1. Reliable, state-of-the-art technology: White Pine Electric is a clean burning (natural gas) facility, fully converted from coal in 2014. All coal-related equipment was removed.  White Pine’s turbine was then completely refurbished in 2015 ensuring full function and reliability through 2025


2. White Pine Electric has been 100% reliable when called upon by MISO to operate. The 2015 outage was preplanned and approved to support the turbine refurbishment (overhaul). White Pine operates at peak capacity 20 megawatt net – 17 megawatt output when called upon.


3. The White Pine SSR is a short term “bridge” to ensure electrical reliability for the citizens of Michigan. All parties were clear that the need of the White Pine SSR would be for 3-5 years while other investments into power generation were complete, and the ATC Power Line to the U.P would be complete (neither of which have begun to date). And if neither of these options came online, White Pine could stay active until the new electrical generator comes on stream expected in 2020.


4. Reduced Electrical Reliability:  Premature closure of the White Pine SSR puts people and businesses at serious risk, due to a significant reduction in electrical reliability for 72 to 74% of the Western Upper Peninsula. Simply, this means that during any power outage, the Western U.P. will be without power until whatever failed or malfunctioned is fixed. This could be up to three weeks without electricity.


5. Although the ATC Proposal, which includes the plan of using radial configuration when necessary, leaves the electrical reliability strong in the Eastern U.P., ATC has ignored the shortfalls of this plan when the Western U.P. is taken into consideration. This proposal places approximately ¾ of the households and businesses of the Western U.P. at serious risk. Risks include absolutely no electricity for up to 3 weeks either in the peak of summer, affecting fridges and freezers, or winter, affecting heating of homes. Western U.P. businesses and households would need to secure/purchase their own backup generators.


6. Both UPPCO & MAE have misled the public, citing “cost” as the rationale for closing White Pine.  This, while benefiting from a unilaterally from a 4.47% rate increase,  equating  to $4,647,975 revenue for UPPCO, a significantly larger burden on ratepayers than the $2.50 per meter charge for White Pine’s service as the cost effective “emergency backup generator” for the Western U.P.   Without a doubt, any outage lasting more than two day would result in a cost greater than the $7M attributable to the federally-approved White Pine SSR.


7. Most importantly, the human element has been completely ignored throughout the ATC radial configuration plan and MISO’s subsequent evaluation. Although closing White Pine technically meets the “planning criteria” and “acceptable load loss”, it further guarantees a reduction in electrical reliability thereby marginalizing the employers and families of the Western U.P. A load loss up to three weeks would be disastrous for this region.


8. This really is a classic case of Regulatory Manipulation vs. the Human Element. Sound familiar?


Conclusion: Energy reliability in the Western U.P.—as in the rest of the state of Michigan—is best served via redundant systems to minimize the risk of planned and unplanned power outages.  The White Pine SSR should be allowed to continue operating until either new generation or ATC’s transmission upgrades are completed, as originally planned and approved by regulatory agencies.