnel will coordinate with local emergency responders to provide education about our operations and any specialized training needed.”
The whole truth: Even for fire departments eight times larger than Ixonia’s volunteer-only fire department, fighting LNG fires is extremely difficult and requires state-of-the-art equipment which we can’t afford. The consensus among many professional firefighting organizations say that the risk of fighting LNG is often too great and the better strategy is to just let the fires burn until it goes out. Even with the “specialized training” for our local emergency responders, the fact is that an LNG fire would decimate the local area and there is nothing we could do about it.
Benefits to the community
Our company and our facilities have co-existed and played an important role in the development of thriving communities throughout Wisconsin for decades. This investment provides ﬁnancial beneﬁts to your community, while also allowing continued agricultural land use around the site. The Town of lxonia is expected to receive more than $500,000 annually and Jefferson County more than $1 million annually in shared revenue payments from the State of Wisconsin. This money can be used by the local municipalities as they deem appropriate.
The half-truth: “The Town of lxonia is expected to receive more than $500,000 annually and Jefferson County more than $1 million annually in shared revenue payments from the State of Wisconsin.”
The whole truth: The key term in this statement is that this money is from the State of Wisconsin, not WE Energies. (In other words, it is a tax on WE Energies which is theirs not to promise our town.)
The Wisconsin Counties Utility Tax Association is a Madison-based lobbying organization created for only one purpose: to protect the utility tax from the many forces constantly attempting to reduce the tax, eliminate it or grab all the money.
Every two years, the state proposes to reallocate all or part of this tax revenue for its own general fund to pay for state operations and programs. The state can do this and the potential for it happening is increasing. This year may pose a heightened threat with the state projecting a budget deficit of $250 million.
In addition, Wisconsin Energy has been among the top 30 companies in the entire United States which have spent money on lobbying to lower taxes. These are the same taxes they are promising Ixonia would get as a benefit of housing their Category 1 Hazardous material holding facility for LNG.
Environmental commitment and corporate responsibility
We have a long-standing commitment to protecting the environment and being a responsible corporate citizen. As part of the permitting process through the Wisconsin Department of Natural Resources, an environmental review will be completed prior to design and construction. Preliminary environmental surveys already indicate that the site is suitable for the proposed facility.
The half-truth: “We have a long-standing commitment to protecting the environment and being a responsible corporate citizen.”
The whole truth: Actions speak louder than words. “A long-standing commitment to protecting the environment” is easy to say, but their almost $1 billion in environmental fines tells us that their commitment means nothing. Fines this large are accrued by either being negligent, or flippant, or ignorant, but definitely not committed to health and safety.
Primary Offense Type Year Agency Penalty Amount
environmental violation 2003 EPA $623,200,000
environmental violation 2013 EPA $307,200,000
environmental violation 2014 EPA (*) $3,200,000
environmental violation 2016 EPA (*) $1,200,000
environmental violation 2008 WI-AG $475,000
environmental violation 2008 EPA $225,000
environmental violation 2013 WI-AG $100,000
environmental violation 2013 EPA $80,000
environmental violation 2013 WI-AG $80,000
environmental violation 2004 EPA $65,000
environmental violation 2004 WI-AG $65,000
environmental violation 2014 EPA $50,000
environmental violation 2014 EPA $50,000
environmental violation 2014 WI-AG $50,000
Road conditions and trafﬁc impact
We will complete a trafﬁc study and work with local authorities to develop preferred routes for any truck trafﬁc during construction. We also will work with the town to minimize any trafﬁc impacts and will repair any road damage as a result of construction activities. During normal operation of the facility, we anticipate minimal truck trafﬁc.
The half-truth: “During normal operation of the facility, we anticipate minimal truck trafﬁc.”
The whole truth: Although there may be minimal truck traffic, our local Ixonia traffic may be impacted during the construction of the project. For a much smaller utility project in 2016 they reduced traffic down to only one lane for four months. In Ixonia where some of our roads are only one lane, this could severely impact traffic for over a year.
As you can see, WEC has been neither fully transparent nor honest in this process of dealing with Ixonia residents and officials. They have both the money to hire expensive marketing, lobbying, and PR firms to sell such projects to communities like ours. WEC executives are trying to make huge money off of our hardworking backs, and leave our community to deal with the consequences. Such projects take advantage of small town officials and people believing that we will not have the education or background to withstand such pressures. Do you think that such facilities are put into wealthy communities and neighborhoods around the country? Do you think that these lobbyists, executives, and marketers live near a LNG facility? We cannot let these lies overshadow the values and history that this community is built on, we must work together to Save ixonia: www.saveixonia.com