Environmental Assessment for the 

Nemadji Trail Energy Center 

Project

Dairyland Power Cooperative

USDA Rural Utilities Service

October 2020
Environmental Assessment for the 

Nemadji Trail Energy Center 

Project

Dairyland Power Cooperative

Rural Utilities Service

October 2020
Nemadji Trail Energy Center Table of Contents

Rural Utilities Service TOC-1 Dairyland Power Cooperative

TABLE OF CONTENTS

Page No.

1.0 PURPOSE AND NEED ..................................................................................... 1-1

1.1 Project Description........................................................................................................... 1-1

1.2 Profile of Dairyland Power Cooperative.......................................................................... 1-3

1.3 Profile of Minnesota Power ............................................................................................. 1-4

1.4 Purpose and Need for the Proposed Project..................................................................... 1-4

1.4.1 Demand Forecast ................................................................................................. 1-6

1.4.2 Purpose and Need for Federal Action.................................................................. 1-9

2.0 ALTERNATIVES............................................................................................... 2-1

2.1 Introduction...................................................................................................................... 2-1

2.1.1 Siting Study Objectives........................................................................................ 2-2

2.1.2 Siting Study Area................................................................................................. 2-3

2.1.3 Siting Study Methodology ................................................................................... 2-3

2.1.4 Preliminary Infrastructure Screening for Preliminary Site Areas........................ 2-5

2.1.5 Desktop Screening for Preliminary Site Areas.................................................... 2-5

2.1.6 Candidate Site Areas............................................................................................ 2-6

2.1.7 Candidate Site Areas Evaluation ......................................................................... 2-6

2.2 Siting Study Conclusions............................................................................................... 2-19

2.3 NTEC Site Selection...................................................................................................... 2-19

2.3.1 Identification of NTEC Study Area ................................................................... 2-20

2.3.2 Identification of Preferred Site Areas within NTEC Study Area ...................... 2-20

2.3.3 Selection of Preferred NTEC Site...................................................................... 2-24

2.3.4 Alternative Generation Site Identification ......................................................... 2-26

2.4 Linear Infrastructure Alternatives.................................................................................. 2-31

2.4.1 Macro-corridor Study Area Identification ......................................................... 2-31

2.4.2 Resource Data Collection .................................................................................. 2-33

2.4.3 Identification of Alternative Macro-Corridors................................................... 2-33

2.4.4 Alternative Macro-Corridors ............................................................................. 2-35

2.4.5 Substation Siting Alternatives............................................................................ 2-42

2.5 Identification of the Project Alternatives for Evaluation............................................... 2-46

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES.... 3-1

3.1 Air Quality ....................................................................................................................... 3-2

3.1.1 Affected Environment.......................................................................................... 3-2

3.1.2 Environmental Consequences.............................................................................. 3-3

3.1.3 Mitigation........................................................................................................... 3-12

3.2 Biological Resources ..................................................................................................... 3-13

3.2.1 Affected Environment........................................................................................ 3-13

3.2.2 Environmental Consequences............................................................................ 3-17

3.2.3 Mitigation........................................................................................................... 3-20

3.3 Cultural Resources......................................................................................................... 3-23
Nemadji Trail Energy Center Table of Contents

Rural Utilities Service TOC-2 Dairyland Power Cooperative

3.3.1 Affected Environment........................................................................................ 3-23

3.3.2 Environmental Consequences............................................................................ 3-30

3.3.3 Mitigation........................................................................................................... 3-39

3.4 Geology and Soils.......................................................................................................... 3-39

3.4.1 Affected Environment........................................................................................ 3-39

3.4.2 Environmental Consequences............................................................................ 3-40

3.4.3 Mitigation........................................................................................................... 3-43

3.5 Infrastructure, Transportation, Public Health and Safety, and Waste Management...... 3-44

3.5.1 Affected Environment........................................................................................ 3-44

3.5.2 Environmental Consequences............................................................................ 3-47

3.5.3 Mitigation Measures .......................................................................................... 3-55

3.6 Land Use, Recreation, Farmland, and Coastal Facilities............................................... 3-57

3.6.1 Affected Environment........................................................................................ 3-57

3.6.2 Environmental Consequences............................................................................ 3-60

3.6.3 Mitigation Measures .......................................................................................... 3-64

3.7 Noise .............................................................................................................................. 3-65

3.7.1 Affected Environment........................................................................................ 3-65

3.7.2 Environmental Consequences............................................................................ 3-66

3.7.3 Mitigation Measures .......................................................................................... 3-68

3.8 Socioeconomics and Environmental Justice.................................................................. 3-69

3.8.1 Affected Environment........................................................................................ 3-69

3.8.2 Environmental Consequences............................................................................ 3-75

3.8.3 Mitigation Measures .......................................................................................... 3-77

3.9 Visual Resources............................................................................................................ 3-77

3.9.1 Affected Environment........................................................................................ 3-77

3.9.2 Environmental Consequences............................................................................ 3-78

3.9.3 Mitigation Measures .......................................................................................... 3-79

3.10 Water Resources ............................................................................................................ 3-80

3.10.1 Affected Environment........................................................................................ 3-80

3.10.2 Environmental Consequences............................................................................ 3-86

3.10.3 Mitigation Measures ........................................................................................ 3-102

3.11 Summary of Impacts.................................................................................................... 3-103

4.0 CUMULATIVE IMPACTS.................................................................................. 4-1

4.1 Past, Present, and Reasonably Foreseeable Future Actions............................................. 4-1

4.2 Cumulative Impacts by Resource .................................................................................... 4-1

4.1.1 Air Quality ........................................................................................................... 4-1

4.1.2 Biological Resources ........................................................................................... 4-4

4.1.3 Cultural Resources............................................................................................... 4-6

4.1.4 Geology and Soils................................................................................................ 4-7

4.1.5 Infrastructure, Transportation, Public Health, and Waste Management.............. 4-8

4.1.6 Land Use ............................................................................................................ 4-11

4.1.7 Noise .................................................................................................................. 4-14

4.1.8 Socioeconomics and Environmental Justice...................................................... 4-14

4.1.9 Visual Resources................................................................................................ 4-16

4.1.10 Water Resources ................................................................................................ 4-17
Nemadji Trail Energy Center Table of Contents

Rural Utilities Service TOC-3 Dairyland Power Cooperative

5.0 SUMMARY OF MITIGATION............................................................................ 5-1

5.1 Air Quality ....................................................................................................................... 5-1

5.2 Biological Resources ....................................................................................................... 5-2

5.3 Cultural Resources........................................................................................................... 5-4

5.4 Geology and Soils............................................................................................................ 5-4

5.5 Infrastructure, Transportation, Public Health, and Waste Management.......................... 5-5

5.6 Land Use .......................................................................................................................... 5-7

5.7 Noise ................................................................................................................................ 5-8

5.8 Socioeconomics and Environmental Justice.................................................................... 5-9

5.9 Visual Resources.............................................................................................................. 5-9

5.10 Water Resources .............................................................................................................. 5-9

6.0 COORDINATION, CONSULTATION, AND CORRESPONDENCE.................. 6-1

6.1 Public Involvement .......................................................................................................... 6-1

6.2 Agency Consultation........................................................................................................ 6-2

6.2.1 Federal Agency Coordination.............................................................................. 6-4

6.2.2 Tribal Coordination.............................................................................................. 6-6

6.2.3 State Agency Coordination.................................................................................. 6-7

6.2.4 Local Coordination ............................................................................................ 6-13

6.3 Locations for Public Review of EA............................................................................... 6-14

7.0 REFERENCES.................................................................................................. 7-1

8.0 LIST OF PREPARERS ..................................................................................... 8-1

APPENDIX A – AGENCY CORRESPONDENCE

APPENDIX B – BIOLOGICAL RESOURCES

APPENDIX C – HISTORIC RESOURCES

APPENDIX D – FARMLAND

APPENDIX E – WILD AND SCENIC RIVERS MAP

APPENDIX F – FEMA FLOODPLAIN MAPS

APPENDIX G – NWI AND WATER FEATURES MAPS

APPENDIX H – PUBLIC INVOLVEMENT MATERIALS
Nemadji Trail Energy Center Table of Contents

Rural Utilities Service TOC-4 Dairyland Power Cooperative

LIST OF TABLES

Page No.

Table 2-1: Candidate Site Area Evaluation Criteria ................................................................ 2-8

Table 2-2: Candidate Site Scores........................................................................................... 2-13

Table 2-3: Transmission Load Flow Analysis Scores for Preferred Sites............................. 2-16

Table 2-4: Preferred Site Scores............................................................................................ 2-17

Table 2-5: Category Weights for Sensitivity Analyses for Preferred Sites........................... 2-18

Table 2-6: Preferred Site Area Rankings for Sensitivity Analyses ....................................... 2-19

Table 3-1: Distance from Project Sites to Class I Areas.......................................................... 3-2

Table 3-2: NAAQS Modeling Results..................................................................................... 3-8

Table 3-3: PSD Class II Increment Modeling Results........................................................... 3-10

Table 3-4: Class I Modeled Screening Impacts and Class I Significant Impact Level.......... 3-10

Table 3-5: Threatened and Endangered Species in Douglas County..................................... 3-15

Table 3-6: WHS Digital Geographic Data Sets Summary..................................................... 3-25

Table 3-7: ASI Polygons in Archaeological Study Area ....................................................... 3-26

Table 3-8: ARI Polygons in Archaeological Study Area ...................................................... 3-26

Table 3-9: AHI Resources In the Archaeological Study Area............................................... 3-27

Table 3-10: ARI Polygons Near the Nemadji River Site......................................................... 3-31

Table 3-11: ASI Polygons Near the Nemadji River Site ......................................................... 3-31

Table 3-12: Archaeological Report Inventory (ARI) Polygons Near the Hill Avenue 

Site........................................................................................................................ 3-32

Table 3-13: ARI Polygons Near the Eastern Transmission Route .......................................... 3-32

Table 3-14: ASI Polygons Near the Eastern Transmission Route........................................... 3-33

Table 3-15: Archaeological Report Inventory (ARI) Polygons Near the Western 

Transmission Route.............................................................................................. 3-34

Table 3-16: Archaeological Sites Inventory (ASI) Polygons Near the Western 

Transmission Route.............................................................................................. 3-35

Table 3-17: Archaeological Report Inventory (ARI) Polygons Near the Hill Avenue

Site Route ............................................................................................................. 3-36

Table 3-18: Archaeological Sites Inventory (ASI) Polygons Near the Hill Avenue Site 

Route .................................................................................................................... 3-36

Table 3-19: ARI Polygons Near the Superior Switching Station ............................................ 3-37

Table 3-20: ASIs Near the Superior Switching Station........................................................... 3-37

Table 3-21: ARI Polygons Near the Parkland Switching Station............................................ 3-37

Table 3-22: ASIs Near the Switching Station.......................................................................... 3-38

Table 3-23: Soil Information Study Area ................................................................................ 3-40

Table 3-24: Typical Chemicals Stored During Construction .................................................. 3-53

Table 3-25: Typical Chemicals Stored for Operation.............................................................. 3-54

Table 3-26: EPA Noise Levels Identified to Protect Public Health and Welfare.................... 3-67

Table 3-27: Sound Modeling Results at the Nemadji River Site with and without 

Mitigation............................................................................................................. 3-68

Table 3-28: Sound Modeling Results at the Hill Avenue Site with and without 

Mitigation............................................................................................................. 3-68

Table 3-29: Population Trends ................................................................................................ 3-70
Nemadji Trail Energy Center Table of Contents

Rural Utilities Service TOC-5 Dairyland Power Cooperative

Table 3-30: Population Characteristics – City of Superior and Census Tracts near 

Project................................................................................................................... 3-72

Table 3-31: Employment Characteristics ................................................................................ 3-73

Table 3-32: Total Minority and Poverty near Project.............................................................. 3-74

Table 3-33: High Capacity Groundwater Users near the Nemadji River Site......................... 3-83

Table 3-34: Waterways Identified Within 0.5 Mile of Nemadji River Site (Total 

Length - 3,246 feet).............................................................................................. 3-86

Table 3-35: Waterways Identified Within 0.5 Mile of Hill Avenue Site (Total Length -

3,025 feet)............................................................................................................. 3-87

Table 3-36: Waterways Identified Within the Eastern Transmission Route Wetland 

Survey Area (Total Length - 1,686 feet).............................................................. 3-87

Table 3-37: Waterways Identified Within the Western Transmission Route Wetland 

Survey Area (Total Length - 1,883 feet).............................................................. 3-88

Table 3-38: Waterways Identified Within the Hill Avenue Site Route Wetland Survey 

Area (Total Length - 407 feet) ............................................................................. 3-88

Table 3-39: Waterways Proposed to Be Crossed for Construction ......................................... 3-89

Table 3-40: Wetlands Identified at Nemadji River Site (Total Area - 7.4 acres).................... 3-91

Table 3-41: Wetlands Identified at Hill Avenue Site (Total Area - 75.591 acres).................. 3-91

Table 3-42: Wetlands Identified Within the Eastern Transmission Route Wetland 

Survey Area (Total Area - 49.51 acres) ............................................................... 3-92

Table 3-43: Wetlands Identified Within the Western Transmission Route Wetland 

Survey Area (Total Area - 86.43 acres) ............................................................... 3-94

Table 3-44: Wetlands Identified Within the Hill Avenue Site Route Wetland Survey 

Area (Total Area - 18.66 acres)............................................................................ 3-96

Table 3-45: Wastewater Constituent Concentrations .............................................................. 3-99

Table 3-46: Variable User Charges for Industrial Connections to the City of Superior 

Sewer System ..................................................................................................... 3-100

Table 3-47: Summary of Potential Impacts........................................................................... 3-104

Table 4-1: Summary of Cumulative Impacts Assessment....................................................... 4-2

Table 4-2: Summary of Habitat Loss....................................................................................... 4-5

Table 6-1: Open House and RUS Formal Scoping Meeting Attendance ................................ 6-2

Table 6-2: Summary of Comments by Topic .......................................................................... 6-2

Table 6-3: Open House and RUS Formal Scoping Meeting Attendance ................................ 6-3

Table 6-4: Federal Permits and Approvals .............................................................................. 6-5

Table 6-5: State Permits and Approvals ................................................................................ 6-11

Table 6-6: Anticipated Local Permits and Approvals ........................................................... 6-14

Table 6-7: List of Library Locations...................................................................................... 6-15
Nemadji Trail Energy Center Table of Contents

Rural Utilities Service TOC-6 Dairyland Power Cooperative

LIST OF FIGURES

Page No.

Figure 1-1: Nemadji Trail Energy Center................................................................................. 1-2

Figure 1-2: Dairyland Power Cooperative Member Systems’ Service Area ............................ 1-3

Figure 1-3: Minnesota Power and Dairyland Cooperative Service Areas................................ 1-5

Figure 1-4: Dairyland Class A Energy Sales Composition 2015.............................................. 1-6

Figure 1-5: Dairyland Power Cooperative Energy Requirement Composition ........................ 1-7

Figure 1-6: Dairyland Load and Capability .............................................................................. 1-8

Figure 2-1: Midcontinent ISO Region/Siting Study Area......................................................... 2-4

Figure 2-2: Candidate Site Rankings ...................................................................................... 2-14

Figure 2-3: Preferred Site Rankings........................................................................................ 2-18

Figure 2-4: NTEC Study Area ................................................................................................ 2-21

Figure 2-5: Alternative Generation Sites ................................................................................ 2-28

Figure 2-6: Study Area............................................................................................................ 2-32

Figure 2-7: Macro-Corridors................................................................................................... 2-34

Figure 2-8: Study Area and Landcover within the Macro-Corridors...................................... 2-36

Figure 2-9: Government and Primary Land Ownership within the Macro-Corridors ............ 2-37

Figure 2-10: Conservation and Recreation Areas within the Macro-Corridors........................ 2-38

Figure 2-11: Transportation and Utilities within the Macro-Corridors .................................... 2-39

Figure 2-12: Farmland of Statewide Importance within the Macro-Corridors......................... 2-40

Figure 2-13: Water Resources within the Macro-Corridors ..................................................... 2-41

Figure 2-14: Project Alternatives.............................................................................................. 2-47

Figure 3-1: Study Area Soils................................................................................................... 3-41

Figure 3-2: Facility Registry Service Sites in Study Area ...................................................... 3-48

Figure 3-3: Census Tracts in Study Area ................................................................................ 3-71

Figure 3-4: Nemadji Trail Energy Center Simulation............................................................. 3-80
Nemadji Trail Energy Center List of Abbreviations

Rural Utilities Service i Dairyland Power Cooperative

LIST OF ABBREVIATIONS

Abbreviation Term/Phrase/Name

ACHP Advisory Council on Historic Preservation

ADID advanced delineation and identification studies

Agl above ground level

APE Area of Potential Effect

AHI Architecture and History Inventory

ARI Archaeological Report Inventory

ASI Archaeological Sites Inventory

ATC American Transmission Company

BACT Best Available Control Technology

BGEPA Bald and Golden Eagle Protection Act

BNSF Burlington Northern Santa Fe

Burns & McDonnell Burns & McDonnell Engineering Company, Inc.

CA Certificate of Authority

Caucus Wisconsin Legislative Black Caucus

CBRA Coastal Barrier Resources Act

CBRS Coastal Barrier Resources System

C&I Commercial & Industrial

CCGT combined cycle gas turbine

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CPCN Certificate of Public Convenience and Necessity 
Nemadji Trail Energy Center List of Abbreviations

Rural Utilities Service ii Dairyland Power Cooperative

Abbreviation Term/Phrase/Name

Dairyland Dairyland Power Cooperative

DATCP Department of Agriculture, Trade and Consumer Protection

DNE Does Not Exceed

EMF Electric and magnetic fields

EPA United States Environmental Protection Agency

ERDC Engineer Research and Development Center

FAA Federal Aviation Administration

FEMA Federal Emergency Management Agency

FIRM Flood Rate Insurance Maps

FRS Facility Registry Service

GHGs greenhouse gases

GIS Geographic Information Systems

GPS Global Positioning System

GTG gas turbine generator

HDPE high-density polyethylene

HRSG heat recovery steam generator

IEC International Electrotechnical Commission

IPaC Information for Planning and Consultation

kV Kilovolt

kV/m kilovolt per meter

Large C&I Large Commercial and Industrial

LiDAR Light Detection and Ranging
Nemadji Trail Energy Center List of Abbreviations

Rural Utilities Service iii Dairyland Power Cooperative

Abbreviation Term/Phrase/Name

LMP locational marginal price

mG Milligauss

MBTA Migratory Bird Treaty Act

MGD Millions of gallons per day

MISO Midcontinent Independent System Operator

MP Minnesota Power

MW Megawatt

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NESHAP National Emission Standards for Hazardous Air Pollutants and Maximum 

Achievable Control Technology

NHD National Hydrography Dataset

NLEB Northern long-eared bat

NOI Notice of Intent

NPDES National Pollutant Discharge Elimination System

NPH Notice of Presumed Hazard

NR Natural Resources

NRCO National Renewable Cooperative Organization

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NSPS New Source Performance Standards

NTEC Nemadji Trail Energy Center

NTEC Study Area Overlap of Dairyland and MP service territories, suitable for alternative 

site location
Nemadji Trail Energy Center List of Abbreviations

Rural Utilities Service iv Dairyland Power Cooperative

Abbreviation Term/Phrase/Name

NWI National Wetland Inventory

OHWM Ordinary High Water Mark

OSHA Occupational Safety and Health Administration

Owners Dairyland Power Cooperative and Minnesota Power

PAH polycyclic aromatic hydrocarbons

Plant NTEC plant

PM Particulate matter

PRMR Planning Reserve Margin Requirement

Project One on one combined cycle natural gas turbine

PSCW Public Service Commission of Wisconsin

PSD Prevention of Significant Deterioration

RCRA Resource Conservation and Recovery Act

RFP Request for Proposal

ROW right of way

RUS Rural Utilities Service

SAMP special area management plans

SF6 sulfur hexafluoride

Siting Study Site selection study to identify and evaluate potential Project sites

SMEC Southern Minnesota Energy Cooperative

SPCC Spill Prevention, Control, and Countermeasures

SSE South Shore Energy, LLC.

SSURGO Soil Survey Geographic Database
Nemadji Trail Energy Center List of Abbreviations

Rural Utilities Service v Dairyland Power Cooperative

Abbreviation Term/Phrase/Name

STG steam turbine generator

SWIS special wetland inventory studies

SWL&P Superior Water Light & Power

TCP Traditional Cultural Property

TSD treatment, storage, and disposal

UCAP Unforced Capacity

USACE United States Army Corps of Engineers

USCB United States Census Bureau

USDA United States Department of Agriculture

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

U.S.C. United States Code

WAC Wisconsin Administrative Code

WCMP Wisconsin Coastal Management Program

WDNR Wisconsin Department of Natural Resources

WisDOT Wisconsin Department of Transportation

WPDES Wisconsin Pollutant Discharge Elimination System

WRAM Wetland Rapid Assessment Methodology

WWI Wisconsin Wetland Inventory
Nemadji Trail Energy Center Purpose and Need

Rural Utilities Service 1-1 Dairyland Power Cooperative

1.0 PURPOSE AND NEED

Dairyland Power Cooperative (Dairyland) is proposing to participate with South Shore Energy, LLC 

(SSE), a subsidiary of ALLETE, Inc. (together the “Owners”), an operating division of ALLETE Inc., in a 

one on one combined cycle natural gas turbine (CCGT) with an in-service date in 2025 (the Project). 

Dairyland has conducted an extensive round of resource planning activities culminating in a Sustainable 

Generation Plan. A key component of the plan is a share1 of a highly efficient, state of the art, one on one 

combined cycle plant named the Nemadji Trail Energy Center (NTEC). The NTEC facility is a

cornerstone enabling Dairyland’s Sustainable Generation Plan which is weighted very heavily with 

renewable sources. This Project will be designed to be highly flexible and capable of operating in peaking 

and intermediate load modes to fulfill energy and capacity requirements for Dairyland, alongside its 

renewable additions. 

Dairyland participated in several renewable requests for proposals (RFPs) in conjunction with the 

National Renewable Cooperative Organization (NRCO) and conducted its own RFP in support of finding 

the best available dispatchable capacity and energy source to mesh with Dairyland’s extensive reliance on 

intermittent renewable projects. In addition, Dairyland along with the other potential NTEC participants 

conducted an extensive siting and self-build technology assessment, which helped inform the best options 

for further consideration in the Dairyland plan.

During the planning process Dairyland conducted numerous presentations and discussions with its

distribution cooperative managers, Dairyland Board Committees and the Dairyland Board of Directors. In 

addition, Dairyland conducted a strategic planning process with its Board of Directors and Cooperative 

Managers culminating in the Dairyland Strategic Plan. A cornerstone of Dairyland’s strategic plan is the 

Sustainable Generation Plan of which the Project is a significant part. Dairyland’s Board having evaluated 

the resource options available to Dairyland authorized the pursuit of a share of the Project at its January 

2016 board meeting.

1.1 Project Description

The Project includes a fired output of approximately 625 MW 1x1 CCGT electric generating unit 

consisting of one H-Class gas turbine generator, one heat recovery steam generator (HRSG) with duct

firing, and one steam turbine generator (STG). NTEC will burn natural gas with the capability to be 

retrofitted to use fuel oil as a backup fuel. NTEC will be between approximately 26 acres to 75 acres, 

1 Dairyland’s share in the facility will ultimately be determined by the size of the turbine selected and the additional 

generation needs Dairyland identifies.
Nemadji Trail Energy Center Purpose and Need

Rural Utilities Service 1-2 Dairyland Power Cooperative

depending on the site selected for the Project, and would be located near Superior, Wisconsin. A general 

simulation of the Project is shown in Figure 1-1. The Project will be cooled using dry cooling by finned 

heat exchangers. The Project will include a 345-kilovolt (kV) transmission line tap at the existing 

Arrowhead to Stone Lake Transmission Line as well as a switching station located southeast of the 

potential plant sites. This transmission line will be between approximately 3.7 miles to 7.1 miles, 

depending on the site selected and constructed.

Figure 1-1: Nemadji Trail Energy Center 

For a dry cooling heat rejection system, cooling would be provided by the following:

• A large finned heat exchanger with fans (fin fan heat exchanger) moving ambient air across the 

outside of the tubes and fins (like a radiator in a car) would be used to reject the energy in the 

steam leaving the steam turbine. 

• A separate finned heat exchanger with fans would be used to reject the energy in the heat transfer 

fluid used in the auxiliary cooling loop. This auxiliary cooling loop is used for miscellaneous 

plant cooling duties such as lube oil cooling, compressed air cooling, generator cooling, and other 

similar duties associated with heat generated in equipment during operation. 
Nemadji Trail Energy Center Purpose and Need

Rural Utilities Service 1-3 Dairyland Power Cooperative

• A third finned heat exchanger with fans may also be included to cool the blown down water from 

the HRSG to acceptable limits for the process wastewater discharge for the facility. 

1.2 Profile of Dairyland Power Cooperative

Dairyland is a generation and transmission cooperative and was formed to produce and deliver electricity 

to rural electric cooperatives in 1941. Dairyland, headquartered in La Crosse, Wisconsin, serves

approximately 600,000 customers in four states – Wisconsin, Minnesota, Iowa, and Illinois (Dairyland, 

2019; Figure 1-2). Dairyland has 24 member cooperative systems (Wisconsin – 18 members; Iowa – 2 

members; Minnesota – 2 members; Illinois – 1 member; Iowa/Minnesota – 1 member) and serves 17 

municipal customers in the Upper Midwest (Wisconsin, Iowa, and Minnesota) with a service area that 

encompasses 62 counties in four states.

Figure 1-2: Dairyland Power Cooperative Member Systems’ Service Area

Dairyland has or contracts for generating resources to produce electricity with coal, natural gas, hydro 

dams, wind, landfill gas, and solar. Dairyland delivers electricity over 3,200 miles of transmission lines 
Nemadji Trail Energy Center Purpose and Need

Rural Utilities Service 1-4 Dairyland Power Cooperative

and 300 substations located throughout the system’s 44,500 square mile service area. Dairyland and its 

members are part of a larger group of Touchstone Energy Cooperatives that work together to find 

innovative energy solutions and educate consumers about energy efficiency, safety, renewable energy, the 

cooperative business model, and the value of electricity. 

1.3 Profile of Minnesota Power

Although not a rural electric cooperative and therefore not regulated by the U.S. Department of 

Agriculture (USDA), Rural Utilities Service (RUS), SSE will be a Project participant with Dairyland for 

construction of the Project. SSE is a subsidiary of ALLETE, Inc., and Minnesota Power (MP) is a 

division of ALLETE, Inc. In initial studies, MP was a partner. Since the conclusion of initial studies, SSE 

has taken over as Owner with Dairyland. Since MP was a Project partner during initial studies, MP is 

described in the following sections related to the siting study for the Project.

MP serves approximately 145,000 residential and commercial customers, and serves 16 municipalities 

(MP, 2017; Figure 1-3). MP is a transmission-owning member of the Midcontinent Independent System 

Operator, Inc. (MISO) and participates in the organized markets under the MISO tariff.

1.4 Purpose and Need for the Proposed Project

Dairyland’s vision is to exceed member expectations as a safe, sustainable premier power cooperative.

The objective is to provide safe and reliable power to its members at a low and reasonable cost. From a 

resource planning perspective, Dairyland needs to secure capacity and energy resources that meet the 

system peak and demand for electricity for the years to come. This includes accounting for required 

system reserve margins in MISO and covering Dairyland’s forecasted losses to ensure reliability and 

resource adequacy during unforeseen events such as uncertainties in extreme weather and forced outages 

for generators. Dairyland needs to add new generating capacity to the current resource mix to serve 

growing load within the service territories that the member cooperatives serve (including the newly 

acquired member cooperative load of approximately 175 MW, in Minnesota and Illinois, from Interstate 

Power and Light) and to replace generation that was recently retired. The addition of the NTEC will also 

enable Dairyland to facilitate the addition of new renewable electricity sources to the power portfolio by 

complementing their intermittent nature.
COPYRIGHT © 2020 BURNS & McDONNELL ENGINEERING COMPANY, INC.

Source: Dairyland Power Cooperative, Minnesota Power, ESRI Issued: 2/12/2020

Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\1_3_ServiceAreas.mxd kasamuelson 2/12/2020

Service Layer Credits: Sources: Esri, Garmin, USGS, NPS

NORTH

85 42.5 0 85

Miles

Figure 1-3

Dairyland Power Cooperative

and Minnesota Power Service Areas

Nemadji Trail Energy Center

Douglas County, WI

State

Boundary

Service Territory

Dairyland Power Cooperative

Minnesota Power
Nemadji Trail Energy Center Purpose and Need

Rural Utilities Service 1-6 Dairyland Power Cooperative

1.4.1 Demand Forecast

Dairyland provides wholesale electric service to 24-member distribution cooperatives and classifies sales 

to member cooperatives as Class A. Dairyland’s energy sales increased at an average of 1.1% annually 

over the last five years, while Dairyland’s peak grew at an average of 1.8% over the same period, due 

mainly to the growth of the Large Commercial and Industrial (C&I) class. Energy for the Large C&I class 

has grown from 15.0% (2011-2015) of Class A sales five years ago to 17.0% of Class A sales now. While 

the Large C&I class is growing at a higher rate, Dairyland’s residential customers still account for 61.3% 

of Class A energy sales and 80.7% of customers (Figure 1-4). In addition to providing service to its 

member distribution cooperatives, Dairyland provides wholesale service to 17 municipal utilities and 

classifies the sales as Class D (3 of the 17 are served by Dairyland indirectly through Class A 

cooperatives).

Dairyland conducts load forecasting on a 2-year cycle, with the last available forecast for the Board of 

Directors’ January 2016 decision to participate in NTEC, finalized in the fall of 2014. Dairyland’s energy 

and peak were forecasted to grow at a 1.2% and 1.0% annual rate, respectively, over the 20 years included 

in the 2014 Load Forecast. Figure 1-4 provides Dairyland’s energy sales composition by class as of 2015.

Figure 1-4: Dairyland Class A Energy Sales Composition 2015

Figure 1-5 shows the breakdown of forecasted energy requirements through 2033 from the 2014 Load 

Forecast. Historical values are included from 1999 through 2013. Forecast numbers are based on the 

historical numbers through 2013. As can be seen in Figure 1-5, there is an increase in energy sales in 
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Rural Utilities Service 1-7 Dairyland Power Cooperative

2023. Dairyland currently serves roughly half of the total requirements of Jo Carroll Energy, an Illinois 

distribution cooperative member. Dairyland will serve a much larger portion of Jo Carroll’s total 

requirement from the Dairyland portfolio in 2023 and beyond. This increase in forecasted load and 

capacity requirement is included in Figure 1-6. (During 2018 an agreement was reached to bring the JoCarroll load into the Dairyland system early, resulting in Dairyland now serving this new portion of Jo 

Carroll’s load, this change is not reflected in Figure 1-5).

Figure 1-5: Dairyland Power Cooperative Energy Requirement Composition 

0

1000000

2000000

3000000

4000000

5000000

6000000

7000000

8000000 MWh

Dairyland Power Cooperative Energy Requirements Composition

DPC Class D Municipals Class A Other (Seasonal, Irrrigation, Street and Highway, Public) Class A C&I Class A Residential
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Figure 1-6: Dairyland Load and Capability

Southern Minnesota Energy Cooperative (SMEC), a group of distribution cooperatives in Minnesota 

(including three members of Dairyland), has acquired Interstate Power and Light’s Minnesota retail load.

This load is not included in the load forecast in Figure 1-4 as the addition of the load was not approved 

and complete at the time of the forecast. Dairyland is forecasting to serve additional SMEC load starting 

in 2025. Accordingly, the forecasted load is included in the load and capability Figure 1-6 starting in 

2025.

Figure 1-6 shows Dairyland’s forecasted unforced capacity (UCAP) accredited resource capacity and 

forecasted Planning Reserve Margin Requirement (PRMR) using the 2016 MISO capacity construct. 

Dairyland owns or has under contract 987.5 megawatts (MW) of accredited capacity in MISO as of the 

2016 load and capability assessment. In addition to load and capability Dairyland evaluates its need for 

energy to hedge its members’ loads in the MISO market. Dairyland will rely on NTEC along with its 

additional intermittent renewable contracts to provide additional energy demands that are coming into the 

system as well as help replace the intermediate energy supply retired from its resource portfolio. 

Dairyland is using a balanced and pragmatic approach to add natural gas generation and renewable 

generation to meet the future load obligations and continue to diversify the Dairyland generation 

portfolio. Dairyland intends to use short-term capacity contracts to purchase or sell any short-term 
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capacity deficit or surplus. Dairyland is currently meeting the planning reserve margin requirements and 

all of the renewable energy obligations and plans to do so in the future. As noted previously, the addition 

of the NTEC will facilitate Dairyland adding additional renewables by complementing their intermittent 

nature.

1.4.2 Purpose and Need for Federal Action

Dairyland intends to request financial assistance from RUS under its Electric Loan Program for its share 

of the Project. The Secretary of Agriculture is authorized under the Rural Electrification Act of 1936, as 

amended) to provide Federal loans for rural electrification and telecommunication development (7 U.S.C. 

901 et seq.). Specifically, RUS is authorized to provide funding or loan guarantees for the construction of 

electric distribution and transmission, as well as generation facilities, to provide and to improve electric 

service in rural areas of the U.S.

The proposed Federal Action is for RUS to decide whether to provide financial assistance to Dairyland 

for Dairyland’s portion of the Project.
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Rural Utilities Service 2-1 Dairyland Power Cooperative

2.0 ALTERNATIVES

2.1 Introduction

Dairyland conducted detailed analysis and discussions with Dairyland Managers and Dairyland’s Board 

of Directors through strategic planning sessions in the production of its preferred power supply plan over 

a 3-year period. Dairyland also conducted a study of self-build options along with potential NTEC 

participation. Dairyland conducted a RFP with potential energy providers for capacity and energy on a 

long term basis in MISO capacity zone 1. These proposals included a variety of alternatives to meet 

Dairyland’s supply needs, including:

• Coal

• Combustion turbines

• Combined cycle 

• Reciprocating Engines

• Power Purchase Agreements (PPA)

These alternatives varied widely in cost per annual MW hour, years of delivery, and MW provided. Cost 

ranged from $45,000 – $236,000/MW/year, and terms ranged from 3 – over 30 years. The various 

alternatives would provide from 10 to over 350 annual MW. These alternatives also included additional 

risks related to congestion and delivery, making it uncertain if these sources would be available when 

required. Dairyland determined none of these alternatives would be superior to participation in the NTEC 

Project, which would provide a very low energy cost, have a term life of at least 30 years, provide 

approximately 300 MW of dispatchable firm capacity, and minimize congestion, delivery and other risks. 

In addition, Dairyland conducted discussions with developers and other cooperatives through the NRCO 

to evaluate a wide range of options, including a multitude of renewable projects. The Dairyland study 

and planning effort culminated in the development of the Dairyland preferred power supply plan that 

strikes a balance between the need for accredited capacity in MISO zone 1, intermediate energy flexibility 

and numerous renewable resources. The plan was found by Dairyland’s board to be the best course of 

action for Dairyland in this round of resource planning. The plan provides rate stability and reliability 

under a number of different future scenarios. Therefore, Dairyland determined to proceed with 

participation in the NTEC Project.
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The Project is a significant resource in the Dairyland’s power supply plan, balancing the intermittent 

nature of renewable generation. Dairyland’s Board having evaluated the resource options available to 

Dairyland authorized the pursuit of a share of the Project at it January 2016 board meeting.

Having determined to advance the NTEC project, MP and Dairyland sought to evaluate potential 

alternative sites for a new generation project. Previously, a group of utilities serving the upper Midwest, 

particularly the states of Wisconsin, Minnesota, and North Dakota, conducted a site selection study

(Siting Study) to identify and evaluate potential sites for the Project. The Siting Study included 

consideration of potential sites across the upper Midwest that could potentially be used for joint 

development of such a facility by multiple regional utilities. Specific sites would, therefore, be evaluated 

based on the site location, ability to serve the needs of the participating utilities, and capability of the 

facility to integrate into the systems of the participating utilities. The Siting Study identified several 

suitable sites throughout the upper Midwest that appeared to provide reasonable sites for the Project. MP2

and Dairyland were among the utilities with service territory over which the Siting Study was conducted 

and within which some sites were identified for potential future development. The objective of the Siting 

Study was to identify and evaluate potential sites for the future joint development and construction of the 

Project. MP and Dairyland reviewed this Siting Study in relation to this Project. While state siting 

requirements required supplemental analysis, in general, the Siting Study methodology remains valid. MP 

and Dairyland used the Siting Study as a substantial basis for the identification of alternative locations for 

the Project. The following summarizes the overall Siting Study methodology and then focuses on those 

portions of the Siting Study applicable to the joint development of the Project by MP and Dairyland.

2.1.1 Siting Study Objectives

The objectives of the Siting Study were consistent with the requirements of Dairyland and MP for the 

Project. The proposed sites were to be capable of accommodating up to 900 MW of natural gas-fueled 

combined cycle generation, with 780 MW combined cycle gas turbine technology considered for the base 

case analysis. The objective of the overall Siting Study was to perform a desktop screening to identify a 

minimum of three potential plant sites and provide the information necessary for the utilities to focus and 

support subsequent site acquisition and permitting efforts.

2 MP is a division of ALLETE, Inc. As discussed in Section 1.3, MP was a partner in initial studies for the Project. 

Since the conclusion of initial studies, SSE has taken over as Owner with Dairyland.
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2.1.2 Siting Study Area

A Siting Study Area was defined to include the MISO region at the time of the Siting Study as it extended

through the states of North Dakota, Minnesota, and Wisconsin. The Siting Study Area boundary is 

identified in Figure 2-1.

2.1.3 Siting Study Methodology 

The Siting Study was completed in several phases. A brief description of each phase of the site selection 

process is included below.

• Phase 1 – Identify Preliminary Site Areas: the first phase of the site selection process was to 

identify Preliminary Site Areas that were near high voltage transmission lines and major natural 

gas pipelines.

• Phase 2 – Identify Candidate Site Areas: Preliminary Site Areas were screened using readily 

available maps and aerial photographs to eliminate sites with obvious development constraints 

and to consolidate sites that were geographically or electrically similar to each other. The 

remaining sites were designated Candidate Site Areas.

• Phase 3 – Candidate Site Quantitative Analysis: Candidate Site Areas were quantitatively 

evaluated against several criteria organized into six major categories: transmission access, fuel 

delivery, water supply, environmental, air quality impacts, and site development. The results of 

the quantitative analysis were used to rank the sites in order from the most preferred site to the 

least preferred site.

• Phase 4 – Identify Preferred Site Areas: Results of the quantitative analysis were reviewed by the 

collective Project team and the six highest performing sites (identified at Preferred Site Areas)

were selected for further consideration.

• Phase 5 – Transmission Analysis of Preferred Site Areas: Preferred Sites were subjected to a

transmission load flow analysis to identify potential overloads on the transmission system caused 

by injecting power at each of the Preferred Sites. These results were incorporated in the scoring 

matrix and the Preferred Sites ranked relative to one another with scoring assessed in all 

categories, including transmission load flow.

The initial step in the site selection process was to identify Preliminary Site Areas within the Siting Study 

Area, analyze each Preliminary Site through a high-level desktop analysis, and identify Candidate Site 

Areas to carry forward for detailed analysis. Candidate Site Areas are general locations, which may be 

larger than the amount of land required for plant development, that possess the necessary infrastructure 
COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING COMPANY, INC.

Source: Dairyland Power Cooperative, MP, SSE, ESRI Issued: 12/16/2019

Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_1_MidcontinentISORegion_SitingStudyArea.mxd kasamuelson 12/16/2019

Service Layer Credits:

NORTH

100 50 0 100

Miles

Figure 2-1

Midcontinent ISO Region

Siting Study Area

Minnesota

North Dakota

Wisconsin

Siting Study Area

County Boundary

Midcontinent ISO Region
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and other characteristics that may allow them to be suitable power plant sites. The investigations 

completed to identify Candidate Site Areas included the following major tasks:

• Identify and map locations within the Siting Study Area for infrastructure that are critical to 

power plant development and where plant locations may be restricted for environmental and 

regulatory reasons.

• Identify Preliminary Site Areas with consideration of the necessary infrastructure, environmental 

constraints, and other development factors.

• Screen Preliminary Site Areas using readily available maps and other resources.

The methodology and results of these investigations are described in the following subsections.

2.1.4 Preliminary Infrastructure Screening for Preliminary Site Areas

To minimize the potential impacts and costs of plant development, prospective Preliminary Site Areas 

should be located as near as practical to the necessary infrastructure, or physical resources, required for a 

new generation project. Preliminary Site Areas were identified based on the proximity of a site area to 

regional natural gas pipeline and transmission infrastructure. The first step in this process was to develop 

a composite map that overlaid natural gas pipeline infrastructure and high voltage transmission 

infrastructure. The basic infrastructure requirements used for this step were as follows:

• Preliminary Site Areas needed to be located directly adjacent to a transmission line or substation 

operating at 230-kV or higher.

• Preliminary Site Areas needed to be within 5 miles of a 16-inch diameter or larger natural gas 

pipeline.

• Preliminary Site Areas needed to be located within 5 miles of either a major river or a municipal 

wastewater treatment facility of sufficient capacity.

Using the criteria listed above, the locations of infrastructure critical to economic power plant 

development were determined and corresponding Preliminary Site Areas were identified. This resulted in 

the identification of 115 Preliminary Site Areas throughout the three-state Siting Study Area for 

additional screening investigations.

2.1.5 Desktop Screening for Preliminary Site Areas

The 115 identified Preliminary Site Areas that met the initial infrastructure requirements were subjected 

to a desktop screening analysis to eliminate or consolidate sites with obvious development constraints or 

redundant characteristics. For example, a preliminary site that was clearly surrounded by a residential 
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neighborhood would be eliminated, and two preliminary sites that were geographically and electrically 

similar in nature would be consolidated into one site. Hence, a preliminary site could represent multiple 

suitable sites in close proximity to each other. In addition, preliminary sites that were within a national, 

state, or local park were eliminated. Through this process, 81 of the 115 Preliminary Site Areas were 

eliminated or consolidated. The remaining 34 Preliminary Site Areas, across the tri-state Siting Study 

Area, were designated as Preliminary Site Areas. 

2.1.6 Candidate Site Areas

To achieve a manageable number of Preliminary Site Areas for more detailed analysis, it was necessary to 

further identify Candidate Site Areas from among these Preliminary Site Areas. The infrastructure 

screening increased the requisite natural gas pipeline diameter from a minimum of 16 inches to a 

minimum of 20 inches. Preliminary Site Areas were then subjected once again to individual review and 

were evaluated relative to one another for strength of attributes. Following the desktop screening, 16 

Candidate Site Areas were identified from the 34 Preliminary Site Areas. These Candidate Site Areas

included:

• North Dakota: three sites

• Minnesota: seven sites

• Wisconsin: six sites

2.1.7 Candidate Site Areas Evaluation

A quantitative analysis process was used to rank the 16 Candidate Site Areas. The first step in using such 

a process is to identify the objectives or criteria to evaluate the candidates. The focus of the Candidate 

Site Areas evaluation, as well as the criteria discussed in this section, was to assess the advantages and 

disadvantages of each Candidate Site Area on a relative basis.

2.1.7.1 Candidate Site Areas Ranking Approach

The evaluation criteria used to judge the relative suitability of the Candidate Site Areas to support a gasfired combined cycle generation facility cover a number of specific attributes. Each of these attributes 

represents a characteristic that is important in the evaluation of prospective sites and also serves to 

differentiate the Candidate Site Areas from one another. These evaluation criteria are not equivalent in 

their importance to the decision-making process. Therefore, each criterion was also assigned a weight 

indicative of its relative importance to the decision process. Criteria with the highest weights are 

considered the most critical for site development. The assignment of weights to the evaluation criteria was 

based on the collective professional judgment.
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In total, 25 different criteria were used to evaluate the Candidate Site Areas. These criteria were first 

organized into six major categories, and these six major categories were allocated weights that totaled 100 

percent. For example, the Site Environmental category was assigned a weight of 10 percent. Therefore, 10 

percent of an overall evaluation score was based on environmental criteria. Within each major category, 

the criteria were assigned subweights indicative of each criterion’s relative importance. The composite 

weight for each individual criterion was then calculated as an aggregate of all subweighted criteria within 

a major category. The evaluation categories, category weights, criteria, criteria subweights, and composite 

weights are summarized in Table 2-1.
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Table 2-1: Candidate Site Area Evaluation Criteria

Major Category/Category 

Weight Sub Criterion (weight) [Evaluation Points – 100 point scale) Subcategory Rankings Scoring

Electric transmission/20 percent Transmission ranking from Load Flow Analysis (45 percent) [9.0 points] 0 – 20 percent relative ranking 50

Electric transmission/20 percent Transmission ranking from Load Flow Analysis (45 percent) [9.0 points] 21 – 40 percent relative ranking 40

Electric transmission/20 percent Transmission ranking from Load Flow Analysis (45 percent) [9.0 points] 41 – 60 percent relative ranking 30

Electric transmission/20 percent Transmission ranking from Load Flow Analysis (45 percent) [9.0 points] 61 – 80 percent relative ranking 20

Electric transmission/20 percent Transmission ranking from Load Flow Analysis (45 percent) [9.0 points] 81 – 100 percent relative ranking 10

Electric transmission/20 percent Locational Marginal Price (LMP) Analysis (45 percent) [9.0 points] Top 20th percentile 50

Electric transmission/20 percent Locational Marginal Price (LMP) Analysis (45 percent) [9.0 points] 21st to 40th percentile 40

Electric transmission/20 percent Locational Marginal Price (LMP) Analysis (45 percent) [9.0 points] 41st to 60th percentile 30

Electric transmission/20 percent Locational Marginal Price (LMP) Analysis (45 percent) [9.0 points] 61st to 80th percentile 20

Electric transmission/20 percent Locational Marginal Price (LMP) Analysis (45 percent) [9.0 points] Bottom 20th percentile 10

Electric transmission/20 percent Interconnection cost (10 percent) [2.0 points] Existing switchyard expansion – bay space 

available 50

Electric transmission/20 percent Interconnection cost (10 percent) [2.0 points] New switchyard – line tap location 10

Fuel supply and delivery/30 

percent Distance to interconnection (20 percent) [6.0 points] 0 to 2 miles from site 50

Fuel supply and delivery/30 

percent Distance to interconnection (20 percent) [6.0 points] 2 to 4 miles from site 30

Fuel supply and delivery/30 

percent Distance to interconnection (20 percent) [6.0 points] Greater than 4 miles from site 10

Fuel supply and delivery/30 

percent Competitive supply (30 percent) [9.0 points] 2 or more fuel suppliers within 15 miles of site 50

Fuel supply and delivery/30 

percent Competitive supply (30 percent) [9.0 points] Only on fuel supplier within 15 miles of site 10

Fuel supply and delivery/30 

percent Pipeline delivery pressure (20 percent) [6.0 points] Equal to or greater than 650 psig 50

Fuel supply and delivery/30 

percent Pipeline delivery pressure (20 percent) [6.0 points] Less than 650 psig 10

Fuel supply and delivery/30 

percent System upgrade costs (30 percent) [9.0 points] Minimal upgrades required (less than $25.0 million) 50
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Major Category/Category 

Weight Sub Criterion (weight) [Evaluation Points – 100 point scale) Subcategory Rankings Scoring

Fuel supply and delivery/30 

percent System upgrade costs (30 percent) [9.0 points] Moderate upgrades required ($25 to $50 million) 30

Fuel supply and delivery/30 

percent System upgrade costs (30 percent) [9.0 points] Significant upgrades required (greater than $50 million) 10

Water supply and delivery/20 

percent Surface water availability (30 percent) [6.0 points) High probability of water availability within 5 miles 50

Water supply and delivery/20 

percent Surface water availability (30 percent) [6.0 points) Moderate probability of water availability within 5 miles 30

Water supply and delivery/20 

percent Surface water availability (30 percent) [6.0 points) Low probability of water availability within 5 miles 10

Water supply and delivery/20 

percent Groundwater availability (30 percent) [6.0 points] High probability of water availability within 10 miles 50

Water supply and delivery/20 

percent Groundwater availability (30 percent) [6.0 points] Moderate probability of water availability within 10 miles 30

Water supply and delivery/20 

percent Groundwater availability (30 percent) [6.0 points] Low probability of water availability within 10 miles 10

Water supply and delivery/20 

percent Municipal reclaim water availability (30 percent) [6.0 points] Sufficiently permitted reclaimed water source within 5 miles 50

Water supply and delivery/20 

percent Municipal reclaim water availability (30 percent) [6.0 points] Sufficiently permitted reclaimed water source within 10 miles 30

Water supply and delivery/20 

percent Municipal reclaim water availability (30 percent) [6.0 points] Sufficiently permitted reclaimed water source within 15 miles 10

Water supply and delivery/20 

percent Water discharge location (10 percent) [2.0 points] Acceptable water discharge location within 1 mile 50

Water supply and delivery/20 

percent Water discharge location (10 percent) [2.0 points] No acceptable water discharge location within 1 mile 10

Site Environmental/10 percent Wetlands (25 percent) [2.5 points] High probability of avoiding wetlands 50

Site Environmental/10 percent Wetlands (25 percent) [2.5 points] Moderate probability of avoiding wetlands 30

Site Environmental/10 percent Wetlands (25 percent) [2.5 points] Low probability of avoiding wetlands 10

Site Environmental/10 percent Floodplains (25 percent) [2.5 points] Site outside of floodplain 50

Site Environmental/10 percent Floodplains (25 percent) [2.5 points] Part of site within floodplain, potential developable 

area

30

Site Environmental/10 percent Floodplains (25 percent) [2.5 points] Extensive floodplain, limited developable area 10
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Major Category/Category 

Weight Sub Criterion (weight) [Evaluation Points – 100 point scale) Subcategory Rankings Scoring

Site Environmental/10 percent Cultural resources (25 percent) [2.5 points] Limited potential for cultural resources to be 

present

50

Site Environmental/10 percent Cultural resources (25 percent) [2.5 points] Moderate potential for cultural resources to be 

present

30

Site Environmental/10 percent Cultural resources (25 percent) [2.5 points] Significant potential for cultural resources to be 

present

10

Site Environmental/10 percent Sensitive species (25 percent) [2.5 points] 10 sensitive species or less within county 50

Site Environmental/10 percent Sensitive species (25 percent) [2.5 points] 11 to 20 sensitive species within county 30

Site Environmental/10 percent Sensitive species (25 percent) [2.5 points] Greater than 20 sensitive species within county 10

Air quality impacts/10 percent Class I Areas (30 percent) [3.0 points] Greater than 100 kilometers from Class I Area 50

Air quality impacts/10 percent Class I Areas (30 percent) [3.0 points] 50 to 100 kilometers from Class I Area 30

Air quality impacts/10 percent Class I Areas (30 percent) [3.0 points] Class I Area within 50 kilometers 10

Air quality impacts/10 percent Air permit feasibility (35 percent) [3.5 points] Low relative probability of having NAAQS 

exceedances 50

Air quality impacts/10 percent Air permit feasibility (35 percent) [3.5 points] Moderate relative probability of having NAAQS 

exceedances 30

Air quality impacts/10 percent Air permit feasibility (35 percent) [3.5 points] High relative probability of having NAAQS 

exceedances 10

Air quality impacts/10 percent Nonattainment status (35 percent) [3.5 points] Site is not in a nonattainment county 50

Air quality impacts/10 percent Nonattainment status (35 percent) [3.5 points] Site is in an area with high potential to go 

nonattainment 30

Air quality impacts/10 percent Nonattainment status (35 percent) [3.5 points] Site is in a nonattainment county 10

Site development/10 percent Existing use (20 percent) [2.0 points] Industrialized / brownfield site area 50

Site development/10 percent Existing use (20 percent) [2.0 points] Agricultural site area 30

Site development/10 percent Existing use (20 percent) [2.0 points] Forested / natural / undisturbed site area 10

Site development/10 percent Site access (10 percent) [1.0 point] Less than 0.5 mile to paved road 50

Site development/10 percent Site access (10 percent) [1.0 point] 0.5 to 1.5 miles to paved road 30

Site development/10 percent Site access (10 percent) [1.0 point] Limited site access or greater than 1.5 miles to 

paved road 10

Site development/10 percent Rail access (10 percent) [1.0 point] Class I rail line within 1 mile of site 50

Site development/10 percent Rail access (10 percent) [1.0 point] Class I line within 1 to 5 miles of site 30
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Major Category/Category 

Weight Sub Criterion (weight) [Evaluation Points – 100 point scale) Subcategory Rankings Scoring

Site development/10 percent Rail access (10 percent) [1.0 point] Class I rail line greater than 5 miles from site 10

Site development/10 percent Proximity to FAA facilities (10 percent) [1.0 point] No FAA facilities within 5 miles of site 50

Site development/10 percent Proximity to FAA facilities (10 percent) [1.0 point] FAA facility within 1 to 5 miles of site 30

Site development/10 percent Proximity to FAA facilities (10 percent) [1.0 point] FAA facility within 1 mile of site 10

Site development/10 percent Noise / Visual receptors (20 percent) [2.0 points] No receptors within 0.5 mile of site 50

Site development/10 percent Noise / Visual receptors (20 percent) [2.0 points] 1 to 5 receptors within 0.5 miles of site 30

Site development/10 percent Noise / Visual receptors (20 percent) [2.0 points] Greater than 5 receptors within 0.5 mile of site 10

Site development/10 percent Site expansion (15 percent) [1.5 points] 200+ acres available with sufficient buffer zone 50

Site development/10 percent Site expansion (15 percent) [1.5 points] 100 to 200 acres available 30

Site development/10 percent Site expansion (15 percent) [1.5 points] Fewer than 100 acres available 10

Site development/10 percent Site ownership (15 percent) [1.5 points] Owned by Project participant 50

Site development/10 percent Site ownership (15 percent) [1.5 points] Partially owned by Project participant 30

Site development/10 percent Site ownership (15 percent) [1.5 points] Site owned by one or more third parties 10
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2.1.7.2 Candidate Site Scoring Summary

As shown in Table 2-2 and Figure 2-2, the following sites were identified to be the top six performing 

sites: Wilton, SupGen, Prairie Island to Blue Lake, Antelope Valley to Huron, Arrowhead to Red Rock,

and Wempletown to Rockdale. The Frazee and Blue Lake sites were further considered and not deemed

well-suited for joint Project development.3 Of the remaining candidate sites, the top six performing sites, 

referred to as Preferred Sites, were carried on to the next stage of the site selection process. The Preferred 

Sites were:

• Antelope Valley to Huron • SupGen

• Arrowhead to Red Rock • Wempletown to Rockdale

• Rocky Run to Gardner Park • Wilton

3 The Frazee and Blue Lake sites were not considered well-suited for a joint project between any utilities, not just for 

a project with MP and Dairyland as the participants. 
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Table 2-2: Candidate Site Scores

Major Category/

Criterion Category/Criterion Weight Antelope Valley to Huron Arcadian to South Oak Creek Arrowhead to Red Rock Coal Creek to Dickinson Forbes Frazee Jamestown to Buffalo Prairie Island to Blue Lake Prairie to Winger Rocky Run to Gardner Park Rush City Saukville SupGen Wempletown to Rockdale Wilton Wood

Electric Transmission 20%

Transmission Ranking from Load Flow Analysis 45% 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

LMP Analysis 45% 1 0 4 0 2 0 2 0 1 0 4 0 1 0 4 0 1 0 5 0 2 0 3 0 3 0 2 0 5 0 1 0

Interconnection Cost 10% 1 0 1 0 1 0 1 0 5 0 5 0 1 0 1 0 1 0 1 0 5 0 5 0 1 0 1 0 5 0 1 0

Fuel Supply & Delivery 30%

Distance to Interconnection 20% 5 0 5 0 5 0 5 0 3 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 3 0 5 0 5 0 5 0

Competitive Supply 30% 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0

Pipeline Delivery Pressure 20% 5 0 1 0 5 0 1 0 1 0 1 0 1 0 5 0 1 0 1 0 1 0 1 0 5 0 1 0 5 0 1 0

System Upgrade Costs 30% 3 0 3 0 5 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 5 0 1 0 5 0 1 0

Water Supply & Delivery 20%

Surface Water Availability 30% 5 0 1 0 5 0 3 0 5 0 5 0 1 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 3 0 1 0

Groundwater Availability 30% 1 0 3 0 1 0 1 0 1 0 3 0 5 0 1 0 1 0 3 0 3 0 5 0 3 0 5 0 3 0 1 0

Municipal Reclaim Water Availability 30% 0 0 0 0 0 0 3 0 5 0 0 0 0 0 3 0 5 0 0 0

Water Discharge Location 10% 5 0 1 0 5 0 5 0 5 0 5 0 1 0 1 0 5 0 1 0 5 0 5 0 5 0 1 0 5 0 5 0

Site Environmental 10%

Wetlands 25% 5 0 5 0 3 0 3 0 3 0 5 0 3 0 5 0 5 0 5 0 3 0 3 0 5 0 5 0 5 0 5 0

Floodplain 25% 5 0 5 0 5 0 3 0 3 0 3 0 5 0 5 0 5 0 5 0 5 0 3 0 3 0 5 0 5 0 5 0

Cultural Resources 25% 3 0 3 0 1 0 1 0 3 0 1 0 5 0 3 0 3 0 3 0 5 0 3 0 1 0 3 0 3 0 5 0

Sensitive Species 25% 5 0 1 0 5 0 5 0 5 0 5 0 5 0 3 0 3 0 3 0 5 0 1 0 1 0 1 0 5 0 3 0

Air Quality Impacts 10%

Class I Areas 30% 5 0 5 0 3 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 3 0 5 0 5 0 5 0

Air Permit Feasibility 35% 5 0 3 0 1 0 3 0 1 0 3 0 5 0 1 0 1 0 3 0 3 0 3 0 1 0 3 0 3 0 3 0

Nonattainment Status 35% 5 0 1 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0

Site Development 10%

Existing Use 20% 3 0 3 0 3 0 3 0 1 0 3 0 3 0 3 0 3 0 3 0 3 0 3 0 1 0 3 0 3 0 3 0

Site Access 10% 3 0 5 0 5 0 1 0 5 0 5 0 1 0 5 0 3 0 5 0 5 0 5 0 5 0 5 0 5 0 5 0

Rail Access 10% 1 0 1 0 3 0 1 0 3 0 5 0 3 0 3 0 5 0 5 0 3 0 5 0 5 0 3 0 5 0 1 0

Proximity to FAA Facilities 10% 5 0 5 0 3 0 5 0 5 0 5 0 5 0 3 0 5 0 5 0 1 0 3 0 3 0 5 0 1 0 5 0

Noise / Visual Receptors 20% 5 0 1 0 1 0 3 0 1 0 1 0 3 0 1 0 3 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0

Site Expansion 15% 5 0 3 0 5 0 5 0 5 0 3 0 5 0 3 0 5 0 3 0 3 0 3 0 1 0 3 0 3 0 5 0

Site Ownership 15% 1 0 1 0 5 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 1 0 5 0 1 0 1 0 1 0

Total Composite Score 100% 28.20 22.50 27.90 20.90 20.40 26.50 24.60 28.50 22.10 26.30 25.10 25.60 28.80 27.10 32.80 20.30
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Rural Utilities Service 2-14 Dairyland Power Cooperative

Figure 2-2: Candidate Site Rankings 

The six top Preferred Sites were further evaluated for impacts on the transmission systems. At each site, 

the number of overloads resulting from the new generation was tallied and weighted according to the 

particular assets that were overloaded. Impacts on affected systems, either transmission lines or 

substations, were weighted according to the relative significance of the implied infrastructure upgrades 

required.4 The relative percentage for each Preferred Site was then calculated based on the difference in 

score between the Preferred Site with the lowest total score and the Preferred Site with highest total score. 

Sites scores to be incorporated into the site scoring matrix were determined based on these relative 

percentages with a low score of 10 for those sites with the greatest impact and a high score of 50 for those 

sites having the least amount of impact. The nature and number of overloads encountered for each 

individual site can be seen in Table 2-3.

It can be seen from Table 2-3 that the Antelope Valley to Huron site received the highest total load flow 

analysis score out of the six sites evaluated and the Rocky Run to Gardner Park site received the lowest 

total score. Antelope Valley to Huron received a score of 54 due to a relatively high volume of 

overloaded assets resulting from the addition of 780 MW of additional capacity to the existing electric 

transmission infrastructure. In this case, it was determined that eight individual assets would be 

4 For instance, a 500-kV transmission line overload was weighted five times more than a 138/115-kV transmission 

line overload and weighted twice as much as a 500-kV transformer overload.
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-15 Dairyland Power Cooperative

overloaded including several 230-kV and 345-kV transmission lines and a 345-kV substation, which 

figure among the more relatively expensive assets to upgrade. Conversely, it was determined that an 

addition of 780 MW at the Rocky Run to Gardner site did not result in any electric transmission asset 

overloads. Thus, it received the lowest possible score of zero. The relative percentages for each site were 

calculated based on these score extremes of 54 points and zero points. Matrix scores of 10, 20, 30, 40, and 

50 were possible with a score of 10 corresponding to a relative percentage of 80% or above and a score of 

50 corresponding to a relative percentage of 20% or below. As shown in Table 2-3, the Antelope Valley 

to Huron, Arrowhead to Red Rock, and Wilton sites all received the lowest score of 10. The Rocky Run 

to Gardner, SupGen, and Wempletown to Rockdale sites all received the highest possible score of 50.

Transmission Load Flow Analysis scores were incorporated into the site scoring matrix for these six sites

and the resulting site score totals were used to determine the rankings of the preferred sites relative to one 

another. The results can be seen in Table 2-4 and Figure 2-3.

Once the transmission load flow evaluation was completed, a number of sensitivity analyses were 

performed to test the sensitivity of the composite evaluation scores to various changes in criteria 

weighting. For these sensitivity analyses, only the weights assigned to the six major evaluation categories 

were adjusted. Six different sensitivity cases were executed: one case each for transmission, fuel, water,

environmental, air quality, and site development. The weight for the category that was emphasized was 

increased 10 percent, and the other five categories were reduced by two percent each. The composite 

weights for each category and weighted composite scores for each site were then recalculated. Table 2-5

contains a schedule of the category weights used in the sensitivity analyses.
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-16 Dairyland Power Cooperative

Table 2-3: Transmission Load Flow Analysis Scores for Preferred Sites

*Constraints were considered up to 780 MW.

500-kV 345-kV 230-kV 161-kV 138/115-kV 500-kV 345-kV 230-kV 161-kV 138/115-kV

Site Name

Initial Overload 

Point (MW) 5 4 3 2 1 10 8 6 4 2

Antelope Valley to Huron 428.1 1 4 3 5 4 100.00% 1 0

Arrowhead to Red Rock 359.8 1 7 4 5 83.33% 1 0

Rocky Run to Gardner Park 897.3 0 0.00% 5 0

SupGen 768 1 1 1 0 18.52% 5 0

Wempletown to Rockdale 431.2 1 1 6 11.11% 5 0

Wilton 212.7 2 1 2 1 3 4 5 83.33% 1 0

Relative 

Percentage Matrix Score

Sub Equip Overloads Line Overloads

Total Score
Nemadji Trail Energy Center 3 Preferred Site Evaluation

Rural Utilities Service 2-17 Dairyland Power Cooperative

Table 2-4: Preferred Site Scores

Major Category/

Criterion

Category/Criterion WeightAntelope Valley to HuronArrowhead to Red Rock Rocky Run to Gardner ParkSupGenWempletown to RockdaleWilton

Electric Transmission 20%

Transmission Ranking from Load Flow Analysis 45% 1 0 1 0 5 0 5 0 5 0 1 0

LMP Analysis 45% 1 0 2 0 5 0 3 0 2 0 5 0

Interconnection Cost 10% 1 0 1 0 1 0 1 0 1 0 5 0

Fuel Supply & Delivery 30%

Distance to Interconnection 20% 5 0 5 0 5 0 3 0 5 0 5 0

Competitive Supply 30% 1 0 1 0 1 0 1 0 1 0 1 0

Pipeline Delivery Pressure 20% 5 0 5 0 1 0 5 0 1 0 5 0

System Upgrade Costs 30% 3 0 5 0 1 0 5 0 1 0 5 0

Water Supply & Delivery 20%

Surface Water Availability 30% 5 0 5 0 5 0 5 0 5 0 3 0

Groundwater Availability 30% 1 0 1 0 3 0 3 0 5 0 3 0

Municipal Reclaim Water Availability 30% 0 0 0 3 0 5 0 0

Water Discharge Location 10% 5 0 5 0 1 0 5 0 1 0 5 0

Site Environmental 10%

Wetlands 25% 5 0 3 0 5 0 5 0 5 0 5 0

Floodplain 25% 5 0 5 0 5 0 3 0 5 0 5 0

Cultural Resources 25% 3 0 1 0 3 0 1 0 3 0 3 0

Sensitive Species 25% 5 0 5 0 3 0 1 0 1 0 5 0

Air Quality Impacts 10%

Class I Areas 30% 5 0 3 0 5 0 3 0 5 0 5 0

Air Permit Feasibility 35% 5 0 1 0 3 0 1 0 3 0 3 0

Nonattainment Status 35% 5 0 5 0 5 0 5 0 5 0 5 0

Site Development 10%

Existing Use 20% 3 0 3 0 3 0 1 0 3 0 3 0

Site Access 10% 3 0 5 0 5 0 5 0 5 0 5 0

Rail Access 10% 1 0 3 0 5 0 5 0 3 0 5 0

Proximity to FAA Facilities 10% 5 0 3 0 5 0 3 0 5 0 1 0

Noise / Visual Receptors 20% 5 0 1 0 1 0 1 0 1 0 1 0

Site Expansion 15% 5 0 5 0 3 0 1 0 3 0 3 0

Site Ownership 15% 1 0 5 0 1 0 5 0 1 0 1 0

Total Composite Score 100% 29.10 28.80 30.80 33.30 31.60 33.70
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-18 Dairyland Power Cooperative

Figure 2-3: Preferred Site Rankings

Table 2-5: Category Weights for Sensitivity Analyses for Preferred Sites

The results of the sensitivity analyses were summarized by comparing each site’s ranking under the 

various cases. A site’s rank was determined by sorting the sites based on their composite evaluation 

scores and then numbering them sequentially, with a rank of one assigned to the site with the highest base 

score. These ranks are summarized in Table 2-6. The shaded cells in this table indicate the sensitivity 

cases where individual sites either increased or decreased in rank.

Review of Table 2-6 indicates that site base rankings remained unchanged when evaluated for sensitivity 

to both the Environmental and Air Quality scoring categories. In each of the remaining sensitivity 

analyses, however, the site rankings were affected as indicated by shaded cells. Red cells indicate sites

increasing in rank, and green cells indicate sites decreasing in rank from the base case scenario. The

Category

Base 

Weighted

(%)

Transmission

Weighted

(%)

Fuel 

Weighted

(%)

Water 

Weighted

(%)

Environmental 

Weighted

(%)

Air Quality 

Weighted

(%)

Site Dev 

Weighted

(%)

Electric Transmission 20% 30% 18% 18% 18% 18% 18%

Fuel Supply & Delivery 30% 28% 40% 28% 28% 28% 28%

Water Supply & Delivery 20% 18% 18% 30% 18% 18% 18%

Site Environmental 10% 8 % 8 % 8 % 20% 8 % 8 %

Air Quality Impacts 10% 8 % 8 % 8 % 8 % 20% 8 %

Site Development 10% 8 % 8 % 8 % 8 % 8 % 20%

TOTAL 100% 100% 100% 100% 100% 100% 100%
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Rural Utilities Service 2-19 Dairyland Power Cooperative

Table 2-6: Preferred Site Area Rankings for Sensitivity Analyses

changes in ranking for a site under each sensitivity case provide an indication of the relative strengths and 

weaknesses of each site and the drivers for each site’s overall ranking.

2.2 Siting Study Conclusions

The objective of the Siting Study was to identify sites suitable for future development of a CCGT plant 

with a nominal capacity of 900 MW and to provide the information necessary to focus and support 

subsequent site acquisition and permitting efforts. Each of the six Preferred Sites identified in the Siting

Study were recommended to be considered as suitable alternatives for future development activities. As 

site visits were not included in the scope of the Siting Study, the ability to investigate the preferred sites 

and rank them relative to one another was limited to the resources available for desktop review. Site visits 

and confirmation of water availability for specific sites were encouraged prior to subsequent actions. 

Further investigation of the transmission constraints at each of the Preferred Sites and evaluation 

transmission deliverability with respect to load and capacity zones was also recommended.

2.3 NTEC Site Selection

The overall Project objectives for Dairyland and MP, as joint developers of the NTEC Project, were 

comparable to those identified for the overall Siting Study discussed previously. Therefore, the objective 

in identifying potential sites for a joint project included all the requirements for infrastructure identified as 

part of the overall Siting Study. Dairyland and MP also identified several other factors specific to a joint 

project between these two utilities:

• All of MP’s load and the vast majority of Dairyland’s load is located in MISO Zone 1. As part of 

MISO’s guidance for intrazone balancing of load and capacity, it was determined desirable for a 

new generation to serve MP and Dairyland load in Zone 1, to be located in MISO Zone 1. 

Site Name

Base 

Weighted 

Rank

Transmission 

Weighted 

Rank

Fuel 

Weighted 

Rank

Water 

Weighted 

Rank

Environmental 

Weighted 

Rank

Air Quality 

Weighted 

Rank

Site Dev 

Weighted 

Rank

Wilton 1 2 1 3 1 1 2

SupGen 2 1 2 1 2 2 1

Wempletown to Rockdale 3 4 4 2 3 3 3

Rocky Run to Gardner Park 4 3 6 4 4 4 4

Antelope Valley to Huron 5 6 5 6 5 5 6

Arrowhead to Red Rock 6 5 3 5 6 6 5

6 = Denotes a rank increase

0 = Denotes a rank decrease
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-20 Dairyland Power Cooperative

• As MP and Dairyland service territories do not overlap, the utilities determined to provide for 

logistical convenience for both utilities, the new facility should be located as close to the 

boundary of their service territories as practical. This would minimize difficulties for one or both 

companies’ accessing the facility due to extra travel distance or remote access. 

• A location in proximity to both company’s service territories provides a suitable hedge for each 

company’s load purchase within MISO.

• Compliance with any applicable local and state regulatory requirements. 

These factors, along with the overall goals of minimizing distance from transmission infrastructure, 

suitable gas supply facilities, and a water source needed to be considered as part of the identification of an 

area suitable for a joint Dairyland/MP project. 

2.3.1 Identification of NTEC Study Area

Dairyland’s service territory primarily includes large portions of western Wisconsin, southeastern 

Minnesota, and northern Iowa and Illinois (Figure 2-4). MP’s service territory includes areas of north and 

central Minnesota. In considering these service areas, Dairyland and MP’s territories border each other 

along the Minnesota/Wisconsin state line, extending south from Lake Superior – Duluth, 

Minnesota/Superior Wisconsin. The service territories roughly border each other for approximately 75 

miles to the south. This seam between the two service territories was identified and the most reasonable 

location for a joint project between these utilities. An area extending 75 miles from the Duluth/Superior 

area was identified for consideration and identification of potential alternative sites for the NTEC Project

(NTEC Study Area) (Figure 2-4).

2.3.2 Identification of Preferred Site Areas within NTEC Study Area

Having identified the NTEC Study Area for the Project, Dairyland and MP overlaid the Preferred Site 

Areas identified in the Siting Study with the NTEC Study Area to determine if any Preferred Site Areas 

were located within the NTEC Study Area. Two Preferred Site Areas, Arrowhead to Red Rock and 

SupGen, are located with the 75-mile circle where the Dairyland and MP service territories roughly 

border one another. The Arrowhead to Red Rock site is located southwest of Duluth within MP service 

territory, but only a short distance from Dairyland service territory. The SupGen site is located in 

Superior, Wisconsin, which is a short distance from both Dairyland and MP’s service territories. In other 

portions of the NTEC Study Area, the two service territories are more widely separated and would be less 

desirable for a joint project.
COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING COMPANY, INC.

Source: Dairyland Power Cooperative, Minnesota Power, ESRI, and Burns & McDonnell Engineering Company, Inc. Issued: 3/8/2019

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Service Layer Credits: Sources: Esri, Garmin, USGS, NPS

NORTH

25 12.5 0 25

Miles

Figure 2-4

NTEC Study Area

Nemadji Trail Energy Center

Douglas County, WI

!( !(

SupGen

Arrowhead to

Redrock

Service Territory

Dairyland Power

Cooperative

Minnesota Power

NTEC Study Area

!( Line Tap

(<=5 miles to water)

Transmission (>= 230 kV)

Natural Gas Pipeline (>=16")

State Boundary

County Boundary

Study Area

Minnesota

Wisconsin

Key Map
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-22 Dairyland Power Cooperative

2.3.2.1 Arrowhead to Red Rock

Arrowhead to Red Rock is a MP-owned site area and is the location of a line tap formed by the Northern 

States Power Company Arrowhead to Red Rock 345 kV electric transmission line and two 36-inch Great 

Lakes Gas Transmission natural gas pipelines. The site is also within 2 miles of a Northern Natural Gas 

Company natural gas pipeline. The site is located in Carlton County, Minnesota, approximately 5.5 miles 

south of the City of Cloquet and directly to the west of Chub Lake. The closest river is the St. Louis 

River, at approximately 3.5 miles to the northeast. Approximately half of the site area is currently used for 

agricultural purposes and the other half is forested. The site is accessed by Sheils Road to the south and is 

2 miles away from a Burlington Northern Santa Fe (BNSF) rail line. 

Following the quantitative scoring process in the overall siting study, this site ranked 5th out of the 16 

Candidate Site Areas due to the following factors:

• Fuel Supply & Delivery: Scores in this category were strong. This site received the highest 

possible scores for distance to interconnection, pipeline delivery pressure, and system upgrade 

costs. It is located within close proximity to the Great Lakes Gas Transmission Ltd. pipeline 

corridor, allowing it to receive one of the highest scores of any of the candidate sites in this 

category. It is also located less than two miles from a 20-inch diameter Northern Natural Gas 

Company pipeline. This site was not, however, awarded a high score for competitive supply as

the Northern Natural Gas line rated poorly as a primary source of fuel for other sites considered 

in the Study.

• Water Supply & Delivery: This site received a competitive score in this category as it is located 

approximately 3.5 miles from the St. Louis River, which has a 7Q10 of 185 millions of gallons 

per day (MGD). It did, however, receive a low score for potential groundwater availability, which 

served to bring its overall score down slightly.

• Other points to note about this site are that it received a lower relative score for the locational 

marginal prices (LMP) Analysis, which kept it from ranking higher in the top five. As a MPowned site, it scored favorably in the site development category.

2.3.2.2 SupGen

SupGen is a MP-owned site located in Douglas County, Wisconsin, on the outskirts of the City of 

Superior. The Stone Lake to Arrowhead 345-kV electric transmission line, owned by American 

Transmission Company, traverses the site area. The closest natural gas pipeline is located approximately 

5.5 miles south of the site area and includes two 36-inch diameter lines, owned by Great Lakes Gas 
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-23 Dairyland Power Cooperative

Transmission Limited. The site is situated directly on the bank of the Nemadji River and less than 2 miles 

from Lake Superior. The site area itself is partially forested and relatively free of development, except for 

a small concrete foundation and pond in the western-most corner. Much of the surrounding area has been 

appropriated for industrial use. The site is accessed directly by 31st Avenue E., and there is a branch of 

the BNSF rail line less than half a mile to the northwest.

Following the scoring process, this site ranked 2nd out of the 16 Candidate Site Areas due to the 

following factors:

• Fuel Supply & Delivery: Scores in this category were strong. This site received the highest 

possible scores for distance to interconnection, pipeline delivery pressure, and system upgrade 

costs. It is located within close proximity to the Great Lakes Gas Transmission Ltd. pipeline 

corridor allowing it to receive one of the highest scores of any of the Candidate Sites in this 

category. This site is also located approximately 8.5 miles from a 20-inch diameter Northern 

Natural Gas Company pipeline. This site was not, however, awarded a high score for competitive

supply as this line rated poorly as a primary source of fuel for other sites considered in the Siting 

Study. 

• Water Supply & Delivery: This site received one of the strongest overall scores of any candidate 

site in this category. It received the highest score for probability of surface water availability as it 

is located within 2 miles of Lake Superior. It also received moderate scores for both probability 

for groundwater availability and proximity to a sufficiently permitted wastewater treatment 

facility.

As a MP-owned site, it scored favorably in the site development category. This site scored competitively 

in all other categories and received a moderate score in the locational marginal price (LMP) analysis. 

2.3.2.3 Brownfield Sites

Dairyland and MP had determined that the overall objectives of the Siting Study were applicable to those 

for this Project, however, the initial Siting Study had only considered greenfield sites. This was due to the 

wide geographic area of the Siting Study, the multiple and geographic variation of the participating 

utilities and the challenges associated with use of a site that may or may not be accessible to future 

utilities participating in a new generation Project. Therefore, in addition to reviewing the sites identified

in the Siting Study within the NTEC Study Area, Dairyland and MP conducted a high level review to 

determine if any potential suitable brownfield sites were available and suitable as alternative sites for this 

Project. Brownfield sites include currently or previously developed commercial or industrial sites that are 
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-24 Dairyland Power Cooperative

either abandoned, idle, or underused for which the expansion or redevelopment of the site would limit or 

minimize impacts to other undeveloped areas. Similar to confining new linear facilities to existing linear 

ROW or corridors reduces the spread of linear infrastructure across the landscape, redevelopment of 

previous industrial or commercial sites can limit commercial and industrial development to previously 

disturbed areas. 

Critical for this Project was the need to have suitable water supply, natural gas supply and access to 

electricity transmission in close proximity to minimize the impacts and costs associated with these 

resources. As outlined in the Siting Study, locations of intersection of natural gas pipelines and electricity 

transmission lines present the first siting consideration for a new generation facility. Dairyland and MP

reviewed the transmission and natural gas infrastructure within the 75-mile study area and identified only 

small areas where these resources intersected or occurred in close proximity to each other. None of these 

locations were determined to contain existing or previous commercial or industrial sites but were typically 

all rural agricultural or undeveloped lands. 

Several existing brownfield sites were identified near the SupGen area. Although not at intersections or in 

proximity to the critical infrastructure for a new generation facility, these sites were evaluated for 

potential use. These sites were either located in close proximity to residential areas, did not have 

sufficient land available for the Project, and/or were located in high density developed areas of Duluth. As 

a result of these locational challenges and potential for conflicts with adjacent land use, as well as a lack 

of necessary infrastructure that would create additional challenges and impacts to these areas to develop, 

these brownfield sites were not considered for the Project. No brownfield sites were determined available 

or suitable for project development within the NTEC Study Area. 

2.3.3 Selection of Preferred NTEC Site 

The following is a summary of conclusions reached for the Arrowhead to Red Rock site:

• Electric Transmission: This site received low scores for all three electric transmission categories.

There is no existing substation on the site so a line tap would be required. The LMP was low 

relative to the other sites, receiving a score of 20 out of a possible 50 points. It received the 

second least desirable score from the transmission load flow analysis. With the addition of 780 

MW, there would be eight individual assets overloaded including seven 230-kV transmission 

lines and one 230-kV substation.

• Fuel Supply & Delivery: Scores in this category were strong. This site received the highest 

possible scores for distance to interconnection, pipeline delivery pressure, and system upgrade 
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-25 Dairyland Power Cooperative

costs. It is located within close proximity to the Great Lakes Gas Transmission Ltd. pipeline 

corridor, allowing it to receive one of the highest scores of any of the candidate sites in this 

category. It is also located less than 2 miles from a 20-inch diameter Northern Natural Gas 

Company pipeline. This site was not, however, awarded a high score for competitive supply as 

the Northern Natural Gas line rated poorly as a primary source of fuel for other sites considered 

in the Study. It should be noted, however, that although there is currently no capacity available on 

the Northern Natural Gas pipeline, the close proximity of the line may still be considered an

advantage in the long term. While it is anticipated that interconnecting to this pipeline for the 

purposes of this Project would incur significant upgrade costs, it is nonetheless a fuel supply 

alternative, the existence of which may provide negotiating leverage and the potential for tapping 

an alternative fuel supply basin, should the need arise.

• Water Supply & Delivery: This site received a competitive score in this category as it is located 

approximately 3.5 miles from the St. Louis River, which has a 7Q10 flow rate of 185 MGD. It 

did, however, receive a low score for potential groundwater availability, which served to bring its 

overall score down slightly.

• It should be noted that this site has the advantage of being MP-owned.

The following is a summary of conclusions for the SupGen site:

• Electric Transmission: This site received the second highest electric transmission score of any of 

the preferred sites. While it did receive a low score for interconnection cost due to the need for 

construction of a line tap, it received the third highest score for the LMP analysis and the highest 

possible score for the transmission load flow analysis. With the addition of 780 MW, two 

individual assets would be overloaded requiring infrastructure updates for one 230-kV 

transmission line and one 345-kV substation.

• Fuel Supply & Delivery: Scores in this category were strong. This site received the highest 

possible scores for distance to interconnection, pipeline delivery pressure, and system upgrade 

costs. It is located within close proximity to the Great Lakes Gas Transmission Ltd. pipeline 

corridor allowing it to receive one of the highest scores of any of the candidate sites in this 

category. This site is also located approximately 8.5 miles from a 20-inch diameter Northern 

Natural Gas Company pipeline. This site was not, however, awarded a high score for competitive 

supply as this line rated poorly as a primary source of fuel for other sites considered in the Study.

It should be noted, however, that although there is currently no capacity available on the Northern 

Natural Gas pipeline, the close proximity of the line may still be considered an advantage in the 
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-26 Dairyland Power Cooperative

long term. While it is anticipated that interconnecting to this pipeline for the purposes of this 

Project would incur potentially significant upgrade costs, it is nonetheless a fuel supply 

alternative, the existence of which may provide negotiating leverage and the potential for tapping 

an alternative fuel supply basin, should the need arise.

• Water Supply & Delivery: This site received one of the strongest overall scores of any candidate 

site in this category. It received the highest score for probability of surface water availability as it 

is located within two miles of Lake Superior. It also received moderate scores for both probability 

for groundwater availability and proximity to a sufficiently permitted wastewater treatment 

facility.

• This site scored competitively in all other categories and has the advantage of being MP-owned.

The scoring for the Arrowhead – Red Rock and SupGen sites was very similar except in two categories –

transmission system performance and water availability. In both these areas, the SupGen site was 

determined to rank better than the Arrowhead – Red Rock site. Development of the SupGen site was 

determined to result in considerably less overloads on the transmission system, likely resulting in much 

less need for other system projects to upgrade and support the system to avoid overloads. Impacts and 

costs associated with system upgrades would likely be less for the SupGen site, thereby minimizing 

overall project impacts and cost. 

Further, the availability of water is an important consideration in development of a new power generation 

facility. The availability of water at the SupGen site provides support for plant water needs without more 

extensive, impacting, and costly development of a water supply (such as a pipeline) to support the site. 

While both sites are in general proximity to the seam between the MP and Dairyland systems, the SupGen 

site is located more closely to the boundary between the systems. The Arrowhead – Red Rock site is 

located several miles into MP territory and would potentially require additional transmission 

infrastructure to connect into the Dairyland system. 

On the basis of the SupGen site minimizing transmission system concerns, providing an adequate and 

available water source, and location central to the boundary of the MP and Dairyland service areas, MP

and Dairyland selected the SupGen site for development of the proposed NTEC Project. 

2.3.4 Alternative Generation Site Identification

Having identified the SupGen site (Figure 2-4) as a location vicinity for further investigation and 

development for the Project, the region around the site was evaluated for potential alternative generation 
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-27 Dairyland Power Cooperative

sites. The SupGen site, as considered in the site selection study, was confirmed to provide a reasonable 

site for Project development (Nemadji River Site; Figure 2-5). The site is owned by MP and provides 

reasonable access to electricity, natural gas, and water/wastewater infrastructure, without the need for 

extensive additional development of these resources.

Other areas in the nearby vicinity of the site were subsequently investigated and considered for alternative 

sites for Project development. For other areas to be considered as potential alternatives, the following 

factors were considered: 

• Sufficient land space is available for the generating unit and supporting infrastructure

• Corridors to connect electricity transmission and natural gas pipelines are available to access the 

site

• Proximity to appropriate electricity grid and natural gas pipeline tap locations to minimize 

impacts and costs associated with the development of this infrastructure

• Avoided major approval or permitting concerns such that the site would have a reasonable 

probability of being approved and permitted if selected for the Project. 

The area around the Nemadji River Site contains a variety of developments. Tank farm facilities lie to the 

north of the site, within the City of Superior, including commercial and residential development, further 

north. The Nemadji Golf Course is to the west, and slightly beyond the golf course to the west is the 

Richard I. Bong Memorial Airport, creating potential concerns for stack height restrictions and above 

ground electrical transmission infrastructure across much of the area. Residential development extends to 

the east, with Lake Superior less than one mile to the east. The area to the south of the Nemadji River Site 

is relatively undeveloped, although it contains numerous utility corridors and some mining facilities. The 

area is heavily wooded and contains extensive wetlands.

Investigations of the area identified an alternative site for the facility approximately 1.5 miles north of the 

Nemadji River Site (Figure 2-5) to the east of Hill Avenue. The Hill Avenue Site is located just north of 

the tank farm and west and south of dense residential areas of the City of Superior. An open corridor is 

available to extend electricity and gas infrastructure into the site. Areas surrounding the Hill Avenue Site 

contain commercial and light industrial facilities, lowland scrub/shrub wetland community, or are 

undeveloped, wooded areas. Dairyland and SSE are including the Hill Avenue Site as part of Project 

development and evaluation activities. 
Service Layer Credits: COPYRIGHT © 2020 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior 2019 aerial photography, Energy Velocity, and Burns & McDonnell Engineering Company, Inc. Issued: 7/14/2020 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_5_1_GenAlternatives.mxd mhughes 7/14/2020

Figure 2-5

Page 1 of 3

Alternative Generation Sites

Nemadji Trail Energy Center

Douglas County, WI

!

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!

^_

^_

£¤2

£¤53

CITY OF SUPERIOR

NORTH

2,000 1,000 0 2,000

Scale in Feet

^_ Hill Avenue Site

^_ Nemadji River Site

Approximate Property Boundary

Railroad

Existing Transmission

! ! 161kV and Below

! ! 345kV

Municipal Boundary
COPYRIGHT © 2020 BURNS & McDONNELL ENGINEERING COMPANY, INC.

Source: City of Superior (Aerial 2019), EV, Minnesota Power, Dairyland Power Cooperative, and Burns & McDonnell Engineering Company, Inc. Issued: 7/15/2020

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NORTH

400 200 0 400

Scale in Feet

Craft, Visitor,

Vendor Parking

Laydown and Fabrication

Construction

Office Trailers

Construction

Entrance Turnstyle

Steam Turbine

Generator

Combustion Turbine

Generator

HRSG

Stack Dry Cooling Equipment

Sheet Pile Wall

Future Fuel

Oil Storage Tank

Ammonia Storage Tank

Storm Water Pond (Expanded Existing)

Storm Water Discharge

Pipe (Existing)

Property Line

Natural Gas

Supply Line

(16-inch)

Potable Water Supply

& Water Discharge

Pipelines

Back-up Natural

Gas Supply Line

(10-inch)

Fence Line

Enbridge Storm

Water Discharge

Pipe (Existing)

Fence Line

345-kV Transmission Line

31ST AV

11TH ST

Figure 2-5

Page 2 of 3

Nemadji River Site Layout

Nemadji Trail Energy Center

Douglas County, WI

Plant Facilities

Temporary Construction

Property Boundary

Fence (Barded Wire)

Fence (Chain Link)

Stormwater Drainage Pipe

Proposed Natural Gas Lateral

Stormwater Pond

Water Pipeline

Laydown

& Staging

Proposed

Transmission

Line
COPYRIGHT © 2020 BURNS & McDONNELL ENGINEERING COMPANY, INC.

Source: City of Superior, WI (Aerial 2019), EV, Minnesota Power, Dairyland Power Cooperative, and Burns & McDonnell Engineering Company, Inc. Issued: 7/15/2020

Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_5_3_HillAveSiteLayout_ACC.mxd mhughes 7/15/2020

NORTH

400 200 0 400

Scale in Feet

Figure 2-5

Page 3 of 3

Hill Avenue Site Layout

Nemadji Trail Energy Center

Douglas County, WI

Storm Water Pond

Construction

Office Trailers

Construction

Parking

Construction

Laydown

Plant

Entrance

Construction

Worker Turnstyles

Guard

House Steam Turbine

Generator

Combustion

Turbine Generator

HRSG

Dry Cooling Equipment

Ammonia Storage Tank

Future Fuel Oil

Storage Tank

Construction

Laydown

Fence Line/Property Boundary

Natural Gas Supply Line

Potable Water Supply

& Water Discharge

Pipelines

Gas Metering

Stack

HILL AV

KIRK ROLSON ST

RANDY JOHNSON ST

Fence Line

Plant Facilities

Property Boundary

Stormwater Pond

Temporary Construction

Natural Gas Supply Line

Water Pipeline

Laydown

& Staging
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-31 Dairyland Power Cooperative

2.4 Linear Infrastructure Alternatives 

Development of this new natural gas generation facility requires the development of associated electricity 

and natural gas infrastructure. The new facility would require a new electric transmission line to connect 

to a new switching station located southeast of the site. The switching station would then be connected to 

the electricity grid in order to deliver the power generated to the bulk power system. Ideally, the 

connection would be at a location minimizing conflicts with existing system reliability, to avoid or 

minimize the need for additional upgrades to accommodate the additional power being inserted into the 

system. American Transmission Company (ATC) would be responsible for the connection between the 

switching station and the existing Arrowhead to Stone Lake 345-kV transmission line. In addition to an 

electrical transmission interconnect, a suitable supply of natural gas to fuel the facility is also required via 

a natural gas pipeline. A 16-inch diameter natural gas line for the Project will be constructed and owned 

by Superior Water Light & Power. As such, it is not evaluated as part of the Project. It is discussed in 

Chapter 4, Cumulative Impacts.

The proposed switching and tap points on existing natural gas pipelines capable of providing the required 

fuel supply are identified as end points for linear infrastructure extending from alternative generation 

sites. The location of potential generation sites and the connection/tap points form the basis for the 

development of a Study Area within which to identify and consider corridors for infrastructure 

development. The Study Area typically is identified within which several 0.5-mile wide macro-corridors 

can be developed. These macro-corridors are investigated in further detail to determine potential impacts 

for a new transmission line in the Study Area. These steps and the results for this study are discussed in 

detail in the following sections.

2.4.1 Macro-corridor Study Area Identification

After identification of the alternative generation sites, and prior to the development of a defined Study 

Area for the development of necessary linear infrastructure (macro-corridors), the primary constraints of 

the area were reviewed. Major considerations for developing a new transmission line between a new 

generation facility in Superior, Wisconsin, and a termination point southeast of the proposed facility 

included residential areas of the City of Superior, the Richard I. Bong Memorial Airport, several local 

parks, tank farm, and the Nemadji Golf Course.

Based on these identified potential constraint areas, a Study Area was established that was capable of 

providing sufficient geographic area to include multiple macro-corridor options that could connect Project 

endpoints (alternative generation plant sites and utility infrastructure connections) while providing 

opportunities to avoid constraints and take advantage of opportunities (Figure 2-6). The Study Area is 
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Service Layer Credits: Copyright:© 2014 Esri COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, USGS PADUS, FAA, USGS NHD, and Burns & McDonnell Engineering Company, Inc. Issued: 3/8/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_6_StudyArea.mxd kasamuelson 3/8/2019

NORTH

1 0.5 0 1

Miles

Figure 2-6

Study Area

Nemadji Trail Energy Center

Douglas County, WI

!.

Project Site

Lake Superior

Wisconsin

Minnesota

Douglas

County

Carlton

County

Pine

County

St. Louis

County

Study Area

^_ Hill Avenue Site

^_ Nemadji River Site

p Airport

Railroad

! ! 161 kV and Below

! ! 345 kV

Parkland Switching Station

Superior Switching Station

County Boundary

Municipal Boundary

Public Park

State Managed Land

Lake Superior

National Estuarine

Research Reserve

Douglas County Forest
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-33 Dairyland Power Cooperative

completely within Douglas County and was designed to provide a reasonable number of corridor

opportunities, while at the same time not being too large as to encumber the process. The following 

sections provide a description of the Study Area and identify the macro-corridors developed within the 

Study Area for further investigation.

2.4.2 Resource Data Collection

Readily-available resource data within the Study Area was collected from Federal governmental agencies, 

state and local governments, utility companies, and other publicly available sources. This data was used to 

prepare Geographic Information System (GIS) maps and included the following resource categories: 

• Land Use and Jurisdiction;

• Existing Transportation and Utility Corridors;

• Geology and Soils;

• Water Resources; and

• Cultural Resources.

The resource data was mapped in GIS format and combined with aerial photography to validate resources 

within the identified macro-corridors.

2.4.3 Identification of Alternative Macro-Corridors

Following the establishment and investigation of the Study Area, the area was evaluated for the 

identification of macro-corridors for the linear infrastructure requirements. Several general areas 

potentially suitable to contain macro-corridor alternatives were identified and evaluated to determine if 

they were suitable for the development of transmission line route (Figure 2-7). The macro-corridors were 

evaluated with consideration of the following constraints and opportunities, which were present in the 

Study Area:

• Communities and other developed areas within the Study Area

• Nemadji Golf Course

• Existing oil and gas infrastructure

• Existing transmission line corridors

• Roads and railroads

• Conservation areas
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Service Layer Credits: Copyright:(c) 2014 Esri COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, Wisconsin DNR, and Burns & McDonnell Engineering Company, Inc. Issued: 12/16/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_7_MacroCorridors.mxd kasamuelson 12/16/2019

NORTH

1 0.5 0 1

Miles

Figure 2-7

Macro-Corridors

Nemadji Trail Energy Center

Douglas County, WI

^_ Hill Avenue Site

^_ Nemadji River Site

Approx. Property

Boundary

Study Area

Macro-Corridors

Railroad

Existing Gas Pipeline

Municipal Boundary

Parkland Switching Station

Superior Switching Station

Existing Transmission

! ! 161kV and Below

! ! 345kV
Nemadji Trail Energy Center Alternatives

Rural Utilities Service 2-35 Dairyland Power Cooperative

Constraints were considered in the development of the macro-corridors (see Figure 2-8 through Figure 

2-13 for macro-corridor resource maps). Macro-corridors considered the locations of natural and social

resources within the Study Area and potential opportunities available for the compatible location of a new 

transmission line such as roadways and existing transmission line corridors. 

A number of existing utility corridors extend through the Study Area. Locating a transmission line along 

linear features may result in fewer environmental impacts because of the previous disturbance from 

construction and is considered good routing practice by confining linear facilities to common corridors. 

Existing transmission lines provide opportunities for routing the proposed transmission line adjacent to an 

existing right of way (ROW). However, locating along these facilities may be difficult due to 

development around these lines and can also limit flexibility to avoid resources along existing 

infrastructure. In considering these factors, along with other constraints in the Study Area, the 

identification of macro-corridors focused on following existing utility infrastructure, with macro-corridors 

wide enough (0.5 mile) to provide opportunities to avoid constraints if necessary.

A more detailed discussion and comparison of these macro-corridors is found in the following section.

2.4.4 Alternative Macro-Corridors

Figure 2-7 illustrates the alternative macro-corridors and identifies individual corridor segments by 

letter designation A through E. The following is a description of each macro-corridor.

The macro-corridors had several similarities. All macro-corridors crossed large areas of wetlands and

woodlands within the City of Superior, the Town of Superior, or Parkland. Areas of hunting lease land 

and wetland mitigation areas are also included within the macro-corridors.

Corridor segment A generally extends from the Hill Avenue generation site alternative to the southeast, 

paralleling existing transmission for its entire length and existing pipeline infrastructure for over half its 

length. Due to the constraints in the area and existing linear infrastructure, only one macro-corridor was 

developed extending south from the Hill Avenue Site. This corridor is wide enough to provide flexibility 

to develop multiple alignments and avoid site specific constraints that may be identified later. 
^_

^_

Richard I. Bong Airport

Carlson Airport

Service Layer Credits: COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, Wisconsin DNR, FAA, and Burns & McDonnell Engineering Company, Inc. Issued: 3/13/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_8_StudyAreaLandcover.mxd kasamuelson 3/13/2019

NORTH

1 0.5 0 1

Miles

Figure 2-8

Study Area and Landcover

within the Macro-Corridors

Nemadji Trail Energy Center

Douglas County, WI

^_ Hill Avenue Site

^_ Nemadji River Site

Approx. Property Boundary

Parkland Switching Station

Superior Switching Station

Macro-Corridors

Study Area

p Airport

Existing Transmission

! ! 161kV and Below

! ! 345kV

Landcover

Urban/Developed

Agriculture

Grassland

Forest

Open Water

Wetland

Barren

E

D

C

B

A
^_

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SUPERIOR

TOWN OF

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Be arCreek

Rock y Run

Service Layer Credits: Copyright:(c) 2014 Esri COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, USGS PADUS, FAA, USGS NHD, and Burns & McDonnell Engineering Company, Inc. Issued: 12/16/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_9_StudyAreaLandO

wnership.mxd kasamuelson 12/16/2019

NORTH

1 0.5 0 1

Miles

Figure 2-9

Government and Primary Land

Ownership within the Macro-Corridors

Nemadji Trail Energy Center

Douglas County, WI

^_ Hill Avenue Site

^_ Nemadji River Site

Study Area

Approx. Property

Boundary

Macro-Corridors

Municipal Boundary

Parkland Switching Station

Superior Switching Station

E

D

C

B

A

Lake Superior

Allouez Bay

City of Superior

Douglas County

Superior School

District

West Wisconsin

Land Trust

Town of

Parkland

Timber Company

Wisconsin DNR

Wisconsin

Wetlands LLC

Land Ownership
!.

!.

!.

^_

^_

Bluff Creek Wetland Bank

VILLAGE OF

SUPERIOR

TOWN OF

SUPERIOR

PARKLAND

CITY OF SUPERIOR

City of Superior

SAMP 2 Bank

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Service Layer Credits: Copyright:(c) 2014 Esri COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, USGS PADUS, Wisconsin DNR, FAA, USGS NHD, and Burns & McDonnell Engineering Company, Inc. Issued: 12/16/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_10_StudyAreaRecreation.mxd kasamuelson 12/16/2019

NORTH

1 0.5 0 1

Miles

Figure 2-10

Conservation and Recreation

Areas within the Macro-Corridors

Nemadji Trail Energy Center

Douglas County, WI

^_ Hill Avenue Site

^_ Nemadji River Site

Approx. Property Boundary

Parkland Switching Station

Superior Switching Station

!. Boat\Canoe Launch

Study Area

Recreation Trail

Municipal Boundary

Macro-Corridors

Hunting Area

Conservation Area

E

D

C

B

A

Special Use

Waterfront

Park

Open Space

City Park and

Recreation Areas
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Service Layer Credits: Copyright:(c) 2014 Esri COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, Ventyx Velocity, FAA, USGS NHD, and Burns & McDonnell Engineering Company, Inc. Issued: 12/16/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_11_TransportationUtilties.mxd kasamuelson 12/16/2019

NORTH

1 0.5 0 1

Miles

Figure 2-11

Transportation and Utilities

within the Macro-Corridors

Nemadji Trail Energy Center

Douglas County, WI

^_ Hill Avenue Site

^_ Nemadji River Site

Approx. Property Boundary

Parkland Switching Station

Superior Switching Station

Study Area

Municipal Boundary

Railroad

U.S. Highway

State Highway

County Road

Local Road

Macro-Corridors

Existing Transmission Line

! ! 161kV and Below

! ! 345kV

p Public Airport

p Private Airport

Existing Gas Pipeline

D

E

C

B

A

Lake Superior

Allouez Bay
^_

^_

VILLAGE

OF

SUPERIOR

TOWN OF

SUPERIOR

PARKLAND

CITY OF SUPERIOR

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Service Layer Credits: Copyright:(c) 2014 Esri COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, Ventyx Velocity, FAA, USGS NHD, and Burns & McDonnell Engineering Company, Inc. Issued: 12/16/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_12_ImportantFarmland.mxd kasamuelson 12/16/2019

NORTH

1 0.5 0 1

Miles

Figure 2-12

Farmland of

Statewide Importance

Nemadji Trail Energy Center

Douglas County, WI

^_ Hill Avenue Site

^_ Nemadji River Site

Approx. Property

Boundary

Study Area

Macro-Corridors

Parkland Switching Station

Superior Switching Station

Municipal Boundary

Farmland of

Statewide Importance

E

D

C

B

A

Lake Superior

Allouez Bay
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Service Layer Credits: COPYRIGHT © 2019 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior, Wisconsin DNR, USGS PADUS, USGE NHD, FEMA, and Burns & McDonnell Engineering Company, Inc. Issued: 12/16/2019 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_13_WaterResources.mxd kasamuelson 12/16/2019

NORTH

1 0.5 0 1

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Figure 2-13

Water Resources

within the Macro-Corridors

Nemadji Trail Energy Center

Douglas County, WI

^_ Hill Avenue Site

^_ Nemadji River Site

Approx. Property Boundary

Parkland Switching Station

Superior Switching Station

Study Area

Macro-Corridors

Wetland

Mitigation Bank

Stream\River

Floodplain

Wisconsin

Wetland Inventory

Municipal Boundary

Existing Transmission Line

! ! 161kV and Below

! ! 345kV

Existing Gas Pipeline

Railroad

Lake Superior

E

D

B

C

A

Allouez Bay
Nemadji Trail Energy Center Alternatives

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2.4.5 Substation Siting Alternatives

Construction of the proposed Project requires interconnection of the plant to the existing 345-kV 

electrical system, as previously discussed. The nearest 345-kV line to be tapped for the project is the 

Arrowhead to Stone Lake 345-kV line located south of the proposed NTEC and Hill Ave sites. As limited 

space was available on both proposed plant sites for a 345-kV substation and construction of a switching 

station at either plant site would require construction of two new 345-kV lines for several miles to loop 

the Arrowhead to Stone Lake line in and out of the new switching station, a new switching station off-site 

was determined necessary and alternative sites were investigated and evaluated. 

The Superior region of Wisconsin has a relatively high abundance of forested and shrub/scrub wetlands. 

In considering potential switching station locations, the evaluation focused on potential locations within 

the macro-corridors, as well as adjacent areas within a mile of the macro-corridor alternatives. Focusing 

the sites for station alternatives to this area minimized the potential, additional new 345-kV line that 

would be required to interconnect the switching station to the existing 345-kV system and the associated 

impacts of establishing new line right-of-way. Sites were evaluated for the presence of wetlands as well 

as numerous other factors, including clearing requirements, federal and state listed sensitive species or 

other resources, land use, proximity to residences and residential areas, grading and stormwater retention 

requirements, and willingness of landowners to sell the property. Additionally, location of the switching 

station near the Arrowhead to Stone Lake 345-kV line was recognized to minimize the length of new 345-

kV line, and associated impacts to establish, construct and maintain the new line and right-of-way. The 

further the switching station from the existing line, the more new line and right-of-way required, and the 

more potential natural resource and social impacts expected. 

Numerous sites within the macro-corridors and surrounding study area were identified and evaluated for 

the new switching station. Ultimately, two sites, the Parkland Switching Station and Superior Switching 

Station (Figure 2-7) were identified as alternative switching station sites for connection of the alternative 

macro-corridors into the 345-kV system. These sites were determined to minimize overall (temporary, 

permanent, conversion) wetland impacts as well as minimizing residential proximity and avoided 

occurrences of state listed sensitive resources. Land use at the sites was determined compatible for the 

development of a switching station and the proximity of the sites to the Arrowhead to Stone Lake line 

was approved by MISO, minimized impacts associated with any new line construction (although the 

Superior Switching Station site would require additional new 345-kV line to facilitate connection to the 

existing 345-kV system) and additional intrusion of transmission lines into the environment, collocated 

adjacent to the existing utility corridor as required by the PSCW, avoided residential proximity concerns, 

and could be obtained through a voluntary purchase from the existing landowner. The Parkland and 
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Superior Switching station alternative sites have therefore been retained for evaluation as part of the 

macro-corridor alternatives identified. 

The existing transmission line, SWL&P’s Winter to Stinson 115-kV transmission line, extends through a 

wooded area from the Hill Avenue alternative site to the Stinson Substation on 24th Avenue. An 

alternative alignment along the existing line would generally confine impacts to an already impacted 

corridor, although paralleling this line would require additional woodland clearing. This portion of 

Corridor segment A includes residential areas along the following roads: 12th Street, 13th Street, 14th

Street, 19th Street, 21st Street, and 22nd Street. The corridor includes a portion of the Christ Lutheran 

Church property. 

From the Stinson Substation to the Nemadji River, alignments within Corridor segment A could parallel 

either a transmission line (Gary to Stinson 115-kV, Superior to Minong 161-kV, or Ino to Superior 115-

kV) or a pipeline (crude oil or natural gas). This area would require additional woodland clearing as well, 

though there is less woodland in this portion of Corridor Segment A compared to the area north of the 

Stinson Substation. The portion of Corridor segment A between 24th Avenue and the Nemadji River 

contains additional oil and gas infrastructure (tank farm), however, which would limit the number of 

alternative alignments that could be reasonably developed. Alignments within portion of Corridor 

segment A may require a transmission line crossing and/or a gas pipeline crossing depending on the 

alternative alignment. Any alternative alignment within Corridor segment A would also require a crossing 

of the Orange Trail. The corridor also includes a portion of the St. Francis Cemetery on the north bank of 

the Nemadji River. Corridor segment A provides the opportunity for crossing the Nemadji River and its 

associated floodplain at an existing crossing, limiting impacts to an existing river crossing, rather than 

creating new impacts elsewhere along the Nemadji River. South and east of the Nemadji River is 

primarily wooded. Alternatives within Corridor segment A would require additional woodland clearing in 

this area. Residential structures occur along East 18th Street. Alignments paralleling existing transmission 

lines or gas pipeline ROW through this area would confine impacts to existing ROWs and areas adjacent 

to existing utility corridors.

Corridor segment B is the more westerly of two macro-corridors that extend from the south end of 

Corridor segment A generally southwest then south. Corridor segment B includes opportunities to parallel 

42nd Avenue as well as a rail line to Woodlawn Road. The corridor includes portions of the Nemadji sled 

hill and structures associated with the rail line. Alternatives through this area would require woodland 

clearing as the area is primarily wooded. Corridor segment B also includes the Superior Switching 

Station. If the Superior Switching Station Site is constructed for the Project, ATC would construct two 
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345-kV transmission lines from the Superior Switching Station Site to a tap location on the existing 

Arrowhead to Stone Lake 345-kV transmission line. This alternative would be the responsibility of ATC

and is therefore not part of the Project or this application.5 Corridor segment B connects to Corridor 

segment C.

After crossing Woodlawn Road, Corridor segment C turns and extends generally south, paralleling an 

existing Enbridge crude oil pipeline. Alternatives using Corridor segment C continue to Corridor segment 

D. Alternatives through this portion of Corridor segment C would require woodland clearing and would 

cross rail lines south of CR A. At CR Z, Corridor segment C extends due south and no longer parallels the 

crude oil pipeline. This portion of the corridor would also require woodland clearing, includes a crossing 

of Bluff Creek and its associated floodplain, and also has several structures, including the George 

Constance Senior Memorial Rifle Range, residences, and outbuildings. 

Corridor segment D extends from the end of Corridor segment C due east along the existing Arrowhead 

to Stone Lake 345-kV transmission line. Alternatives through this corridor would require woodland 

clearing, a Duluth Missabe & Iron Range rail line crossing, and a crossing of an unnamed tributary of 

Bear Creek and its associated floodplain. Alternatives through this corridor would terminate at the 

Parkland switching station site.

Corridor segment E extends from the south end of Corridor segment A generally southeast then south, to 

the east of Corridor segment B. The corridor parallels two existing transmission lines (Superior to 

Minong 161-kV and Ino to Superior 115-kV) and an existing SWL&P natural gas pipeline. Alignments in 

Corridor segment E would require rail line crossings near 42nd Ave and East 18th Street. This area also 

contains several residences and structures related to rail line operations. Continuing south, Corridor 

segment E traverses primarily woodland and crosses City Limits Road. Several residences are located 

along City Limits Road within the macro-corridor. Alignments in this portion of Corridor segment E 

would require crossing Bluff Creek and Bear Creek and floodplain associated with each creek, as well as 

woodland clearing. Paralleling existing linear infrastructure within this corridor would limit impacts to 

areas adjacent to existing waterway crossings and would limit woodland clearing to areas adjacent to 

existing ROWs. Corridor segment E extends due south, crossing a Duluth Missabe & Iron Range rail line. 

Alternatives within Corridor segment E would cross this rail line, as well as Bear Creek for a second time. 

Corridor segment E contains the Parkland Wentworth Cemetery, Ambridge Gun Club, and a flying site 

5 The two 345-kV transmission lines that would be constructed by ATC from the Superior Switching Station Site to 

a tap location on the existing Arrowhead to Stone Lake 345-kV transmission line are included in the cumulative 

impacts discussion in Chapter 4 of this EA.
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for the Duluth/Superior RC Club. South of CR Z, Corridor segment E continues to parallel existing 

transmission and pipeline ROW, as well as Lyman Lake Road, to the Parkland Switching Station area. 

This portion of the corridor contains a Wisconsin Department of Natural Resources (WDNR) wetland 

mitigation program property, woodland, and several residences along Lyman Lake Road and several 

adjacent roads. 

Each of the macro-corridors provided multiple opportunities to develop alignments for linear electricity 

transmission. As these facilities would be relatively short, the areas through which the macro-corridors 

extend are geographically proximate and were determined to have similar characteristics and resources. 

Each also contain existing infrastructure similar to that to be developed as part of the generation Project. 

All the macro-corridors were determined reasonable for potential route alignments and retained for 

further consideration during the environmental review process.

Within all the macro-corridor segments, existing linear facilities were present and could be followed for 

nearly the entire length of the proposed new transmission line between the generation sites and proposed 

switching stations. For the eastern macro-corridor, existing electricity transmission lines extended the 

entire distance from the Hill Avenue Site, through the Nemadji River Site continued to the Parkland 

switching station site. The western macro-corridor contained a combination of existing electricity 

transmission lines (Segments A, B, and D) along with an existing natural gas transmission corridor 

(Segment C). In keeping with the good routing practice of using or following existing linear infrastructure 

with new linear facilities, the most reasonable potential for electricity transmission line development 

would be following parallel to these existing facilities. Routes were identified adjacent to these existing 

linear facilities within the macro-corridors to quantify the potential impacts of development of the 

proposed line within each macro-corridor could reasonably be expected. Should deviations from these 

alignments be required, it is expected they would be for site specific issues or challenges, resulting in only 

minor changes to the potential impacts quantified. 

The FAA applies imaginary surfaces to public use airports to identify and protect the airspace from 

potential obstructions. Because both routes cross FAA obstruction identification surfaces, the airspace 

near the Richard I. Bong Airport (SUW) was evaluated to determine any height restrictions for the two 

alternative transmission line routes within the macro-corridors. Based on the ground elevation and the 

distance from the transmission line routes to the SUW runways, some structures in short sections of both 

routes within approximately two miles of the airport could be restricted to approximately 150 feet above 

ground level (agl). Obstruction identification surfaces are less restrictive further from the airport where 

structure heights could be up to approximately 200 feet agl without exceeding an obstruction surface. 
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However, the FAA would likely require marking and lighting for any structure that is greater than 200

feet agl, regardless of where it is located in proximity to SUW or any other public use airport. The Project 

is not anticipated to have any structures greater than 200 feet agl. Likewise, structures that are found to 

exceed a Part 77 obstruction surface but found to not have a substantial adverse effect upon the navigable 

airspace after further FAA study may be issued a determination of no hazard by the FAA with the 

condition that they are marked and lighted to improve visibility.

2.5 Identification of the Project Alternatives for Evaluation

Construction of the NTEC Project requires identification, consideration, and evaluation of sites for 

location of the generation facilities, as well as alignments for development of the necessary linear 

electricity transmission facilities. While generation sites were well defined parcels of land, transmission 

line macro-corridors were areas of land approximately 0.5-mile wide, considerably greater than the 130 

feet of right-of-way width actually required for the new 345-kV line. This difference in width was 

intended to provide flexibility for location of the actual transmission line following approval should 

unforeseen or previously unidentified obstacles be identified requiring minor deviations of the route. 

Location of the actual right-of-way, provided it remained within the macro-corridor approved, would be 

acceptable. 

For the Project, two generation sites, Nemadji River and Hill Avenue, were identified, as were two 

macro-corridors (eastern and western) for transmission line development. Each site was combined with 

each macro-corridor as a unique Project alternative for comparison and evaluation. These alternatives 

were (Figure 2-14):

• Hill Avenue 1: Hill Avenue Site combined with eastern macro-corridor (Segments A and E)

• Hill Avenue 2: Hill Avenue Site combined with western macro-corridor (Segments A, B, C, and 

D)

• Nemadji River 1: Nemadji River Site combined with eastern macro-corridor (Segments A and E)

• Nemadji River 2: Nemadji River Site combined with western macro-corridor (Segments A, B, C, 

and D)

The NTEC project originally selected wet cooling for the project using ground water as the water source 

because of its efficiency benefits, and economic advantages, and low environmental impacts. Due to 

concerns expressed by the Wisconsin Department of Natural Resource associated with withdrawing the 

quantities of groundwater required, NTEC evaluated other water supply options, including utilization of 

Municipal water, and furthered their earlier investigations of dry cooling.
Western Route

Hill Avenue

Alternative Route

Eastern Route

Superior Switching

Station Site

Parkland Switching

Station Site

Hill Avenue

Site

Nemadji River Site

COPYRIGHT © 2020 BURNS & McDONNELL ENGINEERING COMPANY, INC.

Source: South Shore Energy; MP; City of Superior 2019 aerial photography; Energy Velocity; Burns & McDonnell Engineering Company, Inc. Issued: 3/12/2020

Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\2_14_Project_Alternatives.mxd kasamuelson 3/12/2020

Figure 2-14

Project Alternative Sites,

Switching Stations, and

Transmission Line Routes

Location and Overview

Macro-Corridors

! !

Existing

Electric Transmission

Existing Pipeline

Generation Plant Site

Parkland

Switching

Station

Superior

Switching

Station

Electric Transmission Options

Hill Avenue Alternative Route

Western Route

Eastern Route

!

Lake

Superior

Area Enlarged

Wisconsin

Minnesota

Douglas

County

Superior

0 1,500 3,000

Feet

NORTH
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Dry cooling was selected as a result of these studies. Options utilization Municipal water supply from 

Superior Water Light and Power (SWL&P) were dismissed as they would require significant 

infrastructure upgrades, including a new larger pipeline from SWL&P’s Lake Superior water treatment 

plant to either Project site, and would require additional water allocations from Lake Superior, both of 

which would present significant permitting challenges as well as environmental and social disruptions. 

In dry cooling, a large finned heat exchanger with fans moving ambient air across the outside of the tubes 

and fins (like a radiator in a car) is used to reject the energy in the steam leaving the steam 

turbine. Removing energy in the steam causes the steam to condense inside the tubes. The steam needs 

to be condensed to allow pumping back up to the pressure needed by the heat recovery steam generator 

boiler (HRSG). Dry cooling would have the benefits of eliminating any fogging or rime ice associated 

with wet cooling, as well as reduce water requirements and discharge to and from the Project 

considerably.

Chapter 3 presents the potential impacts of each of the Project alternatives for comparison. For this EA, 

no preferred alternative is identified. RUS will consider this EA, any comments received, and the project 

record to determine a preferred alternative for the Project. 

Other agency approvals and permits must also be obtained for this project. The Public Service 

Commission of Wisconsin (PSCW) has previously approved alternatives for various components of the 

Project. On January 31, 2020, the PSCW issued its final decision on the generation facility (Docket 

Number 9698-CE-100). The Certificate of Public Convenience and Necessity (CPCN) application was 

approved and the PSCW authorized the Nemadji River Site as the location for NTEC. On January 30, 

2020, the PSCW issued its final decision on the electric transmission line for the Project (Docket Number 

9698-CE-101). The transmission line CPCN was approved and the PSCW authorized the eastern route.

On March 3, 2020, the PSCW issued its approval of a 16-in natural gas lateral to SWL&P (Docket 

Number 5820-CG-105) to supply natural gas to the NTEC generation facility as well as the 10-inch 

natural gas reroute required at the Nemadji River Site (Docket Number 5820-CG-106). As discussed later 

in this EA, additional approvals and permits will be required prior to Project construction and operation. 
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3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

Chapter 3 provides descriptions of the existing environmental conditions of the areas that may be 

impacted by constructing and/or operating the Project. This chapter provides an understanding of the 

affected environment and potential environmental consequences of each of the four Project alternatives

for the following resources: air quality; biological resources including vegetation, wildlife, and special 

status species; cultural resources; geology and soils; infrastructure, transportation, public health and 

safety; land use; noise; socioeconomics and environmental justice; visual resources; and water resources.

Federal, state, and local regulations that apply to managing these resources are also discussed in context 

of the existing environment.

As part of the PSCW application, the Owners were required to identify alignments within the macrocorridors for Project development and permitting. These alignments were surveyed and used to develop 

potential Project alternatives that could result from transmission line construction. The potential impacts 

of these linear alignments were combined with the Site alternatives to compare the overall Project impacts 

of each alternative. These Proposed Action Alternatives were:

• Hill Avenue 1: Hill Avenue Site combined with eastern macro-corridor (Segments A and E)

• Hill Avenue 2: Hill Avenue Site combined with western macro-corridor (Segments A, B, C, and 

D)

• Nemadji River 1: Nemadji River Site combined with eastern macro-corridor (Segments A and E)

• Nemadji River 2: Nemadji River Site combined with western macro-corridor (Segments A, B, C, 

and D)

Additionally, switching station sites associated with each macro-corridor included parcels approximately 

14 acres in size. Actual switching station footprint area will likely be approximately 4.4 acres. However, 

as final design and placement of each switching station on each parcel has not yet been determined, the 

potential environmental consequences associated with each switching station site have been estimated 

based on the entire 14 acre parcel to conservatively assess the potential human and natural resources 

effected at each site. Pending final design, the actual impacts associated with each switching station sites 

are anticipated to be somewhat less than those presented. 

The geographical setting for each resource is defined in this chapter for each of these proposed generation 

site, transmission corridor, and switchyard alternatives. The geographical setting may differ for each 

resource, and for each component of the Project. RUS will approve the site for the power plant and a 

corridor within which to locate the new transmission facilities. In a related action, the PSCW approved a
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specific site and transmission route within the proposed corridors under their review and permitting 

processes. Therefore, RUS is considering the geographical settings for the transmission line portion of 

this project as 0.5-mile-wide corridors instead of a specific route centerline (Figure 2-7).

This chapter assesses the potential impacts of the No Action Alternative and the Proposed Action

Alternatives. The No Action Alternative provides a basis for comparison in which none of the Project 

components would be constructed.

3.1 Air Quality

The air quality of the area surrounding the Project along with the impacts on air quality as a result of the 

Project are discussed in the following sections.

3.1.1 Affected Environment

The federal government established the National Ambient Air Quality Standards (NAAQS) under the 

Clean Air Act to protect public health (including the sensitive populations such as asthmatics and the 

elderly), safety, and welfare from known or anticipated effects of eight air pollutants: sulfur dioxide 

(SO2), particulate matter 10 microns or less in diameter (PM10), particulate matter 2.5 microns or less in 

diameter (PM2.5), carbon monoxide (CO), nitrogen dioxide (NO2), ozone, lead (Pb), and greenhouse gases 

(GHGs). Douglas County is in attainment, meaning that the area is in compliance with federal clean air 

standards for all of these criteria pollutants.

Class I areas are protected more stringently than under the NAAQS. Class I areas include national parks, 

wilderness areas, and other areas of special national and cultural significance. There are four Class I areas 

and one non-Federal Class I area that are within 300 kilometers of the Nemadji River Site and Hill 

Avenue Site. The respective distances are shown in Table 3-1. 

Table 3-1: Distance from Project Sites to Class I Areas

Class I Area

Nemadji River 

Site 

(kilometers)

Hill Avenue 

Site 

(kilometers)

Rainbow Lake Wilderness, Wisconsin 60 63

Boundary Waters Canoe Area Wilderness, Minnesota 126 125

Voyageurs National Park, Minnesota 182 180

Isle Royale National Park, Michigan 237 238

Forest County Potawatomi Community Reservation, 

Wisconsin 261 263
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Non-industrial primary pollutants in the area may include particulates (i.e., dust) generated from farming, 

traffic on unpaved roads, wind erosion, and smoke from burning trash or ground cover. These sources 

produce pollution that is temporary and intermittent.

3.1.2 Environmental Consequences

The following sections provide potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to air quality.

3.1.2.1 Proposed Action Alternatives

Air dispersion modeling was performed using the latest version of AERMOD (Version 18081). The 

AERMOD model is an EPA-approved, steady-state Gaussian air dispersion model that is designed to 

estimate downwind ground-level concentrations from single or multiple sources using detailed 

meteorological data. AERMOD is a model currently approved for industrial sources and Prevention of 

Significant Deterioration (PSD) permits. The WDNR requested that the Owners demonstrate regulatory 

compliance through its use. 

Construction and operation of the proposed 625-megawatt combined-cycle combustion turbine and 

associated support equipment at either Project Site would be subject to applicable state and Federal air 

quality regulations. These regulations would apply to the Project equipment, which would include a 

combustion turbine, a finned heat exchanger for cooling, an auxiliary boiler, two natural gas-fired gas 

heaters (natural gas heater), an emergency diesel fire pump, an emergency diesel generator, and fuel oil 

storage tanks. Regulations applicable to the proposed Project are Wisconsin Administrative Code (WAC) 

provisions, Title V Operating Permits, PSD review, New Source Performance Standards (NSPS), and 

National Emission Standards for Hazardous Air Pollutants and Maximum Achievable Control 

Technology (NESHAP).

3.1.2.1.1 Construction

During construction of the plant, transmission line, and switching station, small amounts of air pollutants, 

including GHGs, would be temporarily generated. Temporary increases in fugitive dust from ground 

disturbing activities and combustive emissions from construction equipment would be generated at the 

generation site, along the transmission line ROW, and at the switching station site. These construction 

emissions would be temporary in nature, would fall off rapidly with distance from construction areas, and 

are not anticipated to result in long-term impacts. Once the construction activities are completed, 

construction-related emissions would cease.
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Project Alternatives using the Western Transmission Route and/or the Hill Avenue Site (Hill Avenue 1, 

Hill Avenue 2, and Nemadji River 2) would have slightly longer transmission line which would result in a 

slight increase in construction related air pollutants as construction would likely take additional time to 

complete.

3.1.2.1.2 Operation

The proposed 625-megawatt combined-cycle combustion turbine and associated support equipment 

requires a PSD major source construction air permit. The PSD permit application contains the following 

analyses/assessments regarding emissions of regulated pollutants associated with the construction and 

operation of the Project: 

• Evaluation of ambient air quality in the area for each regulated pollutant for which the Project 

will result in a significant net emissions increase

• Demonstration that emissions increases resulting from the Project will not cause or contribute to 

an increase in ambient concentrations of pollutants exceeding the remaining available PSD 

increment and the NAAQS

• Assessment of any adverse impacts on soils, vegetation, visibility, and growth in the area

• A Best Available Control Technology (BACT) analysis for each regulated pollutant for which the 

Project will result in a significant net emissions increase

The Project would include a combustion turbine, a dry cooling heat rejection system (finned heat 

exchanger), an auxiliary boiler, two natural gas-fired gas heaters (natural gas heater), an emergency diesel 

fire pump, an emergency diesel generator, and fuel oil storage tanks. The WDNR provided notification of 

the air permit approval on September 1, 2020 (Appendix A).The Owners will comply with the issued 

WDNR construction air permit that includes emission limitations, monitoring requirements, and other 

terms and conditions. A variety of strategies to control emissions from Project equipment would be 

implemented. These are discussed below for each source that has emissions of air contaminants.

The combustion turbine and duct burner would be controlled as follows: 

• NOx – Low-NOx burners (natural gas), SCR, water injection (fuel oil)

• CO – Good combustion practices,6 oxidation catalyst

6

“Good combustion practices” and “good combustion control measures” entail operating the units according to 

manufacturer’s recommendations and generally accepted industry practices thereby achieving thermal efficiencies as 

designed. This will vary amongst the various emission units, thus manufacturer’s recommended operation for good 

combustion will be followed separately for each unit, once final decisions are made on vendor make/model.
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• Particulate matter (PM)/particulate matter less than 10 microns (PM10)/ particulate matter less 

than 2.5 microns (PM2.5) – Combustion controls, low ash fuels

• VOC – Good combustion practices, oxidation catalyst

• Sulfuric acid (H2SO4) mist – Good combustion practices and low sulfur fuel

• Greenhouse gases (equivalent carbon dioxide [CO2e]) – Use of natural gas and ultra-low sulfur 

diesel as a fuel, monitoring and control of excess air, efficient turbine design, catalytic oxidation

• Opacity – Low NOx burners, SCR, combustion controls, low ash fuels

The natural gas heaters would be controlled as follows: 

• NOx –Ultra-low NOx burners, good combustion practices, clean fuel, flue gas recirculation

• CO – Good combustion practices, clean fuel

• Particulate matter (PM)/particulate matter less than 10 microns (PM10)/ particulate matter less 

than 2.5 microns (PM2.5) – Good combustion practices, clean fuel 

• VOC – Good combustion practices, clean fuel

• Sulfuric acid (H2SO4) mist – Good combustion practices, clean fuel 

• Greenhouse gases (equivalent carbon dioxide [CO2e]) – Good combustion practices, clean fuel

• Opacity – Good combustion practices, clean fuel

There are no air emission from dry cooling (finned heat exchanger).

The emergency diesel-fired fire pump would be controlled as follows: 

• NOx – Good combustion practices, clean fuel

• CO – Good combustion practices, clean fuel

• Particulate matter (PM)/particulate matter less than 10 microns (PM10)/ particulate matter less 

than 2.5 microns (PM2.5) – Good combustion practices, clean fuel 

• VOC – Good combustion practices, clean fuel

• Sulfuric acid (H2SO4) mist – Good combustion practices, clean fuel 

• Greenhouse gases (equivalent carbon dioxide [CO2e]) – Good combustion practices, clean fuel

• Opacity – Good combustion practices, clean fuel

The emergency diesel-fired generator would be controlled as follows: 

• NOx – Good combustion practices, clean fuel

• CO – Good combustion practices, clean fuel
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• Particulate matter (PM)/particulate matter less than 10 microns (PM10)/ particulate matter less 

than 2.5 microns (PM2.5) – Good combustion practices, clean fuel 

• VOC – Good combustion practices, clean fuel

• Sulfuric acid (H2SO4) mist – Good combustion practices, clean fuel 

• Greenhouse gases (equivalent carbon dioxide [CO2e]) – Good combustion practices, clean fuel

• Opacity – Good combustion practices, clean fuel

The following sulfur hexafluoride (SF6) containing equipment is proposed at each site: 

• Three 345-kV circuit breakers are proposed for the substations located at each site. The substation 

circuit breakers will be monitored via a pressure switch and alarms. 

• Two 19-kV (estimate) low-side generator circuit breakers will be located in the plant at each site 

before the step-up transformers that feed the onsite switchyard. The generator circuit breakers 

will be monitored via a pressure switch and alarms. 

Each of the circuit breakers will contain SF6. SF6 is a potent greenhouse gas with a global warming 

potential of 22,800 times that of CO2. The circuit breakers are state-of-the-art and will be sealed and, 

therefore, SF6 leakage will be minimized. The circuit breakers will each be equipped with a two-stage 

pressure switch with a low pressure alarm to indicate a potential leak. Modern circuit breakers and 

switches are designed as totally enclosed-pressure containing systems with far lower potential for SF6

emissions than older circuit breakers. The current International Electrotechnical Commission (IEC) 

standards are that new equipment be built to low leakage limits (less than 0.5 percent per year). The 

effectiveness of these leak-tight closed systems is further enhanced by equipping them with an alarm that 

provides a warning when SF6 has leaked from the breaker. The Project will also include six disconnect 

switches at each substation site; however, the switches are open air type switches and do not contain SF6.

The NAAQS are set by the EPA to protect human health and public welfare. The PSD increment 

constitutes the maximum allowable ambient air quality concentration increase that may occur for a given 

pollutant above a baseline concentration. To determine if the Project would contribute to a NAAQS or 

PSD Class II increment exceedance, the Project was modeled along with the appropriate existing sources 

in the area (Table 3-2 and Table 3-3). This was performed for the Nemadji River Site and the Hill Avenue 

Site in two phases – an initial screen and then a refined model for pollutants with averaging periods that 

exceeded the modeling significance level. 

A Class I Increment screening analysis for the Nemadji River Site and the Hill Avenue Site to determine 

if further analysis is required was performed for the four Class I areas and one non-Federal Class I area
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(Table 3-4). Based on the screening analysis for both sites, it was determined that the impacts from the 

Project would not significantly impact the PSD Class I Increment at the surrounding Class I areas and do

not require further analysis (SSE, Dairyland, and Burns & McDonnell Engineering, 2019a). 

Based on the conservative modeling results for both sites, it has been predicted that the Project would

have minimal effects on the NAAQS and PSD Class I and Class II Increment (Table 3-2, Table 3-3, and 

Table 3-4; SSE, Dairyland, and Burns & McDonnell Engineering, 2019a).
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Table 3-2: NAAQS Modeling Results

Site Pollutant Averaging 

Period

UTM 

Coordinatesa

Easting (Meters) 

UTM 

Coordinatesa

Northing 

(Meters)

Year

Predicted 

Concentration

micrograms 

per cubic 

meter (μg/m3)

Background 

Concentration

micrograms per 

cubic meter 

(μg/m3)

Total 

Concentration

micrograms per 

cubic meter 

(μg/m3)

NAAQS

micrograms 

per cubic 

meter 

(μg/m3)

Nemadji 

River 

Site

NO2 Annual 570,600.0 5,170,800.0 2013 --

b

--

b 56.8 100

Nemadji 

River 

Site

NO2 1-hour 565,500.0 5,181,500.0 5 

years

2,858.7 --

b 164.9c 188

Nemadji 

River 

Site

CO 8-hour 572,275.0 5,171,075.0 2011 4,990.0 1,191.20 4,049.94 10,000

Nemadji 

River 

Site

CO 1-hour 572,875.0 5,171,525.0 2015 6.5 1,362.70 6,352.74 40,000

Nemadji 

River 

Site

PM10 24-hour 569,750.0 5,175,250.0 2014 0.9 47 53.5 150

Nemadji 

River 

Site

PM2.5 Annual 569,750.0 5,175,250.0 5 

years

4.7 9.4 10.3 12

Nemadji 

River 

Site

PM2.5 24-hour 570,000.0 5,175,250.0 5 

years

--

b 23.6 28.3 35

Hill 

Avenue 

Site

NO2 Annual 570,600.0 5,170,800.0 2013 --

b

--

b 56.87105 100
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Site Pollutant Averaging 

Period

UTM 

Coordinatesa

Easting (Meters) 

UTM 

Coordinatesa

Northing 

(Meters)

Year

Predicted 

Concentration

micrograms 

per cubic 

meter (μg/m3)

Background 

Concentration

micrograms per 

cubic meter 

(μg/m3)

Total 

Concentration

micrograms per 

cubic meter 

(μg/m3)

NAAQS

micrograms 

per cubic 

meter 

(μg/m3)

Hill 

Avenue 

Site

NO2 1-hour 565,500.0 5,181,500.0 5 

years

3,402.9 --

b 164.90665c 188

Hill 

Avenue 

Site

CO 8-hour 570,719.50 5,172,533.90 2011 5,530.0 1,191.20 4,594.09 10,000

Hill 

Avenue 

Site

CO 1-hour 571,800.00 5,172,200.00 2011 6.5 1,362.70 6,892.72 40,000

Hill 

Avenue 

Site

PM10 24-hour 569,750.0 5,175,250.0 2014 0.9 47 53.5 150

Hill 

Avenue 

Site

PM2.5 Annual 569,750.0 5,175,250.0 5 

years

4.7 9.4 10.3 12

Hill 

Avenue 

Site

PM2.5 24-hour 570,000.0 5,175,250.0 5

years

4.7 23.6 28.3 35

(a) UTM = Universal Transverse Mercator: NAD83

(b) HROFDY & MONTH background data used; therefore, the modeled impact is presented as project impacts and background combined.

(c) ARM2 methodology was applied to the model.
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Table 3-3: PSD Class II Increment Modeling Results

Site

Pollutant

Averaging 

Period

UTM 

Coordinatesa

Easting

(Meters)

UTM 

Coordinatesa

Northing 

(Meters)

Year

Predicted

Concentration

micrograms per 

cubic meter (μg/m3

)

PSD Class II 

Increment 

micrograms per cubic 

meter (μg/m3

)

Nemadji 

River

Site

NO2 Annual 570,600.0 5,170,800.0 2013 8.2 25

Nemadji 

River

Site

PM10 24-hour 572,425.0 5,171,075.0 2011 8.5 30

Nemadji 

River

Site

PM2.5 Annual 572,641.5 5,170,971.8 2013 0.6 4

Nemadji 

River

Site

PM2.5 24-hour 572,425.0 5,171,075.0 2011 8.5 9

Hill 

Avenue 

Site

NO2 Annual 570,600.0 5,170,800.0 2013 8.2 25

Hill 

Avenue 

Site

PM10 24-hour 570,719.5 5,172,533.9 2011 8.6 30

Hill 

Avenue 

Site

PM2.5 Annual 570,644.7 5,172,471.2 2011 0.6 4

Hill 

Avenue 

Site

PM2.5 24-hour 570,719.5 5,172,533.9 2011 8.6 9

(a) UTM = Universal Transverse Mercator: NAD83

Table 3-4: Class I Modeled Screening Impacts and Class I Significant Impact Level

Site Pollutant Averaging Time

Maximum Modeled 

Concentration

(μg/m3)

Class I 

Significant 

Impact Level1

Preferred Site

NO2

a Annual 0.03 0.1

PM10

24-hour 0.26 0.3

Annual 0.02 0.2

PM2.5

24-hour 0.22 0.272

Annual 0.02 0.052

Alternate Site NO2

a Annual 0.03 0.1
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PM10

24-hour 0.3 0.3

Annual 0.02 0.2

PM2.5

24-hour 0.23 0.272

Annual 0.02 0.052

Sources:

(1) EPA. Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NSR) 

Proposed Rulemaking, July 23, 1996. (61 FR 38249).

(2) EPA Memorandum, 2018a, “Guidance on Significant Impact Levels for Ozone and Fine Particles in the 

Prevention of Significant Deterioration Permitting Program.”

(a) Modeled as NOx.

During operation, employees would travel to the Project site, creating vehicle emissions at the beginning 

and end of work shifts. Up to 25 full-time permanent employees would be hired for the Project. 

Inspections and maintenance on the transmission line and switching station would also require employees 

to travel to the area, creating vehicle emissions. These vehicle emissions would be intermittent in nature, 

would fall off rapidly with distance from Study Area. As such, it is not anticipated that vehicle emissions 

during operation of the Project would contribute considerably to air quality impacts in the area. 

A variety of emissions resulting from Project operation are considered GHGs. These may include water 

vapor, carbon dioxide (CO2), methane, nitrous oxide, ozone, hydrocarbons, and chlorofluorocarbons. 

GHG emissions from the Project combustion equipment are due to CO2, methane (CH4), and nitrogen 

oxide (N2O) emissions. These calculated GHG emissions were ratioed with their appropriate global 

warming potential (GWP) and summed to obtain the overall project carbon dioxide equivalent (CO2e)

emissions. Consistent with Wisconsin and EPA guidance, air dispersion modeling of CO2e was not 

conducted since there is no modeling threshold for this pollutant. Also as previously noted, equipment 

containing SF6, a GHG, will be part of this Project. Due to the limited leakage anticipated from SF6

containing equipment, only limited, if any, air quality and climate impacts are expected from SF6 from the 

Project.

3.1.2.1.3 Summary of Air Impacts

The existing air quality in the Douglas County area is designated as attainment or unclassifiable in regard 

to the NAAQS for all criteria pollutants. Construction of the Project has the potential for short-term 

adverse effects on air quality in the immediate area around the site. Minor and temporary generation of 

criteria pollutants and GHGs would occur during construction. Based on modeling of Project operation, it 

is anticipated that the Project would not affect the attainment status for Douglas County. The WDNR 

provided notification of the air permit approval on September 1, 2020 (Appendix A).The Owners will 

comply with the issued WDNR construction air permit that will include emission limitations, monitoring 

requirements, and other terms and conditions. Based on the analyses above, it is anticipated that the 
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Project would not cause or contribute to significant adverse ambient air quality impacts. The Class II 

modeling also considered cumulative effects of other existing and proposed sources, indicating the Project

would not cumulatively contribute to significant adverse air quality impacts.

3.1.2.2 No Action Alternative

The No Build Alternative would have no short-or long-term impacts to air because no construction or 

operation would occur.

3.1.3 Mitigation

During construction, steps will be taken to prevent excessive emissions of particulate matter resulting 

from construction activities and vehicular traffic. These steps may include compacting, seeding, covering, 

paving, wetting, sweeping, or otherwise controlling particulate matter emissions. 

Post-construction, the areas disturbed during construction will receive final cover to eliminate dust. All 

exposed soil areas will be seeded to grow grass, lesser-traveled road surfaces will be graveled and 

compacted, and the new main roads on-site will be surfaced with asphalt. The roads will be monitored 

and either wetted or swept to clean any fugitive dust that may occur due to on-site wheeled traffic. 

The SCR and oxidation catalyst will be integrated into the HRSG design by the supplier of the HRSG. 

The HRSG supplier will also provide ports in the stack to monitor HRSG stack emissions. The CEMS 

will monitor the HRSG NOx stack emissions through these ports.

The Project will require a PSD major source construction air permit pursuant to the requirements 

specified in the WAC Chapter Natural Resources (NR) 405. The PSD permit application contains the 

following analyses/assessments regarding emissions of regulated pollutants associated with the 

construction and operation of the Project: 

• Evaluation of ambient air quality in the area for each regulated pollutant for which the Project 

will result in a significant net emissions increase

• Demonstration that emissions increases resulting from the Project will not cause or contribute to 

an increase in ambient concentrations of pollutants exceeding the remaining available PSD 

increment and the NAAQS

• Assessment of any adverse impacts on soils, vegetation, visibility, and growth in the area

• A BACT analysis for each regulated pollutant for which the Project will result in a significant net 

emissions increase
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The Owners submitted the PSD permit application for the Project to WDNR and will adhere to conditions 

and requirements of the application during operation of the Project. The WDNR provided notification of 

the air permit approval on September 1, 2020 (Appendix A).

3.2 Biological Resources

The biological resources of the area surrounding the Project along with the impacts on biological 

resources as a result of the Project are discussed in the following sections.

3.2.1 Affected Environment

The following sections discuss vegetation, wildlife, and special status species within the Study Area.

3.2.1.1 Vegetation

White spruce (Picea glauca), balsam fir (Abies balsamea), and eastern white pine (Pinus strobus), species 

that were the dominant canopy trees prior to the Cutover of the late 1800’s (WDNR, 2010), are absent 

from the Study Area. Based on the results of the field surveys that occurred for the Project, the native 

boreal coniferous forests that would have historically occurred within the Study Area have been replaced 

by more monotypic stands of quaking aspen (Populus tremuloides). The understory of the quaking aspen 

dominated forests in the Study Area include shrub species such as common buckthorn (Rhamnus 

cathartica) shrubs, gray or speckled alder (Alnus incana) shrubs, western brackenfern (Pteridium 

aquilinum), bigleaf aster (Eurybia macrophylla), and stinging nettle (Urtica dioica). Within the Study 

Area, the quaking aspen trees are typically up to 20 to 30 feet tall and 12 inches diameter at breast height.

The grasslands that are within the Study Area occurred within previously disturbed areas or existing, 

maintained utility corridors. These areas were typically dominated by reed canarygrass (Phalaris 

arundinacea). Other species present within the upland grasslands of the Study Area include Canada 

goldenrod (Solidago canadensis) and Canada thistle (Cirsium arvense). Wetland grasslands typically 

include woolgrass (Scirpus cyperinus) and broadleaf cattail (Typha latifolia). Canada thistle is an invasive 

species along with ribbon grass (Phalaris arundinacea), common buckthorn (Rhamnus cathartica), and 

garden heliotrope or Valerian (Valeriana officinalis), all of which are also observed during surveys.

3.2.1.2 Wildlife

Different species thrive under different conditions, from old growth to recently disturbed. The Study Area 

has been previously disturbed by the installation of underground and overhead utilities, industrial and 

commercial areas, past logging, and the nearby City of Superior. The forests within the vicinity of the 

study area are dominated by quaking aspen. Many species likely to be found in the Study Area prefer 
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quaking aspen forests because of the cover and food that dense stands of quaking aspen provide. Whitetailed deer (Odocoileus virginianus), eastern cotton tails (Sylvilaagus floridanus), and North American 

beaver (Castor canadensis) also consume the bark, catkins, leaves, and sprouts of quaking aspen (WDNR, 

2019a). Ruffed grouse (Bonasa umbellus) prefer aspen forests for cover for their broods and food, 

consuming catkins during winter months. Other species that are tolerant of human activity and thrive in 

developed areas and adjacent forests include black-capped chickadees (Poecile atricapillus), red-brested 

and white-breasted nuthatches (Sitta canadensis and S. carolinensis), downy and hairy woodpeckers

(Dryobates pubescens and D. villosus), red fox (Vulpes vulpes), and the common racoon (Procyon lotor).

3.2.1.3 Special Status Species

According to the U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation 

(IPaC) website, there are seven threatened or endangered species protected under the Endangered Species 

Act that are known or likely to occur in Douglas County (Table 3-5; Appendix B); Of those seven 

federally-listed species, four are listed as threatened and three are listed as endangered. Four of the 

federally-listed species are also listed by the WDNR as either endangered or threatened; three are 

considered endangered and one is considered threatened by the State of Wisconsin. RUS initiated 

consultation with USFWS under Section 7 of the Endangered Species Act and prepared a Biological 

Assessment. The Biological Assessment was submitted for USFWS review and concurrence on June 24, 

2020. The USFWS concurred with the Biological Assessment on September 2, 2020, indicating potential 

impacts to the northern long-eared bat would be covered under the January 5, 2016, Programmatic 

Biological Opinion on Final 4(d) Rule for the Northern long-eared Bat and Activities Excepted from Take 

Prohibitions. USFWS determined the project would have no impacts to other identified species 

(Appendix B).

In addition to the seven federally listed threatened or endangered species, nesting migratory birds, which 

are protected under the Migratory Bird Treaty Act (MBTA) (Federal Register, 2013), and bald and golden 

eagles, which are protected under the Bald and Golden Eagle Protection Act (BGEPA), could occur in the 

Study Area. Endangered Resources (ER) Reviews of the Study Area were completed by a Wisconsin 

certified environmental reviewer. The ER Reviews were submitted to the WDNR Bureau of Endangered 

Resources and responses, including the Certified ER Reviews (ER Log number 20-415), was received on 

June 2, 2020. 
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Table 3-5: Threatened and Endangered Species in Douglas County

Common 

Name

Scientific 

Name

Federal 

Status1

State 

Status2 Habitat Requirements3

Canada 

lynx

Lynx 

canadensis LT SC/FL

The distribution of lynx in North America is closely associated with the distribution of 

North American boreal forest. The range of lynx populations extends into the 

boreal/hardwood forest ecotone in the eastern United States. Within this forest type, lynx 

are most likely to occur in areas that receive deep snow and have high-density populations 

of snowshoe hares, the principal prey of lynx. The Canada lynx is not tracked by NHI.

Gray wolf Canis lupus LE SC/FL

The wide range of habitats in which gray wolves can thrive reflects their adaptability as a 

species, and includes temperate forests, mountains, tundra, taiga, and grasslands. Most 

areas of large contiguous forest in northern and central Wisconsin appear suitable for 

wolves, although they do more readily select the most remote areas on the landscape for 

establishing territories and raising pups. Wolf packs select areas with a high percentage of 

forest and other wildlands (generally > 90% wildlands), low densities of roads, low human 

densities, and few farms. Wolves seem to avoid urban areas, lakes with extensive 

development, and other developed landscapes.

Northern 

longeared bat

Myotis 

septentrionalis LT THR

Northern long-eared bat (NLEB) habitat use changes over the course of the year and varies 

based on sex and reproductive status. During the summer, NLEB forage and roost in 

forests and woodland stream corridors where snags and tree species with exfoliating bark 

are present. NLEB roost under exfoliating bark and in the cavities of live trees and snags 

with a diameter at breast height (dbh) of three inches or greater. NLEB forage for insects 

in forests, along stream corridors, over ponds, and at the edges of forests and farm fields. 

This species has also been found roosting in structures like barns and sheds. During the 

winter, NLEB hibernate in caves and abandoned mines.

Kirtland’s 

warbler

Setophaga 

kirtlandii LE END

The Kirtland's warbler is a songbird that nests in young jack pine stands in Michigan, 

Wisconsin, and Ontario, Canada. It requires large stands of young, dense jack pine forest 

at least 80 acres in size, but prefers stands of 300 to 400 acres, or larger. They migrate 

from their nesting grounds to the southeastern coast of the United States on their way to 

wintering grounds in the Bahamas. The recommended avoidance period is from May 1 -

August 30.

Piping 

plover

Charadrius 

melodus LE END

The piping plover prefers large isolated cobble beaches on the shores of Lakes Michigan 

and Superior. The recommended avoidance period is from late May to mid-July. 

Additionally, the USFWS has designated critical habitat for the piping plover along 

portions of the shoreline of Lake Superior in Douglas County.
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Common 

Name

Scientific 

Name

Federal 

Status1

State 

Status2 Habitat Requirements3

Rufa red 

knot

Calidris 

canutus rufa LT SC/FL

Rufa Red Knot is an Arctic breeder that occurs uncommonly in Wisconsin during 

migration along coastal sandy beaches of Lake Superior and Lake Michigan from midMay to early June in spring and from mid-July to early November in fall. Since this 

subspecies does not breed in Wisconsin, avoidance dates do not apply. The red knot is not 

tracked by NHI.

Fassett’s 

locoweed

Oxytropis 

campestris 

var. chartacea

LT END

Fassett's Locoweed is found in sandy, fluctuating lakeshores. Its appearance is sporadic 

depending on water level. Blooming occurs early May through late June; fruiting occurs 

late June through late July. The optimal identification period for this species is late May 

through late July.

Source: USFWS Information for Planning and Consultation (IPac) Website (https://fpdss.fws.gov/ipac/) Species List for Douglas County and WDNR Wisconsin 

Natural Heritage Working List (https://dnr.wi.gov/topic/NHI/documents/NHIWorkingList.pdf)

1 Federal Status: LT = Threatened; LE = Endangered; Federally threatened and endangered species are protected under the Federal Endangered Species Act 

(ESA).

2 State Status: END = Endangered; THR = Threatened; SC = Special Concern; SC/FL = federally protected as endangered or threatened, but not so designated by 

DNR. Species state-listed as Endangered (END) or Threatened (THR) are legally protected (Ch. 29.604 Wis.Stats.). The taking of an END or THR animal 

(whether vertebrate or invertebrate) is prohibited on any lands or waters (public or private) without WDNR authorization. The taking of an END or THR 

plant is prohibited only on public lands, except in the course of forestry, agriculture practices, or in the construction, operation, or maintenance of a utility 

facility.

3 Habitat Requirements includes habitat information taken from the USFWS, Wisconsin DNR Bureau of Endangered Resources Biodiversity webpages, 

Wisconsin All-Bird Conservation Plan, Minnesota DNR Rare Species Website, and NatureServe species accounts for each species, natural community, and 

other feature.
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3.2.2 Environmental Consequences

The following sections provide potential environmental consequences of the Project Action Alternatives 

and No Action Alternative related to biological resources.

3.2.2.1 Proposed Action

Construction and operation of the Project would result in the permanent loss of vegetation communities, 

wildlife habitat, and plant and animal populations within the construction footprint. Additionally, some of 

the wildlife communities that occur at and in the vicinity of the Project would be temporarily displaced to 

surrounding areas where habitat is available. 

Existing vegetation would be altered at and along each Action Alternative. Construction of the proposed 

project at the Nemadji River Site would permanently impact approximately 7.1 acres of forest 

(approximately 4.6 acres of the quaking aspen forest in the northeastern portion of the site and 

approximately 2.5 acres of the mixed quaking aspen and black willow forest in the southeastern portion of 

the site) as well as impact approximately 7.2 acres of the forage grassland and wetland meadow 

communities (Figure 2-8). The proposed project footprint at the Nemadji River Site avoids clearing trees 

and vegetation along the banks, immediately adjacent to the Nemadji River. A vegetation buffer with a 

minimum width of 100 feet would be maintained between the proposed project footprint and the Nemadji 

River. For the Nemadji River Site, the loss of plant and animal habitat would occur adjacent to existing 

areas that have already been developed. The Nemadji River Site is adjacent to an existing tank farm and 

utility corridors. This area has experienced some level of habitat fragmentation associated with 

development in and around the City of Superior.

Based on the results of a site survey that was conducted in October 2017, the Hill Avenue Site consists 

entirely a lowland scrub/shrub wetland community. No forest or grassland community occurs at the Hill 

Avenue Site. The Eastern Transmission Route for the transmission line would likely be constructed 

within an existing utility corridor that contains a natural gas pipeline and overhead electrical transmission 

lines; however, approximately 23.1 acres of woody vegetation would be cleared from forested lands and 

shrubland habitats to widen the corridor and accommodate the additional line. Woody vegetation would 

be removed where additional, new ROW is needed and along the edges of the existing utility corridor. 

The Western Transmission Route would require more clearing in forested areas for new ROW in addition 

to minor impacts to forested land along the existing shared utility corridors. Woody vegetation clearing 

would occur along approximately 79.1 acres of the Western Transmission Route in forested lands and 
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shrubland habitats. Woody vegetation would be removed where additional, new ROW is needed and 

along the edges of the existing utility corridor.

The Hill Avenue Site Route would require clearing in forested areas for new ROW and along the existing 

shared utility corridors. Woody vegetation clearing would occur along approximately 14.3 acres of the 

Hill Avenue Site Route in forested lands and shrubland habitats.

Construction of either the Superior Switching Station or the Parkland Switching Station would impact 

approximately 14 acres of woody vegetation in forested lands and shrubland habitats. No grassland 

habitat is present within the footprint of either switching station site.

Temporary impacts from the Project could occur as a result of the increased presence of human and 

vehicle disturbance during construction. Temporary displacement of species might occur due to increased 

human activity in the area, vehicle traffic, and material transfer. Impacts to wildlife as a result of vehicle 

collisions would also be an increased risk during construction and operation. The majority of species 

affected would be mobile and able to move away from any impacts, but others could be vulnerable. 

Permanent impacts during the construction and maintenance of the Project would occur for some wildlife 

currently utilizing the ROW due to habitat loss. Wildlife permanently impacted could include deer, 

racoon, fox, nesting birds, invertebrates, small mammals, reptiles, and amphibians. It is anticipated that 

most of the impacts to grasslands along the transmission route would only be temporary construction 

impacts to existing grassland habitat along existing utility corridors. Some permanent impacts to 

grassland habitats would occur where transmission line poles and foundations would be set. The 

transmission line ROW would be revegetated as described in Section 3.2.3.4. Wildlife previously using 

the ROW may return to the area after temporary impacts subside.

3.2.2.2 Special Status Species

The following sections discuss the potential impact of the Project on each of the protected species listed 

above in Table 3-5 as well as eagles, other migratory birds, and invasive species.

3.2.2.2.1 Canada Lynx

The Project is not anticipated to affect the Canada lynx because suitable habitat for the Canada lynx, 

which includes large tracks of boreal/hardwood forest with high-density populations of snowshoe hares, 

is not present within the Study Area. The Study Area includes forest separated by public roads and 

developed areas in the City of Superior and surrounding townships. The Canada lynx is not tracked by 

WDNR NHI.
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3.2.2.2.2 Gray Wolf

The Project is not anticipated to affect the gray wolf because large contiguous tracks of forest are not 

present within the Survey Area. Forested areas within the Survey Area are separated by rural residences, 

public roads, and developed areas in the City of Superior and surrounding townships. The gray wolf is 

known to occur in Douglas County, away from populated areas in and around the City of Superior. 

According to WDNR NHI data, no den sites have been recorded in the vicinity of the Survey Area.

3.2.2.2.3 Northern Long-eared Bat

Forested areas adjacent to the Project could provide potential habitat for the northern long eared bat. 

Snags that include potential summer roost trees for the northern long-eared bat were observed during the 

site visit along Bear Creek, adjacent to Study Area. No potential summer roost habitat was observed at 

either proposed facility site. No caves were identified within the Study Area.

3.2.2.2.4 Kirtland’s Warbler

The Project is not anticipated to affect the Kirtland’s warbler because no jack pine stands are present in 

the Study Area.

3.2.2.2.5 Piping Plover

The Project is not anticipated to affect the piping plover because no suitable beach or shore habitat is 

present in the Study Area. Additionally, the Project would not result in the adverse modification to the 

designated critical habitat for the piping plover that occurs along the shores of Lake Superior because the 

Project does not occur within or adjacent to the designated critical habitat for the piping plover.

3.2.2.2.6 Rufa Red Knot

The Project is not anticipated to affect the rufa red knot because no beach or shore habitat is present in the 

Study Area.

3.2.2.2.7 Fassett's Locoweed

The Project is not anticipated to affect Fassett's locoweed because no open sandy lakeshores or beach 

habitat is present in the Study Area.

3.2.2.2.8 Eagles

The BGEPA is enforced by the USFWS. Both the bald eagle (Haliaeetus leucocephalus) and golden eagle 

(Aquila chrysaetos) may occur in Douglas County. In the State of Wisconsin, bald eagles are generally 

found nesting or roosting in forested areas near large bodies of water. Potential bald eagle nesting habitat 

is present along Nemadji River; however, no bald eagle nests were observed during field surveys that 
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occurred within the Study Area. Golden eagles are considered a nonbreeding, infrequent inhabitant in

Wisconsin and are found wintering in more rugged, bluff areas along major rivers and the edges of 

woodland-scrub habitat in valley floors, riparian areas, and over areas dominated by shrub. No golden

eagle nests were observed during field surveys that occurred within the Study Area.

3.2.2.2.9 Migratory Birds

The MBTA is enforced by the USFWS. Migratory birds generally occupy areas of breeding and foraging 

habitats. Douglas County has woodland, wetland, and agricultural areas that provide suitable nesting and 

foraging habitats for a variety of migratory birds and waterfowl during the breeding, migration, and 

overwintering seasons.

3.2.2.2.10 Invasive Species

An invasive species survey identified invasive plant species along the transmission route alternatives and 

near the Switching Station Alternatives. The review was completed in September 2016 and October 2017 

during wetland delineation field surveys. The dominate invasive plant species observed was reed 

canarygrass (Phalaris arundinacea) which is listed as a nonregulated wetland invasive species by the 

WDNR. Canada thistle, common buckthorn, and garden heliotrope or Valerian were also observed during 

surveys.

WDNR has also indicated that emerald ash borer was detected in Douglas County in 2013. One invasive 

plant species, reed canarygrass, was identified along all portions of the transmission line route and 

switching station site during the wetland delineation field. The three other invasive plant species were 

more sparsely distributed and were not observed at each Project component.

3.2.2.3 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to biologic resources at or in the 

vicinity of the Study Area because no construction and associated disturbance and clearing would occur.

3.2.3 Mitigation

The following sections describe the avoidance, minimization measures, and WDNR-identified actions for 

the Project to help conserve federally protected species, Wisconsin’s rare species, and high-quality natural 

communities.

3.2.3.1 Northern Long-eared Bat

Reproductive females and their young are highly vulnerable to mass mortality during their maternity 

period (June 1 – July 31) because they aggregate in maternity colonies. Young northern long-eared bats 
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start flying by 18 to 21 days after birth and therefore cannot leave the roost for several weeks after birth 

(USFWS 2015; Federal Register 2016). To follow the USFWS 4(d) rule for the Northern Long-Eared Bat, 

one of the following options should be implemented to avoid take of the NLEB:

1. Assume the bats are present within suitable habitat and avoid removal of known occupied 

maternity roost trees or any trees within 150 feet of a known occupied maternity roost tree from 

June 1 – July 31. For suitable habitat that occurs outside of 150 feet of a known occupied 

maternity roost tree or outside of 0.25 miles of a NLEB hibernaculum, implement the avoidance 

measures outlined in the Cave Bat Broad Incidental Take Permit and Authorization. According to 

the WDNR, if the Project can implement these avoidance measures, there will not be any further 

Project restrictions related to the NLEB. If the Project cannot completely avoid take of the NLEB, 

WDNR recommends that the BNHC Incidental Take Coordinator be contacted to determine

possible Project-specific avoidance measures. If take cannot be avoided, consultation with the 

USFWS will be necessary. 

2. Not assume the NLEB is present within suitable habitat along the alternative routes and have a 

qualified biologist conduct surveys to determine if the NLEB is present (a copy of the survey 

biologist’s credentials and a copy of the survey protocols must be sent to the WDNR Endangered 

Resources Review Program for approval prior to the initiation of surveys). According to the 

WDNR, if the NLEB is not found within the Study Area as a result of the surveys, there will be 

no Project restrictions related to these species. If surveys are conducted and the NLEB or 

maternity colonies are detected, option 1 must be followed. Survey results should be submitted to 

the Endangered Resources Utility Liaison.

3.2.3.2 Eagles

While the bald eagle was removed from the Federal Endangered Species list in August 2007, it is still 

federally protected by the BGEPA and the MBTA. Golden eagles are considered a nonbreeding, 

infrequent inhabitant in Wisconsin. Eagles can be sensitive to human disturbance, especially during the 

breeding and nesting seasons. Per the USFWS National Bald Eagle Management Guidelines (2007), 

human activity within 660 feet of an active nest should be avoided from January 15 – July 30. No bald 

eagle nests were observed during field surveys that occurred within the Study Area; however, if a bald 

eagle nest should be identified within the Survey Area, the USFWS National Bald Eagle Management 

Guidelines (2007) would be followed.
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3.2.3.3 Invasive Species

In compliance with WAC Chapter NR 40 Invasive Species Identification, Classification and Control 

Rule, the Owners will mitigate the potential to spread invasive plant species during Project activities. 

Invasive plant species locations will be shown on the construction plans and flagged on-site to avoid 

during construction, where feasible. In areas where impacts to the invasive plant species are unavoidable, 

equipment will be cleaned prior to moving from an infested area to a non-infested area.

Equipment cleaning will primarily be conducted by brush, broom, or other hand tools along the Project. 

The Owners may periodically require equipment to be cleaned by compressed air. Equipment used during 

ground disturbing activities will be cleaned prior to leaving the Project ROW to reduce the risk of 

spreading invasive plant species beyond the Project ROW. 

Construction equipment brought on-site will be required to be free of muck and invasive species. In 

accordance with Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP)

Chapter 20, WAC, seed mixtures that contain potentially invasive species or species that may be harmful 

to native plant communities will be avoided.

3.2.3.4 Revegetation

Construction activities will include clearing, grubbing, grading, excavation, infrastructure construction, 

and re-vegetation. In areas were restoration is required, seeding and mulching will be completed in 

accordance with WDNR Technical Standard 1059 – Seeding for Construction Site Erosion Control. The 

seed mix used will be appropriate to the surrounding area and similar to pre-construction conditions. The 

seedbed will be adequately prepared to promote successful germination. Seed mixes will not contain 

invasive species. Permanent seed mixtures will be selected to produce dense vegetation based on soil and 

site conditions, along with intended final use. Temporary seeding will be applied to areas of exposed soil 

where the establishment of vegetation is desired, but the areas have not been brought to final grade or on 

which land-disturbing activities will not be performed for a period greater than 30 days, but vegetative 

cover is required for less than 1 year. Areas needing protection during periods when permanent seeding is 

not applied, will be seeded with annual species.

Upon completion of restoration, each work location will be monitored to document stabilization and revegetation. Monitoring will continue until vegetative cover reaches 70 percent of previous cover.

3.2.3.5 Migratory Birds

The MBTA prohibits the take of migratory birds and their eggs, young, or active nests. The loss of plant 

and animal habitat within the footprint of the proposed Project, would primarily occur adjacent to existing 
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areas that have already been developed or are associated with existing utility and public road ROWs. The 

Nemadji River Site is adjacent to an existing tank farm and utility corridors and this area has experienced 

some level of habitat fragmentation associated with development in and around the City of Superior. The 

Eastern Transmission Route for the transmission line would be constructed within an existing utility 

corridor that contains a natural gas pipeline and overhead electrical transmission lines or the Western 

Transmission Route would be constructed parallel to existing linear infrastructure; however, woody 

vegetation would be cleared from forested lands and shrubland habitats along the edges of the existing 

utility corridor to widen the corridor and accommodate the additional line. During the extent of the 

Project, trees that would be removed would be done so outside of the migratory bird nesting period for 

Wisconsin (May 15 to August 1) to avoid impacts to nesting migratory birds (U.S. Department of 

Agriculture, 2018). 

3.3 Cultural Resources

The cultural resources of the Archaeological Study Area and the potential impacts to cultural resources as 

a result of the Project are discussed in the following sections. The Archaeological Study Area is a 0.5-

mile buffered area from the alternative transmission line routes (Eastern and Western), switching stations 

(Parkland and Superior), and generation sites (Nemadji River Site and Hill Avenue Site). The Eastern 

Transmission Route ROW, Parkland Switching Station, and Nemadji River Site footprint have been 

subject to a phase I field survey and the results submitted to the WHS for Section 106 review. The 

combined surveyed area is the Area of Potential Effects (APE) (see Gottsfield et al. 2019). RUS is the 

lead agency for the Project. RUS defined the APE, and the SHPO concurred with the APE boundaries in 

March 14, 2019 (Appendix C). Construction limits is used in this document to refer to the collective areas 

that would be subject to direct impacts within the Project elements. 

3.3.1 Affected Environment

In accordance with Section 106 of the National Historic Preservation Act (36 CFR Section 800), Federal 

agencies are required to take into account the effects of their undertakings on historic properties and to 

afford the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment on 

such undertakings. A phase I cultural resource survey7 was conducted between 2016-2018 (Gottsfield et 

al. 2019).

7 The Phase I cultural resource survey is available on the PSCW website at: 

http://apps.psc.wi.gov/vs2015/ERF_search/content/searchResult.aspx?UTIL=9698&CASE=CE&SEQ=101&STAR

T=none&END=none&TYPE=none&SERVICE=none&KEY=none&NON=N. PSC Reference No. 360433.
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3.3.1.1 Cultural Resources Literature Review

The literature review included evaluation of the State Historical Society of Wisconsin Digital Geographic 

Data Sets, historic period plat maps, 1938 aerial photographs, historic period topographic maps, and a 

map of Traditional Cultural Properties (TCPs) provided by the Fond du Lac Band of Lake Superior 

Chippewa within the Archaeological Study Area.

3.3.1.2 Historic Map and Aerial Photograph Review

In addition to review of WHS data, the background review included overlays of the 1850s General Land 

Office (GLO) plat maps (48N/13W, 48N/14W, 49N/13W, and 49N/14W), the 1906 Douglas County plat 

map, 1938 aerial photographs, and the 1915 and 1954 USGS Superior topographic maps. 

3.3.1.2.1 GLO Plat Map 

The 1850s GLO plat maps show a trail and a “wind fall” area within the construction limits. One end of 

the trail ends south of Bluff Creek near its intersection with the construction limits and heads to the 

southwest for several miles (outside of the construction limits). No evidence of the trail or associated sites 

was found during the present survey. The “wind fall” area is approximately 8 miles long and 0.25-mile 

wide and crosses the construction limits. The “wind fall” likely refers to a swath of downed trees perhaps 

caused by straight-line winds or tornado(s). The GLO plats do not show any roads, railroads, or 

homesteads within the construction limits. 

3.3.1.2.2 1906 Plat Map, USGS Topographic Maps, and 1938 Aerial 

Photographs

By 1906, two railroads and several roads crossed the construction limits. The 1906 plat shows the modern 

area of the Great Northern Railyard / Allouez Ore Arrival Yard adjacent to Bluff Creek as just a railroad, 

while the 1915 topographic map shows the expansion into a rail yard with multiple siding tracks. The 

accuracy of this plat map is suspect because it shows the Duluth, South Shore, and Atlantic Railway 

(DSS&A Railway) farther west than shown on subsequent maps (e.g., 1915 and 1954 topographic maps). 

The Eastern Transmission Route ROW crosses this former DSS&A Railway grade in two areas. The 1906 

plat shows property ownership but does not show any residences within the construction limits. 

The 1915 topographic map illustrates an expansion of rail systems, transportation corridors, settlements, 

and industry mainly focused near the Town of Parkland and the City of Superior. The 1938 historic 

aerials and 1954 topographic maps shows a consolidation of railways and expansion of roadways and the 

southern expansion of Superior to the Nemadji River and into the construction limits. Two residences 

within or adjacent to the construction limits are shown on these historic documents and relate to sites 
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found during the survey (i.e., 47DG188 and 47DG192). These maps and aerial images provide important 

references to contextualize the newly recorded sites associated with the present survey. 

3.3.1.2.3 Traditional Cultural Properties

During tribal consultation, the Fond du Lac Band of Lake Superior Chippewa provided RUS with a map 

of Traditional Cultural Properties (TCPs) within the vicinity of the Archaeological Study Area. Three of 

the resources are within the Archaeological Study Area. The first is labeled as a “Winter Camp.” It is 

located along the Nemadji River valley south bluffs. No other information was provided about this 

resource, and its extent is not well understood. The construction limits have been modified to avoid the 

area noted as “Winter Camp.” The second TCP is the St. Francis Xavier Cemetery. Approximately 180 

Chippewa burials were moved from their Wisconsin Point Cemetery to this cemetery around 1918-19. 

The St. Francis Xavier Cemetery property would not be impacted by this Project. The third TCP is 

labeled as a Nemadji River Campsite. It is located near the intersection of U.S. Highway 53 and the 

Nemadji River. It falls within the Archaeological Study Area, but it is not in or near the construction 

limits. Another TCP, the Allouez Mission, is just outside of the Archaeological Study Area.

3.3.1.2.4 Wisconsin Historical Society Digital Geographic Data Sets

The Wisconsin Historical Society (WHS) Digital Geographic Data Sets include an Architectural and 

History Inventory (AHI), an Archaeological Sites Inventory (ASI), and an Archaeological Report 

Inventory (ARI) (Table 3-6). Based on that research, 16 previously recorded archaeological sites have 

been recorded within the Archaeological Study Area, and three are within the APE (47DG188, 47DG189 

and 47DG191 – see Table 3-7). A total of 12 cultural resource surveys were previously performed in the 

Archaeological Study Area. Of those 12 surveys, 9 cross the APE (Table 3-8). A total of 30 historic-age 

resources have been recorded in the Archaeological Study Area; none fall within the APE (Table 3-9). 

There are five cemeteries in the Archaeological Study Area: Nemadji (BDG-22), Old City (BDG-23), St. 

Francis (BDG-24), Woodlawn (BDG-25), and a Douglas County Cemetery (BDG-54 / 47DG177); none 

are in the construction limits.

Table 3-6: WHS Digital Geographic Data Sets Summary

ARIsain 

Archaeological 

Study Area / 

Construction Limits

ASIsbin 

Archaeological 

Study Area / 

Construction Limits

AHIscin 

Archaeological 

Study Area / 

Construction Limits

Cemeteries in 

Archaeological Study 

Area / Construction 

Limits

12 / 9 16 / 2 30 / 0 5 / 0

Source: WHS 2017

(a) ARI = Archaeological Report Inventory

(b) ASI = Archaeological Sites Inventory
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(c) AHI = Architecture and History Inventory

Table 3-7: ASI Polygons in Archaeological Study Area

Trinomial / ASI ID Type Affiliation Proximity

14125 Nemadji Cemetery Historic Euro-American Study Area

14126 Old City Cemetery Historic Euro-American Study Area

14127 St. Francis Cemetery Historic Euro-American; 

Historic Indian Study Area

47DG27 Camp site / village Historic Indian Study Area

47DG33 Old stockade Historic Euro-American Study Area

47DG156 Isolated chert flake Unaffiliated Prehistoric Study Area

47DG176 Parkland Health Facility Historic Euro-American Study Area

47DG177 Cemetery Historic Euro-American Study Area

47DG181 Old Firehouse and Police Museum Historic Euro-American Study Area

47DG186 Logging camp Historic Euro-American Study Area

47DG187 Historic scatter Historic Euro-American Study Area

47DG188 Foundation, ceramic drainage tile, 

scatter Historic Euro-American Construction Limits

47DG189 Scatter and railroad grade Historic Euro-American Construction 

Limits

47DG190 Historic dump Historic Euro-American Study Area

47DG191 Foundation, dump, scatter Historic Euro-American Construction 

Limits

47DG192 Foundation, architectural, cistern, 

scatter Historic Euro-American Study Area

Source: WHS 2017; 2018 

Table 3-8: ARI Polygons in Archaeological Study Area

ARI # Report Title Author Date

631 Archaeological Survey of Proposed Railroad Relocation 

Sites in Douglas County, Wisconsin. Hudak 1982

632

Archaeological Survey of Proposed Railroad Relocation 

Sites in Douglas County, Wisconsin. Supplementary 

Report 1982.

Hudak 1982

633

An Archaeological Reconnaissance of the Proposed 

Transmission Line #132 from Gary (Duluth) St. Louis 

County, Minnesota to Stinson (Superior) Douglas County, 

Wisconsin.

Hudak and 

Emery 1979

639 Archaeological Reconnaissance of the Burlington 

Northern Railroad Taconite Facilities. Tiffany 1975
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ARI # Report Title Author Date

5819

WDOT Archaeological Survey Field Report: Replacement 

of the Bardon Avenue Bridge over the Nemadji River, 

City of Superior, Douglas County, Wisconsin.

Barth 1995

6342 WDOT Archaeological Survey Field Report: Parkland 

Wetland Mitigation, Douglas County, Wisconsin. Hawley 1997

7571 WDOT Archaeological Survey Field Report: Replace 

CTH Z Bridge Over Bluff Creek Barth 2001

8846

A Phase I Archaeological Survey of Two 15 Acre Parcels 

for the Superior Generation Project in Superior, 

Wisconsin

Christiansen 2001

22328 (no attribute data / information) -- --

34808

Phase I Archaeological Survey of Lyman Lake Road-Bear 

Creek Wetland Mitigation Project, Douglas County, 

Wisconsin

Egan-Bruhy 

and Guidi 2007

52809 Phase I Archaeological Survey for the Parkland Industrial 

Park, Douglas County, Wisconsin

Mulholland 

and 

Mulholland

2010

52919

A Cultural Resource Assessment of the Proposed 

Telecommunications Tower DUL Parkland E County 

Road Z, South Range, Douglas County, Wisconsin

Blondo 2015

Source: WHS 2017

Table 3-9: AHI Resources In the Archaeological Study Area

Trinomial / AHI ID Address Resource(s) Name

45569 Bardon Avenue Over Nemadji River Bridge Bardon Avenue / 

Woodlawn Bridge

155282 E. 21st Street Superior Terminal Superior Terminal

155302 2909 E. 8th Street House and 

Outbuildings —

155303 2814 E. 8th Street House and 

Outbuildings

Joseph and Arlene 

(Susie) Balcer 

House

155321 2806 E. 8th Street House and 

Outbuildings —

155341 2730 E. 8th Street House and 

Outbuildings —

155342 2726 E. 8th Street House and Garage —

155343 2718 E. 8th Street House and 

Outbuildings —

155344 2714 E. 8th Street House and Garage —
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Trinomial / AHI ID Address Resource(s) Name

155345 2710 E. 8th Street House and 

Outbuildings —

155361 2708 E. 8th Street House and Garage —

155381 2622 E. 8th Street House and Garage —

155382 2612 E. 8th Street House and Garage —

155461 2531 E. 9th Street House and 

Outbuildings —

155462 2530 E. 8th Street House and 

Outbuildings —

155465 2611 E. 8th Street House and 

Outbuildings —

155481 2619 E. 8th Street House and Garage —

155482 2623E. 8th Street House and Garage —

155483 2631 E. 8th Street House and 

Outbuildings —

155484 2703 E. 8th Street House and Garage —

155501 2713 E. 8th Street House and 

Outbuildings

Carl E. Nelson 

House

155502 2725 E. 8th Street House and Garage Duane H. Codotte 

House

17182, 26879, 

and 26881

North side of County Highway Z. 

Three miles East of County 

Highway A

Buildings

Douglas County / 

Parkland Hospital 

(non extant)

17366 1920 E. 10th Street House —

17367 2327 E 12th Street House —

17443 1102 E. 22nd Avenue House Edward Bradley 

Banks House

17462 E. 42nd Avenue at Bluff Creek Railroad Ore Yards Burlington Great 

Northern ore yards 

17787 Stinson Avenue at CNR with 

Bardon Avenue Industrial Building

Superior Refinery, 

Murphy Oil 

Corporation

Source: WHS 2017; 2018 

3.3.1.2.5 Relevant Surveys (AHIs) and Sites (ASIs)

Two archaeological sites adjacent to the construction limits and related cultural resources surveys are 

discussed here because of their proximity to the APE and association with newly recorded sites in the 

APE. Specifically, previously recorded sites 47DG176 and 47DG177 and survey ARI# 52809 are 

associated with the Parkland Health Facility (Mulholland and Mulholland, 2010). Newly recorded sites 
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47DG189 and 47DG190 are indirectly or directly associated with the Parkland Health Facility, and a 

portion of 47DG189 is within the construction limits. 

3.3.1.2.6 Parkland Health Facility and Cemetery: 47DG176 and 47DG177

The Parkland Health Facility (46DG176) was established in 1909 and closed in 1991. Over its 82-year 

lifespan, it served as an asylum, tuberculosis sanatorium, poor house, home for the elderly, “poor farm,” 

hospice, and health care facility. During its early history, the facility featured a maintained farm and 

garden. The Parkland Health Facility parcel also contains a cemetery (47DG177). 

Due to the amount of ground disturbance at site 46DG176, the investigators recommended no further 

investigations (see Mulholland and Mulholland, 2010). They also recorded the cemetery located west of 

the Parkland Health Facility (47DG177) and recommended avoiding impacts to the resource. This 

cemetery is adjacent to the construction limits, but it would not be impacted by the Project.

3.3.1.2.7 Newly Recorded Sites (ASIs) in the APE: 47DG188 and 47DG189

Newly recorded sites 47DG188, 47DG189, and 47DG191 are within the construction limits. Due to the 

high level of disturbance and insufficient integrity, these sites are not recommended as eligible for NRHP

listing. SHPO concurred that sites 47DG188 and 47DG189 are not NRHP eligible (see Gottsfield et al. 

2019; Appendix C). Site 47DG191 is within the Western Transmission Route (not Eastern Transmission 

Route) and was therefore not included in the archaeological report.

Site 47DG188 appears to be associated with a dairy farm operation and residence at this location. There 

were at least two outbuildings and a residence associated with the Kvarnstrom Brothers Dairy, circa 1910 

to 1929. The Dairy appears to have been shut down in the late 1920s. According to census records, the 

Jones family lived at the residence in the late 1930s through the early 1950s. All the buildings were 

removed by 1954. Given the presence of a footing and the drainage features (field tiles) there is a 

potential for intact subsurface cultural features associated with the farm. However, no artifact bearing

subsurface features were located during the present survey. 

Site 47DG189 is railroad grade with an associated trash deposit and an out of primary context railroad 

related signal footing. The abandoned rail grade is associated with the Iron River to Superior, Wisconsin, 

segment of the DSS&A Railway. This segment was constructed between 1892-1894 and abandoned in 

1934. 

Site 47DG191 is a remnant of a homestead located along North 42nd Street, approximately 0.3 mile 

northeast of the intersection of Woodlawn Road. A gravel driveway bears northwest from N 42nd St and 
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ends at a concrete foundation, surface trash scatter, and cistern. This homestead was known locally as the 

Hesselgrave house. Edgar A Hesselgrave owned the parcel at this location from 1945 to 1971. It is 

possible that the home was built in the 1940s or 1950s and abandoned in 1971, the year he sold the home.

3.3.1.2.8 Other Previously Recorded Surveys (AHIs) in the ROW

Several previously recorded cultural resources surveys overlap with the construction limits. Those 

surveys failed to locate cultural resources within the construction limits. The records search did not locate 

a report for the survey polygon (AHI# 22328) to the north of the Nemadji River Plant Site. This survey 

(AHI# 22328) included a portion of the laydown yard north of the Nemadji River Site.

3.3.2 Environmental Consequences

The following sections summarize potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to cultural resources.

3.3.2.1 Proposed Action Alternatives

There are 18 properties in Douglas County listed on the National Register of Historic Places (NRHP): 

Berkshire Block, Brule-St. Croix Portage, Davison Windmill, Douglas County Courthouse, Empire 

Block, Lake Nebagamon Auditorium, Maryland Block, Meteor (Whaleback carrier), Minnesota BlockBoard Trade Building, New Jersey Building, New York Block, Northern Block, Pattison / Martin House,

Roosevelt Terrace, Superior Entry South Breakwater Light, Trade and Commerce Building, Washington 

Block, and Wemyss Building. None of these properties are within the Archaeological Study Area.

A phase I cultural resource survey was conducted between 2016-2018 (Gottsfield et al. 2019) for the 

Nemadji River Site, Eastern Transmission Route, and Parkland Switching Station. The following sections 

provide details of the results of this phase I cultural resource survey as well as previous survey results for 

the Hill Avenue Site, Western Transmission Route, and the Superior Switching Station. 

3.3.2.1.1 Nemadji River Site

A total of 4 cultural resource surveys (ARIs) have been previously performed near the Nemadji River Site 

construction limits (Table 3-10). Of those 4 surveys, 3 (ARI numbers 633, 8846, and 22328) crossed 

portions of the proposed construction limits and all 3 were negative for cultural resources.
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Table 3-10: ARI Polygons Near the Nemadji River Site

ARI # Report Title Author Date

633

An Archaeological Reconnaissance of the Proposed Transmission 

Line #132 from Gary (Duluth) St. Louis County, Minnesota to 

Stinson (Superior) Douglas County, Wisconsin.

Hudak and 

Emery 1979

5819

WDOT Archaeological Survey Field Report: Replacement of the 

Bardon Avenue Bridge over the Nemadji River, City of Superior, 

Douglas County, Wisconsin.

Barth 1995

8846 A Phase I Archaeological Survey of Two 15 Acre Parcels for the 

Superior Generation Project in Superior, Wisconsin Christiansen 2001

22328 (no attribute data / information) -- --

Source: WHS 2017

There are six ASIs near the Nemadji River Site: five cemeteries and one archaeological site (36DG188) 

(Table 3-11). The Fond du Lac Band of Lake Superior Chippewa consider the St. Francis Xavier 

Cemetery a TCP because it contains approximately 180 Chippewa burials. The St. Francis Xavier 

Cemetery would not be impacted by this Project. 

Site 36DG188 was recorded during the survey associated with the Project. The site consists of a poured 

concrete footing remnant, a concrete drainage feature, and the vertical inlet portion of ceramic-lined field 

tile pipe as well as rusted nail fragments, clear glass bottle fragments, and brick fragments. Shovel tests 

revealed truncated A-horizons and mottled soils, both indicators of previous disturbance.

Based on archival research, Site 47DG188 appears to be associated with a dairy farm operation and 

residence at this location. There were at least two outbuildings and a residence associated with the 

Kvarnstrom Brothers Dairy, circa 1910 to 1929. The Dairy appears to have been shut down in the late 

1920s. According to census records, the Jones family lived at the residence in the late 1930s through the 

early 1950s. All the buildings were removed by 1954. Given the presence of a footing and the drainage 

features (field tiles), there is a potential for intact subsurface cultural features associated with the farm. 

However, no artifact bearing subsurface features were located during the present survey. Due to the high 

level of disturbance at the site, no additional archaeological investigations are recommended. SHPO 

concurred the site in not eligible for NRHP inclusion (Appendix C).

Table 3-11: ASI Polygons Near the Nemadji River Site

Trinomial 

/ ASI ID Type Affiliation Location

14125 Nemadji Cemetery Historic Euro-American Within 0.5 mile

14126 Old City Cemetery Historic Euro-American Within 0.5 mile
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Trinomial 

/ ASI ID Type Affiliation Location

14127 St. Francis Cemetery Historic Euro-American; Historic 

Indian

Within 0.5 mile

47DG188 Foundations, scatter Historic Euro-American Construction limits

Source: WHS 2017; 2018

3.3.2.1.2 Hill Avenue Site

A total of 3 cultural resource surveys were previously performed in the Hill Avenue Site construction 

limits (Table 3-12) Of those 3 surveys, none crossed the current proposed construction limits. There are 

no ASIs within 0.5 mile of the construction limits. Recent additional surveys did not record any cultural 

resources within this site.

Table 3-12: Archaeological Report Inventory (ARI) Polygons Near the Hill Avenue Site

ARI # Report Title Author Date

633

An Archaeological Reconnaissance of the Proposed Transmission 

Line #132 from Gary (Duluth) St. Louis County, Minnesota to 

Stinson (Superior) Douglas County, Wisconsin.

Hudak and 

Emery 1979

4217 Letter Report of Survey: New Chaffey Nursing Home in 

Superior.

Oerichbauer, 

Edgar S. 1992

8846 A Phase I Archaeological Survey of Two 15 Acre Parcels for the 

Superior Generation Project in Superior, Wisconsin Christiansen 2001

Source: WHS 2017

3.3.2.1.3 Eastern Transmission Line

A total of 13 cultural resource surveys (ARIs) have been previously performed near the Eastern 

Transmission Route (Table 3-13). Of those 13 surveys, 7 (ARI numbers 631, 632, 6342, 8846, 22328, 

34808, and 52809) crossed portions of the APE, and all were negative for cultural resources. 

Table 3-13: ARI Polygons Near the Eastern Transmission Route

ARI # Report Title Author Date

631 Archaeological Survey of Proposed Railroad Relocation Sites 

in Douglas County, Wisconsin. Hudak 1982

632 Archaeological Survey of Proposed Railroad Relocation Sites 

in Douglas County, Wisconsin. Supplementary Report 1982. Hudak 1982

633

An Archaeological Reconnaissance of the Proposed 

Transmission Line #132 from Gary (Duluth) St. Louis 

County, Minnesota to Stinson (Superior) Douglas County, 

Wisconsin.

Hudak and 

Emery 1979
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ARI # Report Title Author Date

639 Archaeological Reconnaissance of the Burlington Northern 

Railroad Taconite Facilities. Tiffany 1975

5819

WDOT Archaeological Survey Field Report: Replacement of 

the Bardon Avenue Bridge over the Nemadji River, City of 

Superior, Douglas County, Wisconsin.

Barth 1995

6342 WDOT Archaeological Survey Field Report: Parkland 

Wetland Mitigation, Douglas County, Wisconsin. Hawley 1997

8846 A Phase I Archaeological Survey of Two 15 Acre Parcels for 

the Superior Generation Project in Superior, Wisconsin Christiansen 2001

22328 (no attribute data / information) — —

34808

Phase I Archaeological Survey of Lyman Lake Road-Bear 

Creek Wetland Mitigation Project, Douglas County, 

Wisconsin

Egan-Bruhy 

and Guidi 2007

52809 Phase I Archaeological Survey for the Parkland Industrial 

Park, Douglas County, Wisconsin

Mulholland 

and 

Mulholland

2010

52919

A Cultural Resource Assessment of the Proposed 

Telecommunications Tower DUL Parkland E County Road Z, 

South Range, Douglas County, Wisconsin

Blondo 2015

53532 (no attribute data / information) -- --

53628

A Cultural Resource Assessment of the Proposed 

Telecommunications Tower DUL Parkland E County Road Z, 

South Range, Douglas County, Wisconsin

Blondo 2015

Source: WHS 2017

There are ten ASIs near the Eastern Transmission Route: four cemeteries and six archaeological sites 

(Table 3-14). The Fond du Lac Band of Lake Superior Chippewa consider the St. Francis Xavier 

Cemetery a TCP because it contains approximately 180 Chippewa burials. Of the ten ASIs in the area, 

only Site 47DG189 is within the ROW of the Eastern Transmission Route. This site is a railroad grade 

with an associated trash deposit and railroad related signal footing found outside of its primary context. 

The abandoned rail grade is associated with the Iron River to Superior, Wisconsin, segment of the 

DSS&A Railway. This segment was constructed between 1892-1894 and abandoned in 1934. Due to 

insufficient integrity, the site was not recommended as eligible for NRHP listing. SHPO concurred that 

the site was not eligible for NRHP inclusion (Appendix C).

Table 3-14: ASI Polygons Near the Eastern Transmission Route

Trinomial / ASI ID Type Affiliation Location

14125 Nemadji Cemetery Historic Euro-American Within 0.5 mile

14126 Old City Cemetery Historic Euro-American Within 0.5 mile
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Trinomial / ASI ID Type Affiliation Location

14127 St. Francis Cemetery Historic Euro-American; Historic 

Indian Within 0.5 mile

47DG156 Isolated find Unknown Prehistoric Within 0.5 mile

47DG176 Foundation/Depression: 

Commercial Historic Euro-American Within 0.5 mile

47DG177 County Cemetery Historic Euro-American Within 0.5 mile

47DG188

Foundation, ceramic 

drainage tile feature, 

and light historic 

scatter

Historic Euro-American Within 0.5 mile

47DG189 Historic scatter and 

railroad grade Historic Euro-American APE

47DG190 Dump Historic Euro-American Within 0.5 mile

47DG192

Foundation, 

Architectural, cistern, 

historic scatter

Historic Euro-American Within 0.5 mile

Source: WHS 2017; 2018 

3.3.2.1.4 Western Transmission Line

There are no NRHP properties within 0.5 mile of the Western Transmission Route. A total of 11 cultural 

resource surveys (ARIs) have been previously performed near the Western Transmission Route (Table 

3-15). Of those 11 surveys, 4 (ARI numbers 631, 632, 5819, and 8846) crossed portions of the current 

proposed route, and all were negative for cultural resources. The majority of the Western Transmission 

Route has not been surveyed for this Project or previously. 

Table 3-15: Archaeological Report Inventory (ARI) Polygons Near the Western Transmission

Route

ARI # Report Title Author Date

631 Archaeological Survey of Proposed Railroad Relocation Sites 

in Douglas County, Wisconsin. Hudak 1982

632 Archaeological Survey of Proposed Railroad Relocation Sites 

in Douglas County, Wisconsin. Supplementary Report 1982. Hudak 1982

639 Archaeological Reconnaissance of the Burlington Northern 

Railroad Taconite Facilities. Tiffany 1975

5819

WDOT Archaeological Survey Field Report: Replacement of 

the Bardon Avenue Bridge over the Nemadji River, City of 

Superior, Douglas County, Wisconsin.

Barth 1995

6342 WDOT Archaeological Survey Field Report: Parkland 

Wetland Mitigation, Douglas County, Wisconsin.

Hawley 1997
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ARI # Report Title Author Date

7573 WDOT Archaeological Survey Field Report: Replace CTH Z 

Bridge over Bluff Creek Barth 2001

8846 A Phase I Archaeological Survey of Two 15 Acre Parcels for 

the Superior Generation Project in Superior, Wisconsin Christiansen 2001

22328 (no attribute data / information) — —

34808

Phase I Archaeological Survey of Lyman Lake Road-Bear 

Creek Wetland Mitigation Project, Douglas County, 

Wisconsin

Egan-Bruhy 

and Guidi 2007

52809 Phase I Archaeological Survey for the Parkland Industrial 

Park, Douglas County, Wisconsin

Mulholland 

and 

Mulholland

2010

52919

A Cultural Resource Assessment of the Proposed 

Telecommunications Tower DUL Parkland E County Road Z, 

South Range, Douglas County, Wisconsin

Blondo 2015

Source: WHS 2017

There are eleven ASIs near the Western Transmission Route: four cemeteries and seven archaeological 

sites (Table 3-16). The Western Transmission Route would impact the driveway at Site 47DG191. This 

site is a homestead dating to the 1940s. The driveway consists of pea gravels and cinders and extends 

from the foundation area south to North 42nd Street. The cemetery and the other sites would not be 

impacted by the Western Transmission Route. This site remains unevaluated for NRHP eligibility. 

Table 3-16: Archaeological Sites Inventory (ASI) Polygons Near the Western Transmission 

Route

Trinomial / ASI ID Type Affiliation Location

47DG156 Isolated find Unknown Prehistoric Within 0.5 mile

47DG186 Logging Camp Historic Euro-American Within 0.5 mile

14125 Nemadji Cemetery Historic Euro-American Within 0.5 mile

14126 Old City Cemetery Historic Euro-American Within 0.5 mile

14127 St. Francis Cemetery Historic Euro-American; Historic 

Indian Within 0.5 mile

14128 Woodlawn Cemetery Historic Euro-American Within 0.5 mile

47DG188

Foundation, ceramic 

drainage tile feature, 

and light historic 

scatter

Historic Euro-American Within 0.5 mile

47DG189 Historic scatter and 

railroad grade Historic Euro-American Within 0.5 mile

47DG190 Dump Historic Euro-American Within 0.5 mile
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Trinomial / ASI ID Type Affiliation Location

47DG191 Foundation, dump, 

scatter Historic Euro-American Construction Limits

47DG192

Foundation, 

Architectural, cistern, 

historic scatter

Historic Euro-American Within 0.5 mile

Source: WHS 2017; 2018 

3.3.2.1.5 Hill Avenue Site Route

A total of 4 cultural resource surveys (ARIs) have been previously performed near the Hill Avenue Site 

Route (Table 3-17). Of those 4 surveys, 2 (ARI numbers 8846 and 22328) crossed portions of the current 

proposed construction limits and were negative for cultural resources. 

Table 3-17: Archaeological Report Inventory (ARI) Polygons Near the Hill Avenue Site Route

ARI # Report Title Author Date

633

An Archaeological Reconnaissance of the Proposed 

Transmission Line #132 from Gary (Duluth) St. Louis County, 

Minnesota to Stinson (Superior) Douglas County, Wisconsin.

Hudak and 

Emery 1979

5819

WDOT Archaeological Survey Field Report: Replacement of the 

Bardon Avenue Bridge over the Nemadji River, City of Superior, 

Douglas County, Wisconsin.

Barth 1995

8846 A Phase I Archaeological Survey of Two 15 Acre Parcels for the 

Superior Generation Project in Superior, Wisconsin Christiansen 2001

22328 (no attribute data / information) — —

Source: WHS 2017

There are four ASIs near the Hill Avenue Site Route: three cemeteries and one archaeological site (Table 

3-18). The Fond du Lac Band of Lake Superior Chippewa consider the St. Francis Xavier Cemetery a 

TCP because it contains approximately 180 Chippewa burials. These burials were moved from the 

Chippewa’s Wisconsin Point Cemetery to this cemetery around 1918-19. The cemeteries and site would 

not be impacted by the Hill Avenue Site Route. 

Table 3-18: Archaeological Sites Inventory (ASI) Polygons Near the Hill Avenue Site Route

ASI ID / Trinomial Type Affiliation Location

14125 Nemadji Cemetery Historic Euro-American Within 0.5 mile

14126 Old City Cemetery Historic Euro-American Within 0.5 mile

14127 St. Francis Cemetery Historic Euro-American; Historic 

Indian Within 0.5 mile
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ASI ID / Trinomial Type Affiliation Location

47DG188

Foundation, ceramic 

drainage tile feature, and 

light historic scatter

Historic Euro-American Within 0.5 mile

Source: WHS 2017; 2018 

3.3.2.1.6 Superior Switching Station

A total of 2 cultural ARIs have been previously performed near the Superior Switching Station (Table 

3-19). Neither of the surveys crossed the current proposed switching station. 

Table 3-19: ARI Polygons Near the Superior Switching Station

ARI # Report Title Author Date

639 Archaeological Reconnaissance of the Burlington Northern Railroad 

Taconite Facilities. Tiffany 1975

5819

WDOT Archaeological Survey Field Report: Replacement of the 

Bardon Avenue Bridge over the Nemadji River, City of Superior, 

Douglas County, Wisconsin.

Barth 1995

Source: WHS 2017; 2018 

There are two ASIs near the Superior Switching Station: two archaeological sites (Table 3-20). Neither of 

the sites are within the construction area of the Superior Switching Station. 

Table 3-20: ASIs Near the Superior Switching Station

Trinomial / ASI ID Type Affiliation Location

47DG186 Logging camp Historic Euro-American Within 0.5 mile

47DG191 Foundation, dump, 

scatter

Historic Euro-American Within 0.5 mile

Source: WHS 2017; 2018 

3.3.2.1.7 Parkland Switching Station

A total of 6 cultural ARIs have been previously performed near the Parkland Switching Station (Table 

3-21). None of the surveys crossed the current proposed switching station. 

Table 3-21: ARI Polygons Near the Parkland Switching Station

ARI # Report Title Author Date

631 Archaeological Survey of Proposed Railroad Relocation Sites in 

Douglas County, Wisconsin. Hudak 1982

632 Archaeological Survey of Proposed Railroad Relocation Sites in 

Douglas County, Wisconsin. Supplementary Report 1982. Hudak 1982
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ARI # Report Title Author Date

6342 WDOT Archaeological Survey Field Report: Parkland Wetland 

Mitigation, Douglas County, Wisconsin. Hawley 1997

34808 Phase I Archaeological Survey of Lyman Lake Road-Bear Creek 

Wetland Mitigation Project, Douglas County, Wisconsin

Egan-Bruhy 

and Guidi 2007

52809 Phase I Archaeological Survey for the Parkland Industrial Park, 

Douglas County, Wisconsin

Mulholland 

and 

Mulholland

2010

52919

A Cultural Resource Assessment of the Proposed 

Telecommunications Tower DUL Parkland E County Road Z, 

South Range, Douglas County, Wisconsin

Blondo 2015

53532 (no attribute data / information) -- --

53628

A Cultural Resource Assessment of the Proposed 

Telecommunications Tower DUL Parkland E County Road Z, 

South Range, Douglas County, Wisconsin

Blondo 2015

Source: WHS 2017; 2018 

There are five ASIs near the Parkland Switching Station: one cemetery and four archaeological sites 

(Table 3-22). None of the five ASIs in the area are within the construction area of the Switching Station. 

Table 3-22: ASIs Near the Switching Station

Trinomial / ASI ID Type Affiliation Location

47DG156 Isolated find Unknown Prehistoric Within 0.5 mile

47DG176 Foundation/Depression: 

Commercial Historic Euro-American Within 0.5 mile

47DG177 County Cemetery Historic Euro-American Within 0.5 mile

47DG189 Historic scatter and 

railroad grade Historic Euro-American Within 0.5 mile

47DG190 Dump Historic Euro-American Within 0.5 mile

Source: WHS 2017; 2018 

3.3.2.1.8 Summary

On February 4, 2019, the RUS submitted a finding of no historic properties affected to the WHS in 

accordance with 36 CFR § 800.4(d)(1) and provided the cultural resources survey report as 

documentation for review and consideration (see Gottsfield et al. 2019). The WHS concurred with this 

determination in March 2019 (Appendix C). Based on the distance from NRHP properties and the 

concurrence from SHPO that no historic properties will be affected, it is anticipated that the Project would 

not have any adverse impacts on cultural resources. No responses have been received from the Tribes in 

response to the RUS findings report and WHS concurrence.
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3.3.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to cultural resources at or in the 

vicinity of the Archaeological Study Area because no construction would occur.

3.3.3 Mitigation

If the Archaeological Study Area configuration is changed, additional archaeological investigations;

documentation of historic-age, non-archaeological resources; and NRHP evaluations may be necessary.

If buried cultural resources are encountered during Project construction, land-disturbing activities in the 

immediate area must be halted, and the investigators and WHS/SHPO archaeologists must be notified. 

Any exposed cultural resources will be evaluated for their significance and appropriate actions to address 

these finds coordinated with WHS/SHPO.

3.4 Geology and Soils

The following sections provide information on the geology and soils in the Study Area. 

3.4.1 Affected Environment

The following sections discuss the geology and soils of the Study Area. The analysis for geology focused 

the Lake Superior Lowland physiographic province. The analysis for soils focused on the Study Area.

3.4.1.1 Geology

The Study Area is in the Lake Superior Lowland physiographic province, an area of about 1,250 square 

miles in northwestern Wisconsin covering portions of Douglas, Bayfield, and Ashland Counties. Its 

altitude ranges from less than 1,000 feet above to about 300 feet below sea level, and it rises 150 to 350 

feet above and goes 600 to 900 feet below the level of Lake Superior, which stands at 602 feet above sea 

level.

The Lake Superior basin is now a lowland because of the downward movement of a block of the earth's 

crust in a rift, or graben fault. Subsequent sedimentation, erosion, and sculpting by continental ice sheets 

have reshaped the area and notably modified the rift valley.

Bedrock consists of Precambrian-age rock. Igneous and metamorphic types make up the bedrock that is 

present to the north of Superior and the Lake Superior Lowlands. Bedrock underlying Superior consists of 

sandstone and shale of the Precambrian Fond du Lac Formation of the Bayfield Group. The erosion 

surface of the Precambrian bedrock is overlain unconformably by unconsolidated Quaternary glacial, 

glaciofluvial, and alluvial deposits that consist of clay, silt, sand, and gravel. 
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3.4.1.2 Soils

According to the USDA Natural Resources Conservation Service (NRCS) Web Soil Survey 

(http://websoilsurvey.nrcs.usda.gov), the Study Area contains 13 different soil types (Figure 3-1; Table 

3-23). None of these soils are considered prime farmland. Two of the soils are considered to be farmland 

of statewide importance. Three of soils within the Study Area are hydric soils. 

Table 3-23: Soil Information Study Area

Soil Name

Soil 

Symbol

Prime 

Farmland

Farmland 

of 

Statewide

Importance

Hydric 

Soil

Amnicon-Cuttre complex, 0 to 4 percent slopes 262B – Yes –

Arnheim mucky silt loam, 0 to 1 percent slopes, 

frequently flooded

5A – – Yes

Bergland-Cuttre complex, 0 to 3 percent slopes 347A – – Yes

Lupton, Cathro, and Tawas soils, 0 to 1 percent slopes 405A – – Yes

Miskoaki clay loam, 6 to 12 percent slopes 274C – – –

Miskoaki clay loam, 12 to 25 percent slopes 274D – – –

Moquah fine sandy loam, 0 to 3 percent slopes, 

frequently flooded

6A – – –

Pelkie, occasionally flooded-Dechamps, frequently 

flooded complex, 0 to 4 percent slopes

388B – – –

Superior-Sedgwick complex, 0 to 6 percent slopes 756B – Yes –

Udifluvents, loamy to clayey, 0 to 6 percent slopes, 

occasionally flooded

292B – – –

Udorthents and Udipsamments, cut or fill 2030 – – –

Udorthents, ravines and escarpments, 25 to 60 percent 

slopes

92F – – –

Water W – – –

Source: USDA NRCS Soils Database

3.4.2 Environmental Consequences

The following sections discuss potential environmental consequences of the Action Alternatives and No 

Action Alternative related to geology and soils. 

3.4.2.1 Proposed Action Alternatives

Both sites would be graded and grading design would change the topography to facilitate storm water 

drainage patterns. Storm water runoff on the Nemadji River Site would be collected and directed to an 

onsite storm water detention pond located near the southwestern boundary of the site. The existing pond 
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Source: Esri, Minnesota Power, City of Superior 2019 Aerials, USDA NRCS, and Burns & McDonnell Engineering Company, Inc. Issued: 3/12/2020 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\3_1_Study_Area_Soils.mxd kasamuelson 3/12/2020

Figure 3-1

Study Area Soils

SSE and DPC

Nemadji Trail Energy Center

Douglas County, WI

Study Area

Lake Superior

Wisconsin

Minnesota

Douglas

County

Carlton

County

Pine

County

St. Louis

County

Study Area

Soil Boundary

Municipal Boundary

Macro-Corridors

Soil Key ( *Denotes 50% or Greater Hydric Rating)

- *347A: Bergland-Cuttre complex, 0 to 3 percent slopes

- 2030: Udorthents and Udipsamments, cut or fill

- 262B: Amnicon-Cuttre complex, 0 to 4 percent slopes

- 274C: Miskoaki clay loam, 6 to 12 percent slopes

- 274D: Miskoaki clay loam, 12 to 25 percent slopes

- 292B: Udifluvents, loamy to clayey, 0 to 6 percent

slopes, occasionally flooded

- 347A: *Bergland-Cuttre complex, 0 to 3 percent slopes

- 5A: Arnheim mucky silt loam, 0 to 1 percent slopes,

frequently flooded

- 6A: Moquah fine sandy loam, 0 to 3 percent slopes,

frequently flooded

- 92F: Udorthents, ravines and escarpments,

25 to 60 percent slopes

- W: Water

NORTH

0 0.5 1

Miles
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discharges to the south via underground pipe to the Nemadji River. Storm water runoff from 31st Ave 

would continue to drain into a roadside culvert outlet into waterway (WW) 501f. Storm water runoff on 

the Hill Avenue Site would be collected and routed to a new storm water detention pond located in the 

northeast corner of the site. The new pond would be pumped, and storm water would be discharged at 

existing surface grade to the east/northeast to a stream that discharges to Superior Bay.

At the Nemadji River Site, the main power block area would be raised approximately 7 feet at the north 

end. Several areas along the sheet pile wall on the east side of the plant area would have 15 to 20 feet of 

fill behind the wall. The grading of the power block area would require approximately 72,000 cubic yards 

of imported fill. There would be some excavation for underground utilities and deep structures such as 

pump pits and the suitable material from these excavations would be used for trench backfill and site 

grading. An existing stormwater pond is located within the Nemadji River Site in the southwest corner 

near 31st Street. This stormwater pond would be enlarged as part of the Project. The excavation to enlarge 

the existing stormwater pond is included in the site grading quantities. Installation of the sheet pile wall 

would require approximately 15,000 cubic yards of excavation and approximately 48,000 cubic yards of 

select material backfill.8

At the Hill Avenue Site, the preliminary geotechnical investigation report recommends the upper 5 feet of 

the plant area be removed and replaced with suitable fill material. That would require approximately 

499,000 cubic yards of excavation with disposal offsite and approximately 499,000 cubic yards of 

imported fill material. The power block area would be raised approximately 4 feet after the 5 feet of overexcavation is replaced. This would require approximately 400,000 cubic yards of imported fill material. 

There would be some excavation for underground utilities and deep structures such as pump pits and the 

suitable material from these excavations would be used for trench backfill and site grading. The 

stormwater pond would require approximately 81,000 cubic yards of excavation with disposal offsite.

Transmission line structure footprints range from 7 feet to 12 feet in diameter. Holes for the 345-kV 

structure foundations would range from approximately 55 feet to 95 feet deep depending on soil 

conditions and design. Foundation construction would occur after vegetation clearing is complete and 

begins with drilling for structure foundations. Excavated soils would be used for foundation backfill if 

appropriate. Surplus soils would be spread within the right of way and stabilized. After the structure bases 

are installed, the remaining structure is assembled at each pole location by a crane. Excavated soils would 

8 The 48,000 cubic yards of select material to backfill the sheet pile wall is included in the 72,000 cubic yards of 

imported fill to grade the site.
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be used for foundation backfill if appropriate. Surplus soils would be spread within the right of way and 

stabilized. After all line construction is complete, the ROW is restored.

A variety of construction machinery would be required for the Project. Excavators, bulldozers, skidsteers, front end loaders, dump trucks, pick-up trucks, and backhoes would be required during ROW 

clearing and grading at structure sites. Foundation construction would require a drill rig and a concrete 

mix truck in addition to machinery used during ROW clearing and grading. Structure assembly would 

require a crane and bucket lift.

Based on the amount of excavation required, the type of substrate at the Project sites, and erosion control 

techniques that would be implemented (see Section 3.4.4), construction and operation of the Project is not 

expected to affect geological formations. Soils at the Nemadji River Site consist of Amnicon-Cuttre 

complex (0 to 4 percent slopes; farmland of state wide importance); Arnheim mucky silt loam (0 to 1 

percent slopes, frequently flooded; hydric soil); Berland-Cuttre complex (0 to 3 percent slopes; hydric 

soil); udorthents, ravines and escarpments (25 to 60 percent slopes); and a small area of open water. 

These soils would be converted to plant site development with much of the area occupied by the facilities 

and covered by concrete and gravel areas. Soil at the Hill Avenue Site consist of Amnicon-Cuttre 

complex (0 to 4 percent slopes) and Bergland-Cuttre complex (0 to 3 percent slopes). The transmission 

line corridor would be cleared but only soil areas at the structure locations would be permanently 

excavated. Other Areas of hydric and statewide important soils would remain largely unaffected by 

construction and following any necessary stabilization would be available for agriculture and other 

activities.

3.4.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to geology or soil at or in the 

vicinity of the Study Area because no construction would occur.

3.4.3 Mitigation

Best management practice (BMP) erosion control techniques will be used to mitigate soil impacts. 

Topsoil will be kept separate from subsoils and will be stockpiled in a different location than subsoils. 

This topsoil will be used after construction to resurface areas disturbed by construction activities. 

Compacted soils will be disked prior to final stabilization. It is not anticipated that any subsoil removed 

for excavations will be spread in upland cropland or pasture. The Storm Water Management Technical 

Standards from WDNR will be used during construction and operation. 
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A Storm Water Pollution Prevention Plan (SWPPP) will be submitted to WDNR as part of Project 

permitting activities. The Owners will implement, monitor, and maintain BMPs, described in the SWPPP 

to minimize erosion and sedimentation. The Owners will comply with the construction site storm water 

discharge permit (Wis. Admin. Code NR 216) that was submitted to WDNR for the Project in December 

2018. 

3.5 Infrastructure, Transportation, Public Health and Safety, and Waste 

Management

The following sections provide information on the existing infrastructure; transportation; public health 

and safety; and waste management in the Study Area, and the potential impact the Project would have on 

these resources. 

3.5.1 Affected Environment

The following sections provide information related to infrastructure, transportation, public health and 

safety, and waste management.

3.5.1.1 Utility Infrastructure

Natural gas distribution and retail electric services are provided to the Study Area by SWL&P. Potable 

water, also provided by SWL&P, is available in the area north and east of the Nemadji River Site. The 

Owners discussed its potable water needs with SWL&P. SWL&P has indicated potable water service is 

available by extending a tap from the existing line along 31st Avenue East into the Nemadji River Site.

Sanitary wastewater in the area is discharged to the City of Superior municipal sewer system for offsite

treatment. A CenturyLink fiberoptic cable is located within the existing transmission line corridor situated 

between the Hill Avenue and the Nemadji River sites. 

Electric distribution lines are located along Stinson Avenue northwest of the Nemadji River Site, along 

Bardon Ave west of the Nemadji River Site, along Grand Avenue immediately west of the Nemadji River 

Site, and along 31st Avenue East to the east. Existing electric distribution near the Hill Avenue Site is 

found along North 28th Street to the north, Hill Avenue to the west, and in residential areas east of the 

site. Further south near the Switching Station Alternatives, distribution can be found extending parallel to 

42nd Ave E, County Rd A, S Lyman Lake Rd, and County Rd E.

Two existing pipelines extend through the Nemadji River Site (Figure 2-11). A 10-inch diameter SWL&P 

natural gas line extends through western portion of the site, along the existing transmission corridor south 

through the Study Area. A 30-inch diameter Enbridge crude oil line extends along the western edge of the 
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Nemadji River Site. Both pipelines extend through the laydown yard north of the Nemadji River Site. In 

addition to these lines, several crude oil lines extend from southwest to northeast through the center of the 

laydown yard north of the Nemadji River Site. Multiple crude oil lines extend along the northern 

boundary of the temporary impact area and cross the north corner of the laydown yard. Two crude oil 

lines extend west-southwest from the area surrounding the Nemadji River Site, one of which continues in 

a southerly direction through the length of the Study Area, and another crude oil line extends southeast 

from the Nemadji River Site (Figure 2-11). 

Several existing transmission lines are present within the Study Area (Figure 2-11). The Winter to Stinson 

115-kV line extends along the north and east sides of the Hill Avenue Site, connecting into the north side

of the Stinson Substation. Several lines extend from the Stinson Substation to the south, bypassing the 

Nemadji River Site, and continuing predominantly southward through the Study Area: the Gary to 

Stinson 115-kV transmission line, the Superior to Minong 161-kV transmission line, and the Ino to 

Superior 115-kV transmission line. The Lakehead Substation and Lakehead Tap are located west of the 

Nemadji River Site. The Arrowhead to Stone Lake 345-kV transmission line extends from the central 

western edge of the Study Area near the intersection of County Roads A and C, to the east to the existing 

Line No. 160 161-kV. Line No. 160 161-kV and Line No. 761 115-kV parallel each other and extend 

generally southeast from the Stinson Substation, crossing the Nemadji River and the railyard southeast of 

the Nemadji River Site. The lines parallel one another to the south side of City Limits Road, where Line 

No. 761 extends due east and Line No. 160 extends south along Lyman Lake Road. South of County 

Road C, Line No. 160 parallels a pipeline ROW southeast to the edge of the Study Area boundary.

3.5.1.2 Transportation

The Study Area is generally undeveloped woodland or wetland with few major roads. Roads within the 

Study Area include a range of paved and unpaved surfaces. There are no interstates within the Study Area 

and major roads include County Roads A, C, E, K, and Z (Figure 2-11). Hill Avenue, N 28th St E, 24th 

Avenue East extend through the northern portion of the Study Area near the two generation facility site 

alternatives. The central and southern portions of the Study Area are mostly undeveloped apart from 42nd

Ave E and S Lyman Rd, respectively. There are no scenic byways within the Study Area. 

Several rail lines are located within the Study Area (Figure 2-11). The rail lines are owned by BNSF and 

Canadian National lines. No air facilities are located within the Study Area; several are located within 

several miles of the Study Area, however. The nearest public use airport is the Richard I. Bong Airport, 

located approximately 1.8 nautical miles west from the Nemadji River Site. Other nearby air facilities 

include the Sky Harbor Airport and Seaplane Base, a public use airport located approximately 1.9 nautical 
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Rural Utilities Service 3-46 Dairyland Power Cooperative

miles north of the Nemadji River Site; and the Carlson Airport, a private use airstrip located 

approximately 4.1 nautical miles southwest of the Nemadji River Site. The St. Mary’s Hospital and St. 

Luke’s Hospital heliports are private use facilities located 6.5 miles north-northwest of the Nemadji River

Site. The Duluth International Airport is located approximately 10.5 miles northwest of the Nemadji 

River Site. There may be other private use facilities in the area that are not registered with the FAA. 

Because the locations of such facilities cannot be confirmed, they were not included in this report.

3.5.1.3 Public Health and Safety

The nearest medical facility to the Study Area is the Mariner Medical Clinic Urgent Care facility, located 

approximately 1.6 miles northwest of the Nemadji River Site on N 28th St. Emergency medical services 

are provided by Essentia Health St. Mary’s-Superior Clinic, St. Luke’s Mariner Medical Clinic Urgent 

Care and Gold Cross Ambulance. The Superior Police Department, located in the Superior city center, 

provides public safety. Fire protection is provided by the Superior Fire Department, with locations to the 

west (approx. 2.6 miles), to the east (approx. 0.7 mile), and to the north (approx. 3.6 miles).

The Study Area contains existing electric transmission lines. Voltages range from 69-kV to 345-kV. 

Electrical generation and transmission facilities generate electromagnetic fields (EMF). Electric fields are 

produced by the line voltage and magnetic fields are produced by electric current. EMF is produced by 

natural sources (such as build-up of electric charges from thunderstorms in the atmosphere) and human 

sources (such as household electronics, X-rays, and electric generation and transmission facilities). The 

strength of EMF is strongest closest to the source and rapidly decreases in strength the farther one is from 

the source (World Health Organization, 2018). The National Institute of Environmental Health Sciences 

and the National Institutes of Health prepared a Questions and Answers paper on Electric and Magnetic 

Fields Associated with the Use of Electric Power9(2002). The document indicates that at 50 feet from the 

centerline of a 500-kV transmission line (higher voltage than the 345-kV line for this Project), the typical 

electric field is 3.0 kilovolt per meter (kV/m) and the typical magnetic field is 29.4 milligauss (mG). For a 

230-kV transmission line, the typical electric field is 1.5 kV/m and the typical magnetic field is 19.5 mG. 

These values are less than the International Commission on Non-Ionizing Radiation Protection (2010)

levels for members of the general public of 4.2 kV/m for electric fields and 833 mG for magnetic fields.

The PSCW actively monitors research related to EMF and its potential to cause human health impacts. 

The PSCW has concluded the following based on current research (PSCW, 2017):

9 The National Institute of Environmental Health Sciences and the National Institutes of Health did not address 345-

kV lines specifically in this document. The document was considered a reasonable guide to what could be expected 

as it considered voltages higher and lower than 345-kV proposed for this Project.
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• There is no mechanism identified that would explain how EMF could cause cancer.

• There is little evidence that magnetic fields cause childhood leukemia, and there is inadequate 

evidence that magnetic fields cause other cancers in children. 

• Studies of adults’ magnetic field exposure from power lines show little evidence of an association 

with leukemia, brain tumors, or breast cancer. 

• Whole animal exposure studies have not shown evidence that long-term exposure to EMF causes 

cancer, and no link has been found to leukemia, brain cancer, and breast cancer. 

• For power line magnetic fields below 500 mG, no plausible mechanisms have been identified by 

which biological effects can be caused in living systems. 

3.5.1.4 Hazardous Materials and Waste Management

The EPA maintains a Facility Registry Service (FRS) database with information related to hazardous 

wastes, air pollution, water dischargers, toxic releases, superfund sites, brownfields, radiation, and 

controlled toxic substances (EPA, 2019). This database was used to identify registered facilities within the 

Study Area. No superfund sites, brownfield sites, or radiation sites are in the Study Area.

Five sites listed in the FRS are within the Study Area: Peterson Wood Treating, Inc., located at 2 Randy 

Johnson Street; Husky Energy – Superior Refinery, located at 2407 Stinson Avenue; BP Dome Petroleum 

Corporation Superior Terminal, located at 2600 East 21st Street; Enbridge Energy Company, located at 

2800 East 21st Street; and Koppers, Inc. (Beazer East, Inc.), located at 3185 S. County Road A (Figure 

3-2). 

3.5.2 Environmental Consequences

The following sections provide potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to utility infrastructure; transportation; public health and 

safety; and hazardous waste management.

3.5.2.1 Proposed Action Alternatives

The following sections provide information on the potential impacts of the proposed Action Alternatives 

on utility infrastructure; transportation; public health and safety; and hazardous waste management.

3.5.2.1.1 Utility Infrastructure

Several existing transmission lines would be affected by the Project. At the beginning of the Eastern 

Transmission Route, an existing 115-kV line would be replaced with a double circuit 345/161-kV line, 
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Nemadji Trail Energy Center

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and the 115-kV line would be shifted onto the existing 161-kV structures. This would result in the 

following arrangement (from north to south): Stinson-Bayfront 115-kV Line No.761 on former 161-kV 

structures, Stinson-Gordon 161-kV Line No 160 and the Project 345-kV Line on double circuit structures, 

and the Great River Energy 69-kV line. All these lines would be located within the current transmission 

line corridor extending south from the Nemadji River Site. The Great River Energy 69-kV line extends 

south from this corridor approximately 0.3 mile south of the plant site, while the 115-kV line (on the 

former 161-kV structures) and the 345/161-kV double circuit would continue in parallel with each other. 

Toward the southeast, the Eastern Transmission Route and the 161-kV line would then turn south and 

continue on double circuit structures to the Parkland Switching Station for this Project.

The Western Transmission Route extends southeast from the Nemadji River Site to the existing Line No. 

160. The Western Transmission Route would be built double circuit with the 161kV Line 160 for a 

couple spans before extending southwest as a single-circuit transmission line. 

The existing electric transmission lines that traverse the Nemadji River Site would need to be relocated to 

facilitate construction of the generation plant if this site is chosen for the Project. The existing electric 

transmission lines would be relocated to the south end of the site. The existing lines that need to be 

relocated are 115-kV Line No. 132, 115-kV Line No. 761 and 161-kV Line No. 160. Additionally, a 

Great River Energy 69-kV line and a SWL&P 13.8-kV distribution line would also be relocated. The 

relocated portions of the lines would predominately consist of steel self-supporting structures with 

concrete foundations.

Outages would be required on the Line No. 160 transmission line and the Line No. 761 transmission line

to construct the new double circuit 345-kV Transmission Line for any Project alternative. Extended 

outages on the Line No. 761 are difficult to accommodate and would need to be minimized as much as 

practical to maintain reliable service to the area. The Project will require an outage to connect to the 

Arrowhead to Stone Lake 345 kV transmission line. During outages, the Owners would need to 

coordinate with local electrical service providers to provide for continued electrical service with minimal, 

if any, service interruptions.

The fiberoptic cable between the Nemadji River Site and the Hill Avenue Site would need to be relocated 

if the Nemadji River Site is constructed. An existing 10-inch natural gas line would need to be relocated 

at the Nemadji River Site.

The Project would require minor construction of water pipelines to connect with the municipal water 

system to meet the water needs for the plant. There would be no adverse impact to the municipal water 
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system or change in capacity requirements needed to the system related to the Project because the existing 

municipal sewer and water systems have sufficient capacity to accommodate the Project needs. The 

planned municipal water supply service would support sanitary needs and fire water back-up as well as

support service water needs (housekeeping, seal cooling, etc.), to supply the water treatment system as 

needed to accommodate cycle make-up needs (make up for steam losses and HRSG blowdown), and 

potentially as a NOx diluent in the gas turbine if fuel oil provisions are retrofitted in the future. SWL&P 

has indicated sufficient capacity is available to meet all these water needs. 

3.5.2.1.2 Transportation

Construction traffic accessing the Project site would primarily consist of automobile traffic for craft labor, 

construction management staff, contractors, equipment, and vendors. Material and equipment deliveries 

may be made by large trucks as well as heavy haul vehicles. Onsite, traffic is anticipated to primarily 

consist of heavy construction equipment and material transport equipment. 

The construction site would be operated as a closed worksite. Craft workers would be required to ‘badge 

in’ when arriving at the site for access after parking in the designated parking area. Designated walk paths 

to working locations would be constructed for craft workers to use. Craft workers would be expected to 

remain in the construction area onsite for the duration of their shifts, including a lunch break. 

The frequency of the daily workforce automobile traffic would follow the Project workforce numbers 

onsite at a given time. The daily automobile traffic to the site would increase from approximately 25 to 50 

vehicles per day in the initial stages of construction to approximately 200 to 260 vehicles per day during

peak months (April through December 2023). The traffic would begin to decrease until it reaches 

approximately 25 vehicles per day near construction completion.

Material and equipment deliveries are anticipated to average between 15 and 25 trucks per day. Bulk 

deliveries for materials such as crushed stone, hot asphalt paving, and redi-mix concrete may occasionally 

exceed 25 vehicles on a given day. When possible, bulk deliveries would be scheduled to avoid peak 

traffic on local roads. The Project Site would include pull over areas for material delivery trucks to reduce 

congestion.

It is anticipated that material deliveries would utilize the Wisconsin Interstate highway system to US 53, 

US 2, and State Highway 35, then to the local roads and into the plant entrance roads. Heavy haul 

components such as transformers, HRSG tube bundles, combustion turbines, and generators could be 

transported via barge, rail, or heavy haul truck to the Superior area, then transported over local roads via 

heavy haul truck to the site. Heavy haul transports would likely utilize US 53, US 2, or State Highway 35 
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to access the Project site, subject to the limits imposed by the governing heavy haul permits. Construction 

material and workforce would come to the Project site via rubber-tired transport.

No permanent changes to existing roads are anticipated as part of this Project. No permanent damage to 

roads is anticipated with the implementation of mitigation measures proposed in Section 3.5.3. The 

Owners would work with the appropriate county or municipal authority on solutions to potential traffic 

congestion that may develop as a result of the construction traffic.

There is currently no connection or proposed connection to rail lines related to the Project. The Eastern 

Transmission Route would parallel the existing Line No. 761 transmission line and the SWL&P natural 

gas pipeline across the Burlington Northern and Santa Fe (BNSF) railyard southeast and East City Limits 

Road. The Eastern Transmission Route would also require crossing a Canadian National rail line south of 

City Limits Road. The Western Transmission Route crosses over two BNSF rail lines and County Road 

Z, then extends due south to the north side of a Canadian National rail line. The Western Transmission

Route then extends east along the Canadian National rail line, crosses the rail line, and then continues east 

on the north side of the existing Arrowhead to Stone Lake 345-kV transmission line to the Parkland

Switching Station Site along Lyman Lake Road. The Hill Avenue Site Route crosses a Canadian Pacific 

rail line near the Hill Avenue Site. These rail lines would be spanned by the Project.

Any structure (including permanent structures and temporary construction equipment) on the Project site 

that exceeds 200 feet above ground level in height would be considered an obstruction to navigable 

airspace and could impact aircraft safety unless it is marked and lighted in accordance with criteria set 

forth by the FAA. The FAA does not study potential impacts to private use airports unless that airport has 

instrument procedures approved by the FAA. The St. Mary’s Hospital Heliport is a private use facility 

with FAA approved instrument approach procedures that are protected by the FAA obstruction evaluation 

process. However, the entire proposed Study Area is far outside the 5,000-ft radius notice criteria surface 

the FAA applies to such facilities. None of the remaining private use facilities in the area, including the 

St. Luke’s Hospital Heliport, are subject to the FAA obstruction evaluation process, and the Sites are 

outside the navigable airspace for the Duluth International Airport. The Richard I Bong Airport has 

multiple published instrument procedures. Sky Harbor Airport does not have published instrument 

procedures.

An aeronautical study was completed by the FAA for the proposed stack at the Nemadji River Site and 

Hill Avenue Site, and a Notice of Presumed Hazard (NPH) was issued September 20, 2017. The NPH 

letter stated that if the stack height were reduced to 194 feet above ground level, the stack would not 
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create a substantial adverse effect and a favorable determination could then be issued. The Owners

responded to the FAA on October 1, 2017, stating that the stack would not exceed the heights suggested 

by the FAA. The FAA subsequently issued Determination of No Hazard/Does Not Exceed (DNE) letters

for the stacks on October 3, 2017.

For the transmission line structures, an aeronautical study was completed by the FAA for the structures 

along each route alternatives and NPHs were issued for three structures on July 24, 2018. The NPH letters 

stated that if the structure heights were reduced, these three structures would not create a substantial 

adverse effect and a favorable determination could then be issued. The Owners responded to the FAA on 

August 3, 2018, stating that the structure heights would be lowered as to not exceed the maximum heights 

provided by the FAA. The FAA subsequently issued a Determination of No Hazard/DNE letter for all the 

structures that were studied, including these three, on October 2, 2018.

The Owners consulted with the WisDOT Bureau of Aeronautics and the City of Superior regarding 

Project structure heights. The WisDOT Bureau of Aeronautics indicated that Project structures were 

under the authority of the City of Superior since the Project was located within City limits. The City of 

Superior stated that the FAA determinations were sufficient for their purposes and the City would not 

require additional tall structure permits. 

The Project requires several temporary off-ROW access roads for construction access along the 

transmission line route. Temporary off-ROW access roads would be restored to pre-existing conditions, 

subject to the request of the landowner.

3.5.2.1.3 Public Health and Safety

The Project would minimize potential human health and safety impacts through restricting site access 

during construction and operation of the Project to employees, construction workers, emergency 

equipment, police, and fire protection. The roads serving the Project are adequate (width, grade, 

construction, overall safety and design capacity) to carry current and all prospective traffic. Access roads 

would be blocked from public access. 

The Project would comply with all relevant Federal, state, and local requirements, including all 

requirements concerning public health and safety, including but not limited to requirements addressing 

land use, noise, and traffic.

Existing healthcare facilities are anticipated to be sufficient for the Project during construction and 

operation, and no necessary improvements are anticipated. The Project would have fire suppression 
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measures of its own, as well as facilities for the storage of hazardous materials (see Section 3.5.2.1.4 for a 

list of chemicals stored during construction). This storage would require coordination activities with the 

City Fire Department. No improvements are anticipated to be required due to the Project related to the 

City Fire Department. Police protection would be provided by the City of Superior and the Wisconsin 

State Patrol during both construction and operations, and no necessary improvements are anticipated 

related to police patrols.

3.5.2.1.4 Waste Management

Solid waste produced during the Project would only occur from construction debris, wastes produced by 

construction workers, and wastes produced by employees onsite during operation of the Project. These 

wastes would be collected in trash containers throughout the Project site and sent to a local landfill. Local 

waste disposal and sanitation facilities are not anticipated to be adversely affected by the additional waste 

streams generated during construction and operation of the Project. No additional solid wastes would be 

generated by the Project as byproducts from the production of electricity.

Table 3-24 and Table 3-25 provide chemicals needed during construction, pre-operational cleaning, and 

for regular operations and maintenance once the Project is in-service.

Table 3-24: Typical Chemicals Stored During Construction

Product Storage Method

Di Ammonia EDTAa Delivered by contractor at time of service and stored in 

temporary tanks onsite

Antifoam Delivered by contractor at time of service and stored in 

temporary tanks onsite

Oxygen Delivered by contractor at time of service and stored in 

temporary tanks onsite

Surfactant Delivered by contractor at time of service and stored in 

temporary tanks onsite

Corrosion inhibitor Delivered by contractor at time of service and stored in 

temporary tanks onsite

Paint Delivered by contractor at time of service and stored in 

temporary tanks onsite

Solvents and cleaners Delivered by contractor at time of service and stored in 

temporary tanks onsite

Concrete curing compound Delivered by contractor at time of service and stored in 

temporary tanks onsite

Fuel oil and gasoline Stored in separate tanks onsite

19% aqueous ammonia Stored in tank(s) onsite
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Product Storage Method

Glycol Stored in drums onsite

Chlorine Stored in containers onsite

Lube oil Stored in reservoir and/or tanks and drums onsite

Hydraulic oil Stored in reservoir and/or tanks and drums onsite

Turbine Cleaning - Various 

detergents

Delivered by contractor at time of service and stored in 

temporary tanks onsite

Turbine Cleaning - Gas turbine 

generator water wash

Stored in separate tanks onsite

(a) ethylenediaminetetraacetic acid

Table 3-25: Typical Chemicals Stored for Operation

Product Use

HRSGa/Boiler Chemicals - Ammonia Boiler water treatment – condensate pHbcontrol

HRSGa/Boiler Chemicals - Phosphate Boiler water treatment – boiler water conditioner

Demineralizer and ROcchemicals -

Sulfuric acid RO feedwater treatment – pH adjustment and antiscalant

Demineralizer and ROcchemicals -

Sodium bisulfite RO feedwater treatment – dichlorination

Demineralizer and ROcchemicals -

Antiscalant RO feedwater treatment - antiscalant

Demineralizer and ROcchemicals -

Sodium Hydroxide RO second pass treatment - Carbon Dioxide removal

Service Water Treatment Chemicals -

Sodium hypochlorite Service water treatment – biocide

SCR System - Aqueous ammonia NOx

d

control

(a) HRSG = heat recovery steam generator

(b) pH = potential of hydrogen

(c) RO = reverse osmosis

(d) NOx = nitrogen oxides

3.5.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to infrastructure; transportation; 

public health and safety; or waste management at or in the vicinity of the Study Area because no 

generation of additional traffic, human activity, or waste would occur.
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3.5.3 Mitigation Measures

The following presents mitigation measures for transportation, public health, and waste management

resources for the Project. No mitigation measures related to utility infrastructure are proposed.

Transportation

The Owners do not anticipate permanent damage to roads. As a precautionary measure, the Owners will 

video-document the condition of all roads on the construction vehicle routes to document the road 

condition prior to the start of construction. Any documented adverse impacts to the roads incurred due to

the construction of the Project will be addressed through consultation with applicable road authorities 

regarding the Owners’ responsibility for repairing the adversely impacted roads. 

The Owners will coordinate the proper construction signage on the roads used by construction vehicles 

for the Project to make drivers aware of the increased hazards associated with the construction vehicle(s) 

presence.

Public Health and Safety

The Owners will develop a Health and Safety Plan to address public and worker safety during the 

construction and operation of the Project. The Health and Safety Plan would identify any requirements for 

temporary fencing around staging, excavation, and laydown areas during construction, as well as 

protocols for emergency responses. The Owners would work with local first responders to develop 

emergency response procedures in the plan. The plan would also include provisions for worker protection 

as is required under Occupational Safety and Health Administration (OSHA) CFR1926. During 

construction, all employees, contractors, and sub-contractors would be required to adhere to OSHA safety 

procedures, which will be taught in a mandatory training for all construction works on site. All heavy 

equipment would be up to OHSA safety standards and personal safety equipment would be required for 

all workers on site. Any accidents or incidents would be reported to the designated safety officer. During 

construction there is a risk of accidental fires being started by human activities such as refueling heavy 

equipment or the use of vehicles in dry vegetated areas. The Health and Safety Plan will have procedures 

in place to address and restrict the various activities that have a fire-related risk. A fire-suppression 

system will be incorporated into Project design. The Project will implement industry-approved design 

measures to reduce fire-related risks. 
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Waste Management

A Spill Prevention, Control and Countermeasures (SPCC) plan10 has been created for the Project (SSE, 

Dairyland, Burns & McDonnell, 2019). This plan establishes procedures, methods and equipment, and 

other requirements for equipment to prevent the discharge of oil from non-transportation-related onshore 

and offshore facilities into or upon the navigable waters of the United States or adjoining shorelines. 

The oil/water separator will be designed to remove 20 micron and larger oil droplets to concentrations of 

less than 10 ppm. It will be designed to store 1,000 gallons of oil. The oil/water separator will be 

constructed as a double walled buried tank and will have a leak monitor to detect a breech in the inner 

tank wall. The tank will be cathodically protected. Any oil collected will be pumped out as required for 

disposal. 

The Project will have a construction superintendent responsible for oil spill containment and cleanup. The 

construction superintendent will report spills and supervise cleanup and disposal of any contaminated soil 

and spill cleanup materials for any significant volume (defined as 55 gallons or more) of chemicals such 

as lubricants, fuel, grease, or other oil. Diesel and gasoline fuel will be temporarily stored at the Project 

site during construction in aboveground tanks. Preventative measures will be implemented during refueling or transfer of these fuels to reduce the risk of spills. Lubricating oils and certain other industrial 

chemicals required for the project will be stored in specially designed and covered containment areas. 

Also, equipment will be kept in good working condition through routinely inspections and service to 

reduce the risk of leaks of transmission, hydraulic, or brake fluid. Chemical storage areas will be well 

marked and include eye wash stations, first aid kits, safety showers, hose stations, and spill kits with 

absorbent pads and/or material. 

Larger spills will be removed from the containment area using a vacuum tank truck or will be pumped 

into a suitable container for cleanup. Contaminated soil and/or absorbent pads or products used to cleanup 

a spill will be immediately removed, stored, and disposed of in accordance with Wisconsin state 

regulations. Absorbent pads or other manufactured absorbent products will be used to cleanup minor 

spills. These pads and absorbent products will be stored on maintenance trucks and/or in a dedicated 

cabinet that is readily accessible. 

10 The SPCC Plan is available on the PSCW website at: 

http://apps.psc.wi.gov/vs2015/ERF_search/content/searchResult.aspx?UTIL=9698&CASE=CE&SEQ=100&STAR

T=none&END=none&TYPE=none&SERVICE=none&KEY=none&NON=N. PSC Reference No. 357005.
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The oil contaminated gravity drain system collects waste liquid which has the potential of containing 

quantities of oil and conveys the waste through an oil/water separator. Permanent combination safety 

shower/emergency eyewash stations with tepid water conditioning skid will be installed at all battery 

rooms and chemical storage areas including near the aqueous ammonia storage tank and SCR 

vaporization skids.

The Project site will be maintained to contain debris and waste in approved containers and locations. 

Regular trash and waste removal from the site will occur and a recycling program implemented for the 

site. Wastes are anticipated to be removed and disposed of at a local landfill by a local service provider. 

Recycling pickup services are anticipated to be provided by a local disposal company.

3.6 Land Use, Recreation, Farmland, and Coastal Facilities

The following sections provide information related to land use, public facilities, recreation, farmland, and 

coastal facilities for the various Project components.

3.6.1 Affected Environment

The Study Area contains large areas of wooded wetland, as well as deciduous forest, scrub/shrub, and 

grassland (Figure 2-8). The northern portion of the Study Area, near and within the City of Superior, is 

more developed than the rural, sparsely populated southern portion of the Study Area. Development 

includes residential areas and businesses; schools and parks; and industrial areas. The Study Area 

contains utility infrastructure such as oil tanks, electric transmission lines, electric distribution lines, crude 

oil pipelines, natural gas pipelines, fiber optic cable, water pipelines, and sewer pipelines and associated 

ROWs. The following sections provide more detailed information for the Project components related to 

land use, recreation, farmland, and coastal facilities.

3.6.1.1 Land Use

The following sections provide information related to land use for the Site alternatives, transmission line 

routes, and switching station sites.

3.6.1.1.1 Project Sites

The Nemadji River Site is divided between two separate tracts of land: the northwest portion which 

consists of a proposed laydown yard, and the southeast portion which is the proposed generation site 

location. The current land use for the northwest portion is land that is situated between two oil storage 

tank yards associated with the Husky Superior Oil Refinery. The southeast tract is situated on land that is 
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adjacent to the north side of the Nemadji River. These two tracts of land are bisected by 31st Ave E. The 

site is primarily undeveloped woodland, with areas of low intensity development, wetland, and grassland.

The Hill Avenue Site is located east of Hill Avenue and is bounded on the northeast side by the existing 

Winter to Stinson 115-kV transmission line. The site is undeveloped lowland scrub/shrub.

3.6.1.1.2 Switching Station Sites

The Superior Switching Station Site is located in the City of Superior (Figure 2-6). The Superior 

Switching Station Site is located along 42nd Avenue East south of 18th Street East. The site is 

predominantly forested wetland with areas of lowland scrub/shrub. An existing 69-kV transmission line 

extends along 42nd Avenue East along the south side of the switching station. 

The Parkland Switching Station Site for the Project is located in the City of Parkland (Figure 2-6). The 

site is situated in a wooded lot that is predominantly wetland. The site is bordered to the north by County 

Road Z and to the east by S Lyman Lake Rd. Forested and shrub areas border the west and south sides of 

the site. An existing 345-kV transmission line is situated approximately 300 feet south of the site and an 

existing 161-kV transmission line and natural gas pipeline parallel the east side of S Lyman Lake Rd. A 

rail line operated by Duluth Missabe & Iron Range extends near the site, approximately 200 feet from the 

northwest corner.

3.6.1.1.3 Transmission Corridors

The transmission line macro-corridors are primarily forested wetland areas and deciduous forest areas. 

The macro-corridors also cross areas of agricultural land, coniferous forest land, grassland, wetlands,

open water associated with rivers, and urban/developed areas.

3.6.1.2 Recreation

Recreational opportunities within the Study Area include the Nemadji Golf Course, Nemadji Sled Hill, 

and the Nemadji River canoe launch (Figure 2-10). There is also fishing access at 18th Street and 11th 

Street for the Nemadji River. There are also several hunting areas owned by the City of Superior and 

Douglas County within the Study Area (Figure 2-10). The Orange Trail extends through the northern 

portion of the Study Area near 31st Avenue East and the Enbridge Energy Facility. The Wild Rivers State 

Trail extends a short distance into the western boundary of the Study Area. Several small city parks can 

be found adjacent to the outside of the Study Area. However, none of these parks are located within 0.5 

mile of the Nemadji River Site, Hill Avenue Site, or within the macro-corridors.
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3.6.1.3 Farmland

Agricultural land in the Study Area is sparse as most of the Study Area is situated in urban/developed 

areas (predominately the northern third of the Study Area) and wetland/forestland/grassland 

(predominantly the southern two thirds of the Study Area). A small area of tilled land is adjacent to the 

northeast corner of the Parkland Switching Station area. 

The NRCS Web Soil Survey was used to identify prime farmland and other important farmland soils in 

the Study Area. In Part 523 of the Farmland Protection Policy Act, the NRCS defines prime farmland as: 

...land that has the best combination of physical and chemical characteristics for 

producing food, feed, forage, fiber, and oilseed crops and is also available for these uses. 

The land could be cropland, pastureland, rangeland, forestland, or other land but not 

urban built-up land or water (USDA, 2012).

No prime farmland exists within the Study Area. Approximately 13.1 square miles of the 22-square mile 

Study Area is considered farmland of statewide importance11 (Figure 2-12). The remaining land in the 

Study Area is designated as “not prime farmland12” by the NRCS (approximately 9.3 square miles).

No known agricultural buildings and animal dairy confinement operations are located in or near the Study 

Area.

3.6.1.4 Coastal Facilities

The Great Lakes coastline includes shoreline in Douglas County, Wisconsin. The Federal Emergency 

Management Agency (FEMA) has initiated a coastal analysis and mapping study to produce updated 

Flood Insurance Rate Maps (FIRMs) for coastal counties along the Great Lakes. In partnership with 

USACE Detroit District and the Engineer Research and Development Center (ERDC), FEMA conducted 

a comprehensive analysis of storm and high-water events within the Great Lakes Basin. The study uses 

the latest scientific methods and the best available data to comprehensively depict flood hazards along the 

lakeshore. The new flood risk information would be used to increase the understanding of local flood risk, 

11 USDA designates map units as ‘farmland of statewide importance’ when less than 50 percent of the map unit 

components are prime, but a combination of lands of prime or statewide importance is 50 percent or more of the 

map unit composition. Areas of statewide importance farmland are determined by the State Conservationist (USDA, 

2012).

12 Soils that are designated as “not prime farmland” do not have the combination of physical and chemical 

characteristics of prime farmland and is also not designated as farmland of statewide importance.
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facilitate mitigation efforts, and improve local community resilience to flood losses (life, property, and 

business) along the Great Lakes.

The Wisconsin Coastal Management Program (WCMP) preserves and manages access to Wisconsin’s 

natural and historic Great Lakes coastal resources (WCMP, 2019). The objectives of the WCMP are:

• To improve the implementation and enforcement of existing state regulatory and management 

policies and programs affecting key coastal uses and areas;

• To improve the coordination of existing policies and activities of governmental units and 

planning agencies on matters affecting key coastal uses and areas;

• To strengthen local governmental capabilities to initiate and continue effective coastal 

management consistent with identified state standards and criteria;

• To provide a strong voice to advocate the wise and balanced use of the coastal environment and 

the recognition in Federal, state, and local policies of the uniqueness of the coastal environment; 

and

• To increase public awareness and opportunity for citizens to participate in decisions affecting the 

Great Lakes resources.

The coastal zone boundaries subject to WCMP include the 15 counties with frontage on Lake Superior 

and Lake Michigan. Douglas County is one of the 15 counties in the WCMP. The Study Area and 

facilities are located within Douglas County, but do not contain Great Lakes coastline.

In addition to WCMP, the Coastal Barrier Resources Act of 1982 (CBRA) designated relatively 

undeveloped coastal barriers along the Atlantic, Gulf of Mexico, Great Lakes, U.S. Virgin Islands, and 

Puerto Rico coasts as part of the John H. Chafee Coastal Barrier Resources System (CBRS). CBRA was 

designed to encourage conservation of areas that are hurricane prone or biologically rich coastal barrier 

by restricting federal expenditures that encourage development, such as federal flood insurance. These 

locations are ineligible for most new federal expenditures and financial assistance. The nearest CBRS 

area is located approximately 30 miles northeast of the Project area along the Lake Superior shoreline in 

Bayfield County. 

3.6.2 Environmental Consequences

The following sections provide potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to land use, recreation, farmland, and coastal facilities.
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3.6.2.1 Proposed Action Alternatives

The following sections provide information on the potential impacts of the proposed Action Alternatives

on land use, recreation, farmland, and coastal facilities.

3.6.2.1.1 Land Use

Construction of the proposed project at the Nemadji River Site would permanently convert approximately 

7.1 acres of forest and approximately 7.2 acres of the forage grassland and wetland meadow communities 

to power generation use. This use is compatible with adjacent land uses, which include an oil tank farm 

and an oil refinery. The proposed project footprint at the Nemadji River Site avoids clearing trees and 

vegetation along the banks, immediately adjacent to the Nemadji River. A vegetation buffer with a 

minimum width of 100 feet would be maintained between the plant footprint and the Nemadji River.

Based on the results of a site survey that was conducted in October 2017, the Hill Avenue Site consists 

entirely a lowland scrub/shrub wetland community. No forest or grassland community occurs at the Hill 

Avenue Site. The Eastern Transmission Route for the transmission line would likely be constructed 

within an existing utility corridor that contains a natural gas pipeline and overhead electrical transmission 

lines; however, approximately 23.1 acres of woody vegetation would be cleared from forested lands and 

shrubland habitats to widen the corridor and accommodate the additional line. Woody vegetation would 

be removed where additional, new ROW is needed and along the edges of the existing utility corridor. 

The Western Transmission Route would require more clearing in forested areas for new ROW in addition 

to minor impacts to forested land along the existing shared utility corridors. Woody vegetation clearing 

would occur along approximately 79.1 acres of the Western Transmission Route in forested lands and 

shrubland habitats. Woody vegetation would be removed where additional, new ROW is needed and 

along the edges of the existing utility corridor.

The Hill Avenue Site Route would require clearing in forested areas for new ROW and along the existing 

shared utility corridors. Woody vegetation clearing would occur along approximately 14.3 acres of the 

Hill Avenue Site Route in forested lands and shrubland habitats.

Construction of the either the Superior Switching Station or the Parkland Switching Station would 

convert approximately 14 acres of woody vegetation in forested lands and shrubland habitats to a 

switching station with electric transmission infrastructure.

It is anticipated that most of the impacts to grasslands along the transmission route would only be 

temporary construction impacts to existing grassland habitat along existing utility corridors. Some 
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permanent impacts to grassland habitats would occur where transmission line poles and foundations 

would be set. No grassland habitat is present within the footprint of either switching station site.

3.6.2.1.2 Recreation

No parks are located within 0.5 mile of the Nemadji River Site, Hill Avenue Site, or within the macrocorridors; therefore, impacts to any parks are not expected. While the Sites may be visible from these 

parks and loud Site noise such as from steam blows may be heard offsite, several streets with homes, 

combined with nearby commercial and industrial areas provide visual and sound buffers between the Sites 

and the existing parks. The transmission line routes primarily extend through undeveloped wooded areas. 

The switching station sites are also mostly surrounded by woodland, which helps provide visual buffers.

The fishing access at 18th Street and Nemadji canoe launch are accessed from roads also used to access 

the Nemadji River Site and are near the transmission routes south of the Nemadji River Site. Though not 

directly crossed, the access may be impacted during construction of facilities through temporary road 

closures and temporary increased noise associated with construction. If the Nemadji River Site is 

constructed, there would be increased traffic and operation noise near the fishing access at 18th Street

during operation. Traffic during operation would primarily include employees entering or exiting the 

plant facility, as well as occasional maintenance vehicles. Traffic during operation of the Project would

increase vehicles on nearby roads but is not anticipated to significantly increase traffic due to the number 

of employees anticipated or reduce access to these facilities.

The Project may impact visitors to the Orange Trail, a snowmobile and ATV trail that generally extends 

along 31st Avenue East and Grand Avenue southwest of the site. Impacts would include increased traffic 

crossing the trail or temporary closures during Project construction, as well as slightly increased traffic

crossing the trail during Project operation. Construction traffic and any road closures would be temporary 

in nature and cease after construction is complete. 

The Nemadji River Site is not located within a hunting area. The transmission line route south of the 

Nemadji River Site would require clearing woodland in a portion of the Allouez Area Parcel 1 hunting 

area, the Itasca Area hunting area, and the Annex hunting area. The route generally follows existing 

transmission line and natural gas line through these parcels, however. Clearing would remove woodland 

habitat and result in a minor change to the habitat mix on these areas. Access to all or portions of these 

areas may also be controlled during construction. Once completed, access to these areas would be 

restored. The Hill Avenue Site would reduce the size of the Murphy Oil – 5 hunting area by 

approximately 72 acres. This would reduce the amount of area available for hunting in the northern 
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portion of the hunting area. The transmission line route from the Hill Avenue Site south to the Nemadji 

River would also remove a portion of the Murphy Oil – 5 hunting area from hunting activities. The 

Eastern and Western Transmission Routes would both cross the Allouez Area Parcel 1 hunting area. The 

Eastern Transmission Route would also cross the Itasca Area hunting area as well as the Annex hunting 

area. The Western Transmission Route would cross a small portion of the Allouez Area Parcel 2 hunting 

area. The connecting facilities extending from the Hill Avenue Site to the southeast would cross 

greenfield and would introduce a new utility corridor through the hunting area. 

3.6.2.1.3 Farmland

No farming activities currently occur at either Site. No farming has occurred in the recent past. A review 

of earliest available records from 1938 through 2015 show the majority of the Nemadji River Site 

property has remained undeveloped and heavily wooded, with the exception of a gravel parking lot and a 

storm water pond located on the western side. Based on historical topographic maps, the Hill Avenue Site

has been marsh/swamp, and no agricultural or residential use on the Hill Avenue Site was identified. 

The Western Transmission Route and Hill Avenue Site Route do not cross farmland. The Eastern 

Transmission Route extends along the edge of a row crop field north of its intersection with County Road 

Z for approximately 930 feet. This length is entirely within existing ROW, however. 

The row crop field crossed by the Eastern Transmission Route would be impacted during construction of 

the Project. This section of route is within existing ROW, however, which helps restrict impacts to 

already impacted areas. Soil along this portion of the route would likely be disturbed during transmission 

line construction and temporary access. If planted, crops in the ROW could be damaged during 

construction. After construction is complete in the area, farming activities can resume.

No known agricultural buildings and animal dairy confinement operations are located near the Project. In 

addition, the Project’s electrical clearances and ROW width are designed to limit neutral-to-earth and 

induced voltages that can create concern with livestock operations.

An agricultural impact notice was sent to the Wisconsin DATCP on December 18, 2018. An Agricultural 

Impact Statement was not required as the Project does not cross private agricultural land. See Appendix D

for correspondence with the Wisconsin DATCP as well as the formal release letter.
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3.6.2.1.4 Coastal Facilities

No coastal facilities are located within the Project Study Area or macro-corridors. The nearest CBRS area 

is located approximately 30 miles northeast of the Project area along the Lake Superior shoreline in 

Bayfield County. As such, no impacts to coastal facilities are anticipated due to the Project.

3.6.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to land use, recreation, farmland, 

or coastal facilities at or in the vicinity of the Study Area because no construction would occur.

3.6.3 Mitigation Measures

During construction, portions of the Project site will be cleared, grubbed, graded, excavated, and 

revegetated. In areas not impacted by these activities, such as riparian vegetation along the Nemadji River 

outside the ROW and areas of the transmission line ROW that do not require clearing, existing vegetation 

will be preserved where practicable. The amount of soil exposed during construction will be minimized. 

Seed mixtures will be selected to produce dense vegetation based on soil and site conditions, along with 

intended final use. In areas were restoration is required, seeding and mulching will be completed in 

accordance with WDNR Technical Standard 1059 – Seeding for Construction Site Erosion Control, 

Chapter DATCP 20, WAC regarding noxious weed seed content and labeling, and Wisconsin Department 

of Transportation (WisDOT) Mix 75 – Erosion Control Native Mix. 

Temporary seeding will be applied to areas of exposed soil where the establishment of vegetation is 

desired, but the areas have not been brought to final grade or on which land-disturbing activities will not 

be performed for a period greater than 30 days, but vegetative cover is required for less than 1 year. Areas 

needing protection during periods when permanent seeding is not applied, must be seeded with annual 

species. 

Final stabilization is achieved when all soil-disturbing activities at the site have been completed and a 

uniform (i.e., evenly distributed, without large bare areas) perennial vegetation cover with a density of 70 

percent of the native background vegetative cover has been established on all unpaved areas or areas not 

covered by permanent structures or with alternative surfacing, such as riprap or crushed rock. 

During construction, areas that have been seeded will be inspected by a qualified person at least once 

every 7 days and within 24 hours after every precipitation event that produces 0.5 inch of rain or more 

during a 24-hour period. Where areas of concern are identified, the area will be re-seeded and watered, 

and fertilizer will be applied, if applicable. The Project site will be inspected at least once per month to 
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monitor vegetative growth until final stabilization is achieved after construction and stabilization 

activities are complete.

The Owners will comply with WAC, Chapter Natural Resources (NR) 40, WAC – Invasive Species 

Identification, Classification and Control during monitoring and management of invasive plant species. 

The Owners will control any prohibited plant species identified onsite during inspection and monitoring 

activities and will minimize the spread of restricted plant species beyond their known boundaries 

throughout the duration of the Project.

In accordance with Chapter Department of Agriculture, Trade and Consumer Protection (DATCP) 20, 

WAC, seed mixtures that contain potentially invasive species or species that may be harmful to native 

plant communities will be avoided. Seed will be tested for purity, germination, and noxious weed seed 

content, and will meet the minimum requirements prescribed in the current edition of Rules for Testing 

Seed, published by the Association of Official Seed Analysts. 

To minimize impacts to agricultural areas, construction of the transmission line will occur after harvest 

and/or before spring planting and be contained within the existing ROW to the greatest extent practicable, 

to reduce the potential for loss of crop production. Outside of winter months, matting will be used in wet 

areas to spread out heavy vehicle loads and minimize soil disturbance.

The Owners will coordinate the proper construction signage near recreation area access points on the 

roads used by construction vehicles for the Project to make drivers aware of the increased hazards 

associated with the construction vehicle(s) presence.

3.7 Noise

The following sections provide information related to noise associated with the Project. 

3.7.1 Affected Environment

The land use immediately surrounding the proposed generating station locations is industrial, commercial, 

and residential. There are residential properties to the north and east of the Nemadji River Site and an 

industrial tank farm to the west. The Hill Avenue Site has residential property to the northeast and east, 

with commercial property to the north and industrial property to the west and south. Noise is primarily 

generated by activities in industrial areas, traffic on existing area roads, air traffic at nearby airports and 

airstrips, and rail traffic along area railroads.
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Applicable Federal, state, county, and municipal noise ordinances were reviewed for the Study Area. The 

Project would be in the City of Superior, Wisconsin. The State of Wisconsin, Douglas County, and City 

of Superior do not have noise ordinances with applicable numerical sound level limits for the Project. The 

EPA established noise guidelines to protect public health and welfare in 1971. Though the guidelines are 

not enforceable Federal limits or standards, they represent valid criteria for evaluating the effect of 

Project-generated noise on public health and welfare. 

Environmental sound level measurements were obtained to establish the existing ambient sound levels in 

the areas surrounding the Sites. The environmental sound level measurements were taken in accordance 

with the PSCW Measurement Protocol for Sound and Vibration. Sound levels at each frequency were 

measured for 10 minutes and logged by the sound level meter at each location. The sound levels varied at 

each measurement point depending on the extraneous sounds that occurred during each measurement. 

3.7.2 Environmental Consequences

The following sections provide potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to noise.

3.7.2.1 Proposed Action Alternatives

Project construction would result in temporary and minor noise impacts in the surrounding area. 

Construction-related sounds would vary in intensity and duration depending on specific stages and 

activities of construction but would not be permanent. Nearby residences may temporarily experience 

increased noise during construction. Minor temporary disturbances to wildlife could occur. 

As there are no specific government agency-related numeric noise limits for the Project, the Owners have

elected to follow the EPA noise guidelines in order to minimize sound level impacts to the neighboring 

residences. The EPA’s overall Leq and Ldn guidelines are shown in Table 3-26. The Leq is the average 

sound level for a specific time period, and the Ldn is the average sound level over a 24-hour period with 

the inclusion of a 10-dB penalty during the nighttime hours of 10 P.M. to 7 A.M.

The noise levels contained in Table 3-26 were established as required by the Act, but do not constitute 

enforceable Federal regulations or standards. However, these noise levels represent valid criteria for 

evaluating the effect of Project-generated noise on public health and welfare. Many noise studies 

performed for new projects compare residential noise levels to these EPA-established guidelines.

The recommended EPA guideline for outdoor activity in residential areas is an Ldn of 55 dBA or less.
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Table 3-26: EPA Noise Levels Identified to Protect Public Health and Welfare

Effect Noise Level Area

Hearing Loss Leq(24) ≤ 70 dBA All areas.

Outdoor activity 

interference Ldn ≤ 55 dBA

Outdoor residential and farm areas, and other outdoor areas 

where people spend widely varying amounts of time and 

other places in which quiet is a basis for use

Outdoor activity 

interference Leq(24) ≤ 55 dBA Outdoor areas where people spend limited amounts of time, such as school yards, playgrounds, etc.

Indoor activity 

interference and 

annoyance

Ldn ≤ 45 dBA Indoor residential areas

Indoor activity 

interference and 

annoyance

Leq(24) ≤ 45 dBA Other indoor areas with human activities, such as school, 

etc.

Source: EPA, Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an 

Adequate Margin of Safety, 1974

Using industry-accepted sound modeling software (CadnaA), the expected sound pressure levels of the 

Project were predicted. The software is a scaled, three-dimensional program which considers each piece 

of sound-emitting equipment and predicts sound-pressure levels over a gridded geographic area of 

interest. The model calculates sound propagation based on International Organization for Standardization 

(ISO) 9613-2:1996, General Method of Calculation. ISO 9613-2 assesses the sound levels based on the 

octave band center frequency range from 31.5 to 8,000 hertz.

Equipment sound power levels were provided for the gas turbine, fin fan heat exchanger, steam duct, and 

air cooled condenser. Gas turbine sound levels provided by the equipment manufacturer are considered to 

be unmitigated. Other noise sources were assumed based on historical data from projects of similar size 

and scope. In the model, appropriate sound generation was applied to all sound-radiating surfaces and 

points. The planned site grading topography changes have been included in the respective noise models. 

Modeled results for the Nemadji River Site show a maximum total A-weighted sound level emitted from 

the Project that would be in excess of the EPA guideline noise levels at the nearest residential properties. 

The Nemadji River Site, however, can meet the EPA guidelines with mitigation (Table 3-27). Modeled 

results for the Hill Avenue Site show a maximum predicted A-weighted sound level emitted from the 

Project that would be in excess of the EPA guideline noise levels at the nearest residential property. The 

Hill Avenue Site would need further mitigation to reduce sound levels to below the EPA guidelines

(Table 3-28). However, these guidelines are not enforceable sound level limits and are only provided as a 

suggested design goal.
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Table 3-27: Sound Modeling Results at the Nemadji River Site with and without Mitigation

Location

Baseline Modeled 

Sound Level

(Leq / Ldn dBA)

Mitigated Modeled 

Sound Level

(Leq / Ldn dBA)

Res 1 (MP4) 50.1 / 56.5 48.0 / 54.4

Res 2 42.8 / 49.2 41.6 / 48.0

Res 3 (MP5) 44.8 / 51.2 43.1 / 49.5

Res 4 (MP6) 44.9 / 51.3 43.4 / 49.8

Table 3-28: Sound Modeling Results at the Hill Avenue Site with and without Mitigation

Location

Baseline Modeled 

Sound Level

(Leq / Ldn dBA)

Mitigated Modeled 

Sound Level

(Leq / Ldn dBA)

Res 1 (MP1) 51.9 / 58.3 50.0 / 56.4

Res 2 (MP4) 55.1 / 61.5 53.3 / 59.7

Res 3 (MP5) 48.5 / 54.9 47.8 / 54.2

Steam blows, which are an uncommon commissioning and maintenance activity occurring prior to 

commercial operation of the facility and in association with major plant maintenance, have the potential 

to significantly increase sound levels near the Project, regardless of the site, during their temporary 

operation. Following the initial steam blow for commercial operation, subsequent steam blows would be 

rare occurrences, anticipated once every 10 to 15 years as part of major system maintenance. Because 

these are rare and not long-term sources of noise, their impact is expected to be minimal. 

3.7.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to existing noise levels at or in the 

vicinity of the Study Area because no construction would occur.

3.7.3 Mitigation Measures

Within twelve months of the date when the project is fully operational, and within two weeks of the 

anniversary date of the pre-construction ambient noise measurements, sound level measurements will be 

repeated both with and without the Project in operation to verify noise levels do not exceed contractually 

guaranteed levels, as well as EPA guideline levels. Sound measurements will be taken at the same

measurement points that were analyzed for the ambient measurements. The Owners will provide notice to 

nearby residents of expected timeframes for steam blow operation.
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3.8 Socioeconomics and Environmental Justice

The following section provides information related to socioeconomics and environmental justice.

3.8.1 Affected Environment

Various public facilities are located within the Study Area. One school, the Great Lakes Elementary 

School, is located in the northern portion of the Study Area along North 28th Street East. St. Luke’s 

Mariner Medical Clinic Urgent Care is also located in the northern part of the Study Area on the north 

side of North 28th Street East. Two religious facilities are located along North 28th Street East: Christ 

Lutheran Church and Memorial Garden (located on the south side of North 28th Street East) and United 

Presbyterian Church (located on the north side of North 28th Street East).Two retirement facilities are 

located within 0.5 mile of the Hill Avenue Site: Villa Rita, a low-income housing development for age 55 

and older and Villa Marina Health and Rehabilitation. Both facilities are located at the northwest corner 

of North 28th Street and Hill Avenue. The St. Francis Catholic Cemetery and Nemadji Cemetery are

located to the northeast of the Nemadji River Site along 31st Ave E and are buffered by approximately 

130 feet of trees. Two cemeteries are located in the central portion of the Study Area with access from 

County Road Z: Woodland Cemetery and the County Hospital Cemetery. Lastly, there are three public 

facilities (post office, fire department, and a Town of Parkland office) located in the southeastern portion 

of the Study Area on County Road K.

3.8.1.1 Population Growth Trends

The Study Area is within Douglas County, Wisconsin. It includes portions of the City of Superior, Town 

of Superior, and Town of Parkland. Wisconsin, Douglas County, the Town of Superior, and the Town of 

Parkland experienced growth between 2000 and 2017, while the City of Superior decreased in population 

slightly (Table 3-29). According to the U.S. Census Bureau (2000, 2017), Wisconsin had a growth rate of 

7.4 percent from 2000 to 2017. The Town of Parkland had the highest growth rate of communities in the 

study area at 6.5 percent, considerably higher than Douglas County (0.5 percent), but lower than the State 

overall.
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Table 3-29: Population Trends

2000 2010

2017 5-Year 

Estimate

Percent Change 

2000-2017

Wisconsin 5,363,675 5,686,986 5,763,217 7.4

Douglas County 43,287 44,159 43,503 0.5

City of Superior 27,368 27,244 26,473 -3.3

Town of Superior 2,058 2,166 2,140 4.0

Town of Parkland 1,240 1,220 1,321 6.5

Source: U.S. Census Bureau, 2000 and 2010 Censuses; U.S. Census Bureau American Community Survey 2013-

2017 5-Year Estimates

3.8.1.2 Population, Race, and Income Levels

The U.S. Census Bureau (2017) American Community Survey 5-Year Estimates has published 

demographic data for 2013-2017. Table 3-30 shows estimates for the State of Wisconsin, Douglas 

County, City of Superior, Town of Superior, Town of Parkland, and for the census tracts within which 

Project components would be located (Figure 3-3).

The Study Area population composition is primarily white, with small percentages of black or African 

American, American Indian, Asian, and other races. The median household income levels within the 

Study Area range from $43,836 in the City of Superior, to $70,875 in the Town of Superior. The City of 

Superior had the greatest percentage of people whose income in the past 12 months was below poverty 

level (18.0 percent) while the Town of Superior had the lowest percentage (5.9 percent).
VILLAGE OF

SUPERIOR

TOWN OF

SUPERIOR

PARKLAND

CITY OF SUPERIOR

Census

Tract

207

Census

Tract

206

Census

Tract

209

Census

Tract

205

Census

Tract

208

Census

Tract 302

Census

Tract 204

Census

Tract 9900

Census

Tract

210

Service Layer Credits: COPYRIGHT © 2020 BURNS & McDONNELL ENGINEERING CO

MPANY, INC.

Source: Esri, Minnesota Power, City of Superior 2019 Aerials, USGS PADUS, FAA, USGS NHD, and Burns & McDonnell Engineering Company, Inc. Issued: 3/12/2020 Path: Z:\Clients\ENS\SouthShoreEn\101798_NTECGeneration\Studies\Geospatial\DataFiles\ArcDocs\EA\3_3_Study_Area_CensusTracts.mxd kasamuelson 3/12/2020

NORTH

0 0.5 1

Miles

Figure 3-3

Census Tracts

SSE and DPC

Nemadji Trail Energy Center

Douglas County, WI

Study Area

Lake Superior

Douglas

County

Carlton

County

Pine

County

St. Louis

County

Wisconsin

Minnesota

Study Area

Macro-Corridors

Municipal

Boundary

County

Boundary

Census Tract

Boundary
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Table 3-30: Population Characteristics – City of Superior and Census Tracts near Project

Demographic Group

Douglas 

County, 

Wisconsin

City of 

Superior

Town of 

Superior

Town of 

Parkland

Census 

Tract 204

Census 

Tract 205

Census 

Tract 208

Census 

Tract 209

Census 

Tract 210

Census 

Tract 302

Total population 43,503 26,473 2,140 1,321 3,429 2,961 3,267 2,359 1,674 5,188

White (percent) 93.0 91.8 97.0 93.6 92.2 88.0 91.9 92.6 90.4 94.9

Black or African American 

(percent) 1.2 1.8 0.0 0.0 1.1 5.5 1.7 1.7 3.9 0.3

American Indian and 

Alaska Native (percent) 1.7 1.8 1.5 4.1 0.3 1.2 2.3 1.1 3.5 2.2

Asian (percent) 1.0 1.4 0.2 1.3 0.6 4.0 1.9 0.0 0.7 0.4

Native Hawaiian and Other 

Pacific Islander (percent) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Some other race (percent) 0.3 0.3 0.3 0.0 0.0 0.3 0.3 0.0 0.0 0.2

Two or more races 

(percent) 2.7 2.9 1.0 1.1 5.7 1.0 1.7 4.6 1.4 2.0

Hispanic or Latino 

(percent) 1.5 1.8 1.1 1.0 2.0 2.3 0.7 0.4 0.0 2.0

Median household income $ 50,730 $ 43,836 $70,875 $57,404 $ 49,977 $ 63,152 $ 51,563 $ 51,985 $ 45,439 $ 65,906

All people whose income 

in the past 12 months is 

below the poverty level 

(percent)

15.5 18.0 5.9 6.8 9.8 13.6 15.0 10.7 11.6 7.9

Source: U.S. Census Bureau American Community Survey 5-Year Estimates, 2013-2017
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3.8.1.3 Employment

Table 3-31 provides employment characteristics for the State of Wisconsin, Douglas County, the City of 

Superior, Town of Superior, and Town of Parkland. The Town of Superior had an estimated 

unemployment rate of 6.8 percent for its civilian labor force, while the Town of Parkland, City of 

Superior, and Douglas County had slightly lower unemployment rates (5.1 percent, 5.4 percent, and 5.6

percent, respectively).

Table 3-31: Employment Characteristics

Douglas 

County

City of 

Superior

Town of 

Superior

Town of 

Parkland

Population 16 years and over 35,571 21,685 1,774 1,083

In labor force 22,911 14,279 1,191 743

Employed (civilian labor 

force) 21,594 13,494 1,110 701

Unemployed (civilian labor 

force) 1,293 776 81 38

Armed forces 24 9 0 4

Not in labor force 12,660 7,406 583 340

Unemployment rate, civilian 

labor force (percent) 5.6 5.4 6.8 5.1

Top occupation

Management, 

business, science, 

and arts 

occupations

Management, 

business, science, 

and arts 

occupations

Management, 

business, science, 

and arts 

occupations

Management, 

business, science, 

and arts 

occupations

Top industry

Educational 

services, and 

health care and 

social assistance

Educational 

services, and 

health care and 

social assistance

Educational 

services, and 

health care and 

social assistance

Educational 

services, and 

health care and 

social assistance

Source: U.S. Census Bureau American Community Survey 2013-2017 5-Year Estimates

The top occupation category for Douglas County, the City of Superior, Town of Superior, and Town of 

Parkland was management, business, science, and arts occupations. The top industry category was 

educational services, and health care and social assistance (USCB, 2017).

3.8.1.4 Environmental Justice

Environmental justice concerns may arise from the human health or environmental effects of a project on 

minority or low-income populations. Executive Order (EO) 12898, “Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations”, provides that “each 

Federal agency shall make achieving environmental justice part of its mission by identifying and 

addressing, as appropriate, disproportionately high and adverse human health or environmental effects of 
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its programs, policies, and activities on minority populations and low-income populations” (CEQ, 1997). 

In the memorandum that accompanied EO 12898, the President specifically recognized the importance of 

procedures under NEPA for identifying and addressing environmental justice concerns. The

memorandum states that “each Federal agency shall analyze the environmental effects, including human 

health, economic and social effects, of Federal actions, including effects on minority communities and 

low-income communities, when such analysis is required by NEPA.” 

Environmental justice issues are identified by first determining whether minority or low-income 

populations are present. If so, then any disproportionate effects on these population would be identified 

and considered. The CEQ guidance states that minority populations should be identified when the 

percentage of minority residents in the affected area exceeds 50 percent or is meaningfully greater than 

the percentage of minority residents in the general population (CEQ, 1997). If the percentage of minority 

residents of the population in the area census tract exceeds the county level by more than 10 percent, it is 

considered to be “meaningfully greater” for the purposes of the analysis. The CEQ guidance also states 

that low-income populations should be identified based on poverty thresholds as reported by the U.S. 

Census Bureau (USCB). If the poverty rate for the population of the area census tract exceeds the county 

poverty rate by more than 10 percent, it is considered to be an area of environmental justice concern for 

the purposes of the analysis. Table 3-32 provides total minority and poverty information for the Study 

Area.

Table 3-32: Total Minority and Poverty near Project

Environmental 

Justice Factor

Douglas 

County, 

WI

Census 

Tract 204

Census 

Tract 205

Census 

Tract 208

Census 

Tract 209

Census

Tract 210

Census 

Tract 302

Total minority 

(percent) 8 9 12 12 7 11 7

Low-income 

population

(percent)

33 27 33 34 28 45 22

Source: EPA EJScreen, 2019

Based on this methodology, Census Tract 210 is considered to be in an environmental justice low-income 

area. The low-income population of Census Tract 210 is 10 percentage points higher than Douglas 

County. The poverty rates for the remaining Study Area census tracts are not substantially higher (and for 

Census Tracts 204, 209, and 302, the poverty rates are lower) than the county poverty rate. 
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As identified in Table 3-32, the percentage of minority residents in Census Tracts 204, 205, 208, 209, 

210, and 302 is only slightly higher (and for Census Tracts 209 and 302, slightly lower) than the 

percentage for Douglas County as a whole. Therefore, no environmental justice minority areas were 

identified in the Study Area.

3.8.2 Environmental Consequences

The following sections provide potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to socioeconomics and environmental justice.

3.8.2.1 Proposed Action Alternatives

During construction at either site, the Project would create up to 260 jobs during peak activity. These jobs 

would include construction management staff, site superintendents, skilled craftsmen, engineers, start-up 

support personnel, and other miscellaneous services. Contractors would be chosen from a competitive bid 

process and would be local whenever practical.

Craft labor, including carpenters, heavy equipment operators, laborers, millwrights, ironworkers, masons, 

pipefitters, and electricians, would be required during construction. Other staff would also be onsite 

during construction, such as management, engineering, technical, and start-up staff. The number of 

workers onsite would begin at nominal levels at the beginning of construction and steadily increase over 

time, declining as major construction activities are completed. 

Contractors would be chosen from a competitive bid process and would be local whenever practical. The 

workforce may be sourced from different locations locally or nationwide. The Owners, construction 

contractor, and sub-contractors would supply staff for management, engineering, technical, start-up, and 

other support staff. Skilled labor such as carpenters, heavy equipment operators, laborers, millwrights, 

ironworkers, insulators, painters, boilermakers, sheet metal workers, masons, pipefitters, electricians etc., 

would be sourced as available from sub-contractors and/or local union labor halls. Local businesses near 

the Facility, such as gas stations, convenience stores, and restaurants, may experience increases in 

business during construction due to construction workers onsite. Local materials such as concrete, lumber, 

and general hardware may be purchased from local businesses. This increased demand would cease after 

construction is complete and would not add considerably to the demand on existing business, services, or 

community facilities.

The new permanent employment positions (up to 25 full-time permanent jobs) include Control Room 

Operators; Mechanical Maintenance Technicians; and Electrical, Instrument, and Control Technicians.

These new permanent employees may be from the local workforce or may relocate to the area for the 
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position. Considering the population of the City of Superior (26,473 residents) and Douglas County 

(43,503 residents), the addition of 25 jobs is not anticipated to considerably increase demand for housing, 

schools, or other local services. 

The City of Superior and Douglas County would receive payments in lieu of taxes of around one million 

dollars annually (two-thirds to the city; one-third to the county) from the State of Wisconsin for hosting a 

generation facility. The City of Superior would also receive considerable fees from the facility for 

increased use of the City’s wastewater treatment system. County sales tax revenues are likely to increase 

over time, especially during the intense construction phase. There could be a negative local budget impact 

due to the increased use of 31st Avenue East, which is currently a short-paved road with an extended 

gravel portion that would need to be paved and maintained over time.

Census Tract 210 is considered to be in an environmental justice low-income area, based on the 

environmental justice analysis described in Section 3.8.1.4. Census Tract 210 within the Study Area 

contains 52 residences. The nearest residence is located approximately 230 feet west of the Eastern 

Transmission Route on 42nd Avenue East. The nearest residence to the Western Transmission Route in 

Census Tract 210 is nearly 300 feet east of the route on East 18th Street. Both portions of transmission 

line alternatives in this area are within an existing transmission line corridor. The ROW is surrounded by 

trees in this area, which provide a partial visual buffer. The minimal impacts within Census Tract 210 do 

not constitute disproportionately high and adverse impacts to this environmental justice area.

The Project would not directly impact any residences, public facilities, farming structures, cemeteries, 

religious facilities, or other structures. Temporary disruptions to normal traffic may occur during 

construction as equipment and employees commute to and from the Project. The frequency of the daily 

workforce automobile traffic would follow the Project workforce numbers onsite at a given time. The 

daily automobile traffic to the site would increase from approximately 25 to 50 vehicles in the initial 

stages of construction to approximately 200 to 260 vehicles for peak months (April through December 

2023). The traffic would begin to decrease until it reaches approximately 25 vehicles near construction

completion.

Regional economic benefits are estimated at around one billion dollars over 20 years. The facility owners 

are both active in their other host communities and intend to continue that commitment to the City of 

Superior and Douglas County. For example, the Owners have co-sponsored a bike sharing program in the 

City for the next two years. The Project is in discussions with local partners to create a trail near the 

facility and to upgrade the canoe launch near the facility.
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3.8.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to socioeconomics or 

environmental justice communities at or in the vicinity of the Study Area because no construction would 

occur.

3.8.3 Mitigation Measures

Construction activities will primarily be scheduled between the hours of 7:00 a.m. and 10:00 p.m. to 

minimize noise impacts to nearby residences. The Owners will provide notice to nearby residents of 

expected timeframes for steam blow operation.

The Owners do not anticipate permanent damage to roads. As a precautionary measure, the Owners will 

video-document the condition of all roads on the construction vehicle routes to document the road 

condition prior to the start of construction. Any documented adverse impacts to the roads incurred due to

the construction of the Project will be addressed through consultation with applicable road authorities 

regarding the Owners’ responsibility for repairing the adversely impacted roads. 

The Owners will coordinate the proper construction signage on the roads used by construction vehicles 

for the Project to make drivers aware of the increased hazards associated with the construction vehicle(s) 

presence.

Contractors will be chosen from a competitive bid process and will be local whenever practical. Local 

materials such as concrete, lumber, and general hardware may be purchased from local businesses.

3.9 Visual Resources

The following section provide information related to existing visual resources near the Project.

3.9.1 Affected Environment

The Study Area is primarily undeveloped wooded wetland areas with some areas of industrial and

residential development, both denser subdivision and scattered rural in nature. The Nemadji River Site is 

surrounding by the Husky Superior Oil Refinery on the north and west sides, the Nemadji River on the 

south side, and a cemetery on the east. The site is buffered from the cemetery by approximately 130 feet 

of trees. The topography is relatively flat with riparian areas near the river. The Hill Avenue Site is within 

undeveloped scrub/shrub and is relatively flat, sloping slightly to the northeast.

The closest scenic byway to either Site is the Skyline Parkway Scenic Byway, a Minnesota State Byway 

located along West Skyline Parkway in Duluth, Minnesota, outside the Study Area. Veterans Evergreen 
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Memorial Drive, along Highway 23, is the only scenic byway in Douglas County, Wisconsin. It is a 

Minnesota State Scenic Byway that crosses approximately 0.5 mile of Douglas County, also outside the 

Study Area.

The switching station sites are situated in undeveloped wooded areas. The Superior Switching Station is 

bounded to the south by an existing 69-kV transmission line and 42nd Avenue East. All other sides of the 

site are surrounded by forested lands and shrubland habitats. The Parkland Switching Station location is 

bounded by County Road Z to the north, South Lyman Lake Road to the east, woodland to the west, and 

woodland/existing transmission corridor to the south. Man-made features in the area include existing 

roads, buildings, homes, railroads, utilities, and communication towers.

A significant portion of the transmission line routes would be located parallel to or double circuit with 

existing transmission infrastructure or located near other existing linear infrastructure. The majority of its 

length extends through undeveloped wooded areas. No designated scenic overlooks or vantage points 

were identified in the Study Area.

3.9.2 Environmental Consequences

The following sections provide potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to visual resources.

3.9.2.1 Proposed Action Alternatives

The aesthetics of the surrounding area would be altered by the Project. Vegetation would need to be 

cleared permanently for the Project Site, transmission line ROW, and switching station site. Light 

emissions at the Project Site would increase compared to current levels of light emissions as a result of 

facility lighting. The lighting regime near the Nemadji River Site is currently influenced by lighting at the 

existing oil and gas facilities located immediately adjacent to the site property, although no light emitting 

sources currently occur on the site itself. The Hill Avenue Site also has no light emitting sources currently 

onsite.

The Project site would require exterior lighting for safety and security. Lights would be required in 

parking areas, on service roads around the facility, at pedestrian entrances to various buildings, and along 

walkways on the property. Plant service roads, parking areas, and walkways would be illuminated with 

roadway lighting fixtures on poles. The trees on the eastern boundary of the Nemadji River Site would 

provide a buffer and help mitigate additional lighting impacts. Wooded areas located offsite of the Hill 

Avenue Site would provide a buffer to help mitigate light impacts to surrounding development. Building 

entrances would be illuminated with fixtures mounted directly above doors. Outdoor light fixtures would 
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be fully shielded and directed downward to minimize light visible from adjacent properties and to reduce 

glare in the area. Any floodlights required for the operation of the Project would be directed inward 

towards the facility and would have top and side shields. 

The dominant visual features of the Project would be a stack and finned heat exchanger. The finned heat 

exchanger would be somewhat larger than the other facility equipment at the Project Site. A simulation of 

the facility is provided in Figure 3-4. The tallest features of the site would be the stack, which would be 

approximately 194 feet above ground level at the Nemadji River Site or 171 feet above ground level at the 

Hill Avenue Site. The proposed transmission line structures would predominately range in height from 

120 feet to 160 feet above grade based on similar structure designs used for other projects. The proposed 

structures would likely be steel self-supporting structures on concrete foundations. The stack and 

transmission line, and potentially the finned heat exchanger, would be visible from multiple viewpoints 

throughout the area; most of the transmission line route is within undeveloped forested areas along 

existing utilities, however, as well as within existing transmission line corridors. The Nemadji River Site 

is located adjacent to existing industrial areas. The Hill Avenue Site is undeveloped lowland scrub/shrub 

surrounded by wooded areas and Hill Avenue on the west side. The transmission line routes parallel 

existing linear infrastructure for the majority of its length. The switching station sites are surrounded by 

undeveloped forested and shrubland habitats. None of the Project facilities are out of character with 

features already present across the visual landscape and the Project does not generally introduce new 

visual elements into the viewshed, keeping new facilities in proximity to already developed locations. 

Due to these factors and the distance from these scenic byways, it is anticipated that the Project would not 

significantly impact visual resources in the area.

3.9.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts to visual resources at or in the 

vicinity of the Study Area because no construction would occur.

3.9.3 Mitigation Measures

Building entrances will be illuminated with fixtures mounted directly above doors. Outdoor light fixtures 

will be fully shielded and directed downward to minimize light visible from adjacent properties and to 

reduce glare in the area. Any floodlights required for the operation of the Project will be directed inward 

towards the facility and will have top and side shields.
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Figure 3-4: Nemadji Trail Energy Center Simulation

*View from residential area east of Plant

Cleared ROW would be revegetated as soon as practicable as described in Section 3.2.3.5. Existing 

vegetation outside the plant footprint, ROW, switching station areas, and laydown yards will be left intact 

to reduce visibility of the Project and provide screening. During construction, work areas would be 

maintained in an orderly manner and trash and construction debris removed to help avoid unsightly areas. 

All disturbed areas would be restored as soon as practicable. Disturbance would be limited to those areas 

necessary for construction, limiting clearing and ground disturbance. 

3.10 Water Resources

The following sections provide information related to water resources in the Study Area. 

3.10.1 Affected Environment

The Project is located within the St. Louis River Watershed and Lower Nemadji River - Frontal Lake 

Superior Watershed of the St. Louis SubBasin and Beartrap - Nemadji SubBasin in the Great Lakes
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Region. Waterways in the area include the Nemadji River (which is adjacent to the south side of the 

Nemadji River Site), Bear Creek, Bluff Creek, Newton Creek, and various unnamed streams. Several 

small ponds are located throughout the area as well.

3.10.1.1 Surface Water

Surface water features were identified using the National Hydrography Dataset (NHD). The NHD 

represents the surface water drainage network of the United States, providing georeferenced locations for 

features such as rivers, streams, canals, lakes, and ponds. Waterbodies in the area include Lake Superior, 

the Nemadji River, Bear Creek, Bluff Creek, Newton Creek, and various unnamed streams. Several small 

ponds are located throughout the area as well. The City of Superior obtains its water supply from Lake 

Superior. 

Based on interpretation of Wisconsin Statutes, Chapter 30 “Navigable Waters, Harbors, and Navigation”, 

waterway WW-019f (Nemadji River) is classified as being a Navigable Water of the State. WW-019f is 

also listed a navigable water of the United States under USACE jurisdiction. Additionally, the WDNR 

made an in-person determination on August 2, 2018 that the lower majority of WW-501f is considered 

navigable under Wisconsin Statutes, Chapter 30 “Navigable Waters, Harbors, and Navigation”. However, 

WW-501f is not considered to be a navigable water of the United States under USACE jurisdiction. No 

other waterways, wetlands, or waters within or near the Project are considered as navigable waters.

3.10.1.1.1 Water Quality

The Nemadji River is a 303d listed impaired river (WDNR, 2019b). The Nemadji River flows north and 

empties into Superior Bay. The impairment of the Nemadji River is degraded habitat due to erosion. The 

main pollutant of the Nemadji River is sediment/total suspended solids from severe natural and humaninduced erosion, which is carried into Superior Bay (WDNR, 2019b). The Duluth-Superior Harbor is 

dredged periodically to maintain channels for ship traffic. The Nemadji River contributes 23,000 tons of 

silt and clay, and 14,000 tons of sand to Superior Bay on average every year (WDNR, 2019b). 

Bear Creek is a 303d listed impaired stream. It is a small, partially intermittent stream that flows into 

Allouez Bay. It has variable and seasonal flows. The condition of Bear Creek is poor and its impairment 

is unknown (WDNR, 2019b). The main pollutant of Bear Creek is total phosphorus. 

Bluff Creek is a 303d listed impaired stream. Its condition is poor and its impairment is unknown 

(WDNR, 2019b). The main pollutant of Bluff Creek is total phosphorus. Bluff Creek flows into Allouez 

Bay on the southeast side of the City of Superior. 
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Newton Creek is a 303d listed impaired stream in poor condition with limited aquatic life (WDNR, 

2019b). Newton Creek drains a large wetland area west of Murphy Oil refinery, which discharges into the 

creek. Newton Creek flows north and empties into Hog Island Inlet, which then empties into Superior 

Bay. Impairments include chronic aquatic toxicity and degraded biological community. Pollutants in 

Newton Creek include foam/flocs/scum/oil slicks, polycyclic aromatic hydrocarbons (PAHs), unspecified 

metals, and other unknown pollutants (WDNR, 2019b). 

3.10.1.1.2 Exceptional or Outstanding Resource Waters

The only Exceptional or Outstanding Resource Waters within 10 miles of the Project Sites are the Red 

River (Exceptional) and the Amnicon River (Outstanding). A small area of Lake Superior at the mouth of 

the Amnicon River is also considered an exceptional water. The Red River is approximately 9.3 miles 

from the Nemadji River Site and approximately 8.6 miles from the Hill Avenue Site. The Amnicon River 

is approximately 7.3 miles from the Nemadji River Site and approximately 8.7 miles from the Hill 

Avenue Site. Neither are crossed by the transmission line alternatives.

3.10.1.1.3 Trout Streams

The following trout streams are located within 10 miles of the Project Sites:

• Balsam Creek

• Black River

• Copper Creek

• Little Amnicon River

• Red River

• Rock Creek

• Silver Creek

The nearest trout stream to the Project is the Black River, located over 5 miles south-southwest of the 

Project. It is not crossed by the transmission line alternatives.

3.10.1.1.4 Wild or Scenic Rivers

The only wild or scenic river in Douglas County is the St. Croix River, located approximately 25 miles 

south of the Project (Appendix E). There are no other state or federally designated wild or scenic rivers in 

Douglas county. 
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3.10.1.2 Groundwater

The regional aquifer near Superior consists of a thick unit of glacial deposits that are comprised of clay, 

silt, sand, and gravel. These glacial deposits directly overlie Precambrian age sandstone bedrock. The 

bedrock units in Douglas County are not considered groundwater aquifers due to their low yield and 

mineralized water quality. The thickness of the glacial materials is variable through the County and 

generally increases towards Lake Superior, with a maximum thickness of over 600 feet near the St. Louis 

River (Weidman and Schultz, 1913). At the Nemadji River Site, the maximum thickness of the glacial 

deposits is approximately 280 feet. The aquifer underlaying the site and proposed to provide water for the 

Project is the Copper Falls Formation, characterized by sandy glacial till.

Two municipal water users are located near the Nemadji River Site: the City of Superior, and the Village 

of Oliver. The City of Superior obtains its water supply from a surface water source (Lake Superior). The 

Village of Oliver is located 7.3 miles west of the Nemadji River Site and uses groundwater as its water 

supply. The WDNR online mapping tool, the Water Withdrawal and High Capacity Well Viewer, was 

used to conduct research on high capacity groundwater users that are located within a 10-mile radius of 

the Nemadji River Site. Four high capacity permitted groundwater users were shown as existing within 

the search radius. The nearest high capacity groundwater user is located over 3 miles west of the Nemadji 

River Site. The nearest high capacity municipal groundwater user is the Village of Oliver. The permitted 

capacities, distances from the Nemadji River Site, and type of water use are listed in Table 3-33.

Table 3-33: High Capacity Groundwater Users near the Nemadji River Site

User Name Use Type Approved Maximum 

Withdrawal (gpd)a

Distance from 

Site (miles)

Precision Foods Inc. Industrial 500,000 3.0

Wisconsin Central Railway Industrial 48,000 5.1

Wisconsin Central Railway Industrial 48,000 6.0

Village of Oliver Municipal 80,000 7.3

Source: WDNR Wisconsin Water Quality Data View

(a) gallons per day

3.10.1.3 Floodplains

FIRMs have been prepared for Douglas County, Wisconsin (Appendix F). Near the Study Area, 100-year 

floodplain occurs along the Nemadji River, Bluff Creek, and Bear Creek. A portion of the Nemadji River 

Site is located within the 100-year floodplain due to its proximity to the Nemadji River. Other smaller 

streams are located near the Project but there are no identified 100-year floodplains associated with these 
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smaller streams. Nearby Superior Bay and Allouez Bay have associated 100-year floodplains (Figure 

2-13). Small areas of 500-year floodplain existing along the Nemadji River, Bluff Creek, and Bear Creek 

in the Study Area (Figure 2-13). Appendix G shows water features, including floodplains, within the 

Project study area.

3.10.1.4 Wetlands/Riparian Areas 

The Study Area is predominantly wetland (Figure 2-8 and Figure 2-13; Appendix G). Wetland types 

include emergent/wet meadow; emergent/wet meadow, open water; filled/drained wetland, forested, 

emergent/wet meadow; filled/drained wetland, forested, scrub/shrub; filled/drained wetland, Scrub/shrub; 

forested; forested, emergent/wet meadow; forested, open water; forested, scrub/shrub; open water; 

scrub/shrub; scrub/shrub, emergent/wet meadow; and upland. 

A field wetland delineation was conducted in September 2016 and October 2017 for the Project, including 

site and line alternatives and associated facilities. Data forms and photographs for these identified features 

were surveyed using a sub-meter-accurate GPS unit. Some areas were inaccessible due to lack of survey 

permission. In these inaccessible areas, a desktop delineation was completed to identify where wetlands 

and waterways are likely to occur. The methodology for the desktop delineation consisted of reviewing 

several baseline datasets including, but not limited to recent high-resolution aerial imagery, USFWS 

National Wetland Inventory (NWI) data, Wisconsin Wetland Inventory (WWI) data, NRCS SSURGO 

hydric soils, LiDAR contours, and USGS topographic maps. The desktop delineation was conducted 

following the field delineation in order to further evaluate wetlands and waterways based on known 

adjacent field verified boundaries. Following the field and desktop delineation, approximately 120 

wetlands and 25 waterways were identified within the Wetland Survey Area (Appendix G).

In addition to the NWI designated wetlands and field delineated wetlands, the State of Wisconsin has 

programs for identification and designation of special wetlands. Wisconsin Chapter NR 103.04 defines 

unique and significant wetlands as “identified in special area management plans (SAMP), special wetland 

inventory studies (SWIS), advanced delineation and identification studies (ADID) and areas designated 

by the U.S. EPA under section 404 (c), 33 USC 1344 (c)”. The City of Superior has a SAMP for specific 

unique and significant wetlands within their jurisdictional boundary. However, none of the City of 

Superior SAMP wetlands occur within the Nemadji River Site. Additionally, no other State special 

wetland designations as outlined in Wisconsin Chapter NR 103.04 are applicable for wetlands within the

Nemadji River Site. As a result, none of the wetlands within the Nemadji River Site are considered to be 

significant. One state designated SAMP wetland (W-117d) is within the Eastern Transmission Route 

Wetland Survey Area. W-117d is a detention pond associated with a rail yard and would be spanned 
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entirely. No other State special wetland designations as outlined in Wisconsin Chapter NR 103.04 are 

applicable for wetlands within the Study Area. 

Based on interpretation of Wisconsin Statutes, Chapter 30 “Navigable Waters, Harbors, and Navigation”, 

the Nemadji River (waterway WW-019f) is classified as being a Navigable Water of the State. The 

Nemadji River is also listed a navigable water of the United States under USACE jurisdiction. No other 

waterways, wetlands, or waters within or near the Project are considered as navigable waters. 

3.10.1.5 Wastewater

The Project would produce wastewater. All wastewater, microfiltration and ultrafiltration (MF/UF)

backwash, and RO reject water would be piped offsite to the City’s wastewater system. Tie-ins to the City 

sewer would be constructed. No additional treatment is expected to be necessary to meet the City’s 

discharge quality limitations. HRSG blowdown would discharge to the City sewer system. 

The discharge of wastewater to the City of Superior’s sewer system from the Nemadji River Site would 

require installation of sewer pipeline from the northern boundary of the site to a tie-in location northeast 

of the site along 31st Avenue East. The primary tie-in location would be the East 2nd Interceptor, while 

the alternate tie-in location would be Manhole 040176. The Hill Avenue Site would also require an 

extension of the City’s sewer pipeline system from the central portion of the site to the tie-in location at 

Manhole 050314, located northwest of the site along Hill Avenue. 

Sanitary wastewater from bathrooms, showers, and other employee areas would be collected and routed to 

a lift station, which would also discharge to the municipal sewer system for offsite treatment. Drains for 

areas around equipment that could be contaminated with oil would be gravity drained and directed 

through an oil/water separator prior to discharge to the municipal sewer system. No additional treatment 

is expected to be necessary to meet the City of Superior’s discharge quality limitations. Based on 

preliminary plant design, it is anticipated that the City of Superior has the capacity to treat wastewater 

from the Project.

3.10.1.6 Stormwater

In the State of Wisconsin, projects that would disturb one or more acres of land must obtain coverage 

under the WPDES General Permit No. WI-S067831-5 (WPDES General Permit), which authorizes the 

discharge of storm water associated with land-disturbing construction activities into State waters. 

Coverage under the WPDES General Permit is obtained by developing Erosion Control and Storm Water 
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Management Plans and submitting a Water Resources Application for Project Permits (WRAPP)13 to the 

WDNR for approval prior to the start of Project construction. 

Land-disturbing construction activities within the boundaries and jurisdiction of the City of Superior, 

Wisconsin must obtain an Erosion Control/Grading Permit and Storm Water Management Permit from 

the Public Works Department. The application requirements include the permit application forms, an 

Erosion & Sediment Control Plan, Storm Water Management Plan, and the required fees. 

The Nemadji River Site has an existing stormwater pond that discharges via an underground pipe to the 

Nemadji River. It would be expanded to attenuate the increase in non-contaminated stormwater runoff 

volume from Project construction. A new storm water detention pond is proposed for the Hill Avenue Site 

and would be constructed in the northeast corner of the site. Storm water would be pumped from the pond 

and would drain at existing surface grade to the east/northeast to a stream that discharges to Superior Bay. 

Drains for areas around equipment that could be contaminated with oil would be gravity drained and 

directed through an oil/water separator prior to discharge to the municipal sewer system. 

3.10.2 Environmental Consequences

The following sections provide potential environmental consequences of the proposed Action 

Alternatives and No Action Alternative related to water resources.

3.10.2.1 Proposed Action Alternatives

The following sections provide potential environmental consequences of the proposed Action 

Alternatives related to water resources.

3.10.2.1.1 Surface Water

Table 3-34 and Table 3-35 provide the types and length of each waterway delineated at each Site and 

within 0.5 mile of its boundary (see Appendix G for maps of surface waters, wetlands, and floodplains

near the Project).

Table 3-34: Waterways Identified Within 0.5 Mile of Nemadji River Site (Total Length - 3,246 feet)

Waterway IDa Name Within Project Site or 

Within 0.5mile

Flow 

Regime

Centerline 

Length in Site 

Limits (feet)

WW-018f UNT to Nemadji River Within 0.5 Mile Ephemeral 221

WW-019f Nemadji River Within Project Site Perennial 953

13 A WRAPP is also referred to as a Notice of Intent. 
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Waterway IDa Name Within Project Site or 

Within 0.5mile

Flow 

Regime

Centerline 

Length in Site 

Limits (feet)

WW-022d Newton Creek Within 0.5 Mile Intermittent 1,397

WW-501f UNT to Nemadji River Within Project Site Ephemeral 675

(a) A waterway ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) Centerline length is based on an average length down the center of the waterway that 

intersects within the site boundary.

Table 3-35: Waterways Identified Within 0.5 Mile of Hill Avenue Site (Total Length - 3,025 feet)

Waterway IDa Name Within Project Site or 

Within One-half mile

Flow 

Regime

Centerline 

Length in Site 

Limits (feet)

b

WW-019f Nemadji River Within 0.5 Mile Perennial 953

WW-022d Newton Creek Within Project SitecIntermittent 1,397

WW-501f UNT to Nemadji River Within 0.5 Mile Ephemeral 675

(a) A waterway ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) Centerline length is based on an average length down the center of the waterway that 

intersects within the site boundary.

(c) WW-022d is within the water supply line area, approximately 0.6 miles southeast of the Hill 

Avenue Site boundary.

Nine waterways (totaling 1,686 centerline linear feet) were delineated within the Eastern Transmission 

Route Wetland Survey Area. Seven waterways (totaling 1,883 centerline linear feet) were delineated 

within the Western Transmission Route Wetland Survey Area. Two waterways (totaling 407 centerline 

linear feet) were delineated within the Hill Avenue Site Route Wetland Survey Area. Table 3-36, Table 

3-37, and Table 3-38 provide the types and length of each delineated waterway.

Table 3-36: Waterways Identified Within the Eastern Transmission Route Wetland Survey Area

(Total Length - 1,686 feet)

Waterway IDa Name Flow Regime Centerline Length in 

Wetland Survey Area (feet)b

WW-007f UNT to Bear Creek Intermittent 151

WW-008f Bear Creek Perennial 246

WW-009f Bear Creek Perennial 169

WW-010f UNT to Bluff Creek Ephemeral 180

WW-011f UNT to Bluff Creek Intermittent 162

WW-012f UNT to Bluff Creek Intermittent 194
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Waterway IDa Name Flow Regime Centerline Length in 

Wetland Survey Area (feet)b

WW-014f Bluff Creek Perennial 155

WW-015f UNT to Nemadji River Intermittent 246

WW-019f Nemadji River Perennial 183

(a) A waterway ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) Centerline length is based on an average length down the center of the waterway that 

intersects within the Wetland Survey Area.

Table 3-37: Waterways Identified Within the Western Transmission Route Wetland Survey Area

(Total Length - 1,883 feet)

Waterway

IDa Name Project Component Association

Flow 

Regime

Centerline 

Length in 

Wetland Survey 

Area (feet)

b

WW-015f UNT to Nemadji River

Shared Eastern and 

Western Transmission 

Route

Intermittent 1061

WW-016f UNT to Nemadji River Western Transmission 

Route Only Ephemeral 174

WW-017f UNT to Nemadji River Western Transmission 

Route Only Ephemeral 30

WW-018f UNT to Nemadji River Western Transmission 

Route Only Ephemeral 46

WW-019f Nemadji River

Shared Eastern and 

Western Transmission 

Route

Perennial 178

WW-020f UNT to Nemadji River Western Transmission 

Route Only Intermittent 226

WW-021d Bluff Creek Western Transmission 

Route Only Perennial 168

(a) A waterway ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) Centerline length is based on an average length down the center of the waterway that 

intersects within the Wetland Survey Area.

Table 3-38: Waterways Identified Within the Hill Avenue Site Route Wetland Survey Area (Total 

Length - 407 feet)

Waterway IDa Name Flow Regime Centerline Length in Wetland Survey 

Area (feet)

b

WW-019f Nemadji River Perennial 257
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Waterway IDa Name Flow Regime Centerline Length in Wetland Survey 

Area (feet)

b

WW-022d Newton Creek Perennial 150

(a) A waterway ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) Centerline length is based on an average length down the center of the waterway that 

intersects within the Wetland Survey Area.

Table 3-39 provides the waterways that are proposed to be crossed by the transmission line routes. 

Table 3-39: Waterways Proposed to Be Crossed for Construction 

Waterway IDa Name

Route Alternative

Crossing Methodb

WW-007f UNT to Bear Creek Eastern Transmission 

Route

Temporary Prefabricated Span 

Bridge

WW-011f UNT to Bluff Creek Eastern Transmission 

Route

Temporary Prefabricated Span 

Bridge

WW-012f UNT to Bluff Creek Eastern Transmission 

Route

Temporary Prefabricated Span 

Bridge

WW-015f UNT to Nemadji 

River

Eastern and Western

Transmission Route

Temporary Prefabricated Span 

Bridge

WW-016f UNT to Nemadji 

River

Western Transmission 

Route

Temporary Prefabricated Span 

Bridge

WW-017f UNT to Nemadji 

River

Western Transmission 

Route

Temporary Prefabricated Span 

Bridge

WW-018f UNT to Nemadji 

River

Western Transmission 

Route

Temporary Prefabricated Span 

Bridge

WW-020f UNT to Nemadji 

River

Western Transmission 

Route

Temporary Prefabricated Span 

Bridge

WW-021d Bluff Creek Western Transmission 

Route Temporary Span Bridge

(a) A waterway ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) Temporary spans would avoid disturbance below the ordinary high-water mark (OHWM) 

via supported prefabricated span bridge across each bank. A permanent span bridge would

avoid placement of any structures within and below the OHWM and would not result in a 

floodplain water rise.

A temporary span bridge would be needed at WW-021d to allow for construction access within the 

Western Transmission Line ROW. Based on discussions with the WDNR, it is understood that temporary 

culvert and fill would not be allowable based on the waterway size and potential public use for recreation. 
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Rural Utilities Service 3-90 Dairyland Power Cooperative

All other waterway crossings would be temporary in nature and utilize prefabricated span bridges placed 

above the OHWM.

Considering the distance of the Project from Outstanding or Exceptional Resource Waters; trout streams; 

and wild and scenic rivers, and with the implementation of mitigation measures described in Section 

3.10.3, it is anticipated that construction and operation of the Project would not result in impacts to these 

features.

3.10.2.1.2 Groundwater

No groundwater would be used for the Project. There would be no impacts to groundwater. 

3.10.2.1.3 Floodplains

The Nemadji River Site is located adjacent to the Nemadji River floodplain and a small portion of the 

property boundary extends into the 100-year and 500-year floodplain (see Appendix G for maps of 

floodplain near the Project). All equipment for the facility is located outside the 100-year and 500-year 

floodplain, however. The Hill Avenue Site, Superior Switching Station, Parkland Switching Station, and 

all laydown yards are not within 100-year floodplain. The Eastern and Western Transmission Routes 

would require crossing floodplain associated with the Nemadji River, Bear Creek, and Bluff Creek by the 

transmission line. The macro-corridors contain both 100-year and 500-year floodplain. All rivers would 

be spanned by the transmission line. Two transmission line structures would need to be placed within the 

Nemadji River floodplain due to the floodplain width. 

3.10.2.1.4 Wetlands/Riparian Areas

A total of six wetlands (7.4 acres) were delineated14 within the Nemadji River Site (see Appendix G for 

maps of wetlands near the Project). One wetland (totaling 75.6 acres) was delineated within the Hill 

Avenue Site. According to the Wetland Rapid Assessment Methodology (WRAM) assessment15 provided

in the wetland delineation report, the wetlands at the Sites have low-to-medium functional values because 

they are dominated by invasive wetland plant species, have a low vegetative diversity, are degraded due 

to adjacent existing roads and industrial facilities, and no threatened, endangered or species of concern

14 The wetland delineation for the Project is available on the PSCW website at: 

http://apps.psc.wi.gov/vs2015/ERF_search/content/searchResult.aspx?UTIL=9698&CASE=CE&SEQ=100&STAR

T=none&END=none&TYPE=none&SERVICE=none&KEY=none&NON=N. PSC Reference Numbers 357006, 

357007, 357008, 357009, 357229, 357228, 357227, 357230, 357231, 357232, 357234, 357235, 357236, 357237, 

357238, 357239, 357240, 357026, and 357241.

15 The WRAM assessments for the Project components are included in the wetland delineation report.
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were observed. Table 3-40 and Table 3-41 provides the types and size of each wetland delineated at each

Site.

Table 3-40: Wetlands Identified at Nemadji River Site (Total Area - 7.4 acres)

Wetland IDa

Wetland 

Classification

Cowardinb

Wetland 

Classification

WWIc

Area in Site Limits (acres)

W-501f PFO T3Kr 3.192

W-502f PSS S3Kr 2.133

W-503f PEM E1Kr 1.291

W-504f PEM E1Kr 0.074

W-505f PUB W0Hx 0.385

W-517f PFO T3Kr 0.289

(a) A wetland ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) PEM = palustrine emergent, PSS = palustrine shrub/scrub, and PUB = palustrine 

unconsolidated bottom. Source: Based on Cowardin, L. M., V. Carter, F.C. Golet, and E.T. 

LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. 

FWS/OBS-79/31. U.S. Fish and Wildlife Service, Washington, D.C.

(c) E1Kr = emergent/wet meadow, persistent, wet soil, palustrine, red clay complex; S3Kr = 

shrub/scrub, broad-leaved deciduous, wet soil, palustrine, red clay complex; W0Hx = open 

water, subclass unknown, standing water, palustrine, excavated. Source: Wisconsin Wetland 

Inventory Classification Guide 

(http://dnr.wi.gov/topic/wetlands/documents/WWI_Classification.pdf)

Table 3-41: Wetlands Identified at Hill Avenue Site (Total Area - 75.591 acres)

Wetland IDa

Wetland 

Classification

Cowardinb

Wetland 

Classification

WWIc

Area in Site Limits (acres)

W-513f PSS S3Kr 75.591

(a) A wetland ID ending in “d” indicates it was delineated via desktop evaluation, while “f” 

indicates it was field delineated.

(b) PSS = palustrine shrub/scrub, Source: Based on Cowardin, L. M., V. Carter, F.C. Golet, and 

E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. 

FWS/OBS-79/31. U.S. Fish and Wildlife Service, Washington, D.C.

(c) S3Kr = shrub/scrub, broad-leaved deciduous. Source: Wisconsin Wetland Inventory 

Classification Guide (http://dnr.wi.gov/topic/wetlands/documents/WWI_Classification.pdf)

For the Nemadji River Site, approximately 3.47 acres of wetlands would be permanently impacted (1.32 

acres of PEM wetlands, 0.33 acre of PFO wetlands, and 1.82 acres of PSS wetlands) from placement of 

facility components. One existing detention basin would be relocated and expanded. Additionally, the 

Nemadji River Site’s staging area would temporarily impact approximately 14.82 acres of wetlands (4.54 

acres of PEM wetlands and 10.28 acres of PFO wetlands). As a result of the temporary staging area 

impacts, approximately 10.3 acres of PFO wetlands would be converted to PEM wetlands. 
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Rural Utilities Service 3-92 Dairyland Power Cooperative

For the Hill Avenue Site, approximately 27.65 acres of PSS wetlands would be permanently impacted 

from placement of facility components. Additionally, the Hill Avenue Site’s staging area would 

temporarily impact approximately 23.91 acres of PSS wetlands. As a result of the temporary staging area 

impacts, approximately 23.91 acres of PSS wetlands would be converted to PEM wetlands. 

A total of 30 wetlands (49.5 acres) were delineated within the Eastern Transmission Line Wetland Survey

Area. A total of 42 wetlands (totaling 86.4 acres) were delineated within the Western Transmission Route 

Wetland Survey Area. A total of 16 wetlands (totaling 18.7 acres) were delineated within the Hill Avenue

Site Route Wetland Survey Area. According to the WRAM assessment provided in the wetland 

delineation report, the wetlands in the Wetland Survey Area have low-to-medium functional values 

because they are dominated by invasive wetland plant species, have a low vegetative diversity, are likely 

degraded due to presence within and adjacent to utility and road easements, and no threatened, 

endangered or species of concern were observed (SSE, Dairyland, Burns & McDonnell, 2019b). Table 

3-42, Table 3-43, and Table 3-44 provide the types and size of each wetland delineated for each route in 

the Wetland Survey Area.

Table 3-42: Wetlands Identified Within the Eastern Transmission Route Wetland Survey Area (Total 

Area - 49.51 acres)

Wetland 

IDa Project Component Association

Wetland 

Classification

Cowardinb

Wetland 

Classification

WWIc

Acreage in 

Wetland 

Survey Area 

W-023f Eastern Transmission Route Only PEM E1Kr 1.20

W-024f Eastern Transmission Route Only PFO T3Kr 0.13

W-030f Eastern Transmission Route Only PEM E1Kr 2.43

W-031f Eastern Transmission Route Only PSS S3Kr 0.29

W-032f Eastern Transmission Route Only PSS S3Kr 0.03

W-035f Eastern Transmission Route Only PEM E1Kr 0.09

W-037f Eastern Transmission Route Only PEM/PSS E1Kr/S3Kr 2.64

W-038d Eastern Transmission Route Only PFO T3Kr 2.43

W-040f Eastern Transmission Route Only PEM E1Kr 1.49

W-041f Eastern Transmission Route Only PEM E1Kr 3.43

W-045f Eastern Transmission Route Only PEM E1Kr 6.40

W-047f Eastern Transmission Route Only PFO T3Kr 0.01

W-049f Eastern Transmission Route Only PEM E1Kr 0.43

W-051f Eastern Transmission Route Only PEM E1Kr 0.66

W-053d Eastern Transmission Route Only PFO T3Kr 0.05
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Wetland 

IDa Project Component Association

Wetland 

Classification

Cowardinb

Wetland 

Classification

WWIc

Acreage in 

Wetland 

Survey Area 

W-054f Eastern Transmission Route Only PEM/PSS E1Kr/S3Kr 0.85

W-055fd Eastern Transmission Route Only PEM/PSS E1Kr/S3Kr 5.28

W-055fd Shared Eastern and Western

Transmission Routes

PEM/PSS E1Kr/S3Kr 1.35

W-057fd Eastern Transmission Route Only PFO T3Kr 0.32

W-057fd Shared Eastern and Western

Transmission Routes

PFO T3Kr 0.06

W-061fd Eastern Transmission Route Only PEM E1Kr 0.40

W-061fd Shared Eastern and Western

Transmission Routes

PEM E1Kr 1.05

W-062fd Eastern Transmission Route Only PFO T3Kr 1.83

W-062fd Shared Eastern and Western

Transmission Routes

PFO T3Kr 0.04

W-064fd Eastern Transmission Route Only PEM E1Kr 0.02

W-064fd Shared Eastern and Western

Transmission Routes

PEM E1Kr 0.04

W-081fd Eastern Transmission Route Only PSS S3Kr 3.14

W-081fd Shared Eastern and Western

Transmission Routes

PSS S3Kr 0.68

W-084fd Eastern Transmission Route Only PFO T3Kr 8.77

W-084fd Shared Eastern and Western

Transmission Routes

PFO T3Kr 0.74

W-117d Eastern Transmission Route Only PUB W0Hx 1.01

W-119d Eastern Transmission Route Only PEM E1Kr 0.01

W-120d Eastern Transmission Route Only PEM E1Kr 0.27

W-121d Eastern Transmission Route Only PEM E1Kr 0.22

W-501fd Eastern Transmission Route Only PFO T3Kr 0.15

W-501fd Shared Eastern and Western 

Transmission Routes

PFO T3Kr 0.58

W-514d Shared Eastern and Western 

Transmission Routes

PFO T3Kr 0.44

W-515d Shared Eastern and Western 

Transmission Routes

PEM E1Kr 0.55

(a) A wetland ID ending in “d” indicates it was delineated via desktop evaluation, while “f” indicates it 

was field delineated.

(b) PEM = palustrine emergent, PSS = palustrine shrub/scrub, and PUB = palustrine unconsolidated 

bottom, PFO = palustrine forested wetland. Source: Based on Cowardin, L. M., V. Carter, F.C. Golet, 

and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. 

FWS/OBS-79/31. U.S. Fish and Wildlife Service, Washington, D.C.
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Rural Utilities Service 3-94 Dairyland Power Cooperative

(c) E1Kr = emergent/wet meadow, persistent, wet soil, palustrine, red clay complex; S3Kr = shrub/scrub, 

broad-leaved deciduous, wet soil, palustrine, red clay complex; T3Kr = forested, broad-leaved 

deciduous, wet soil, palustrine, red clay complex; W0Hx = open water, subclass unknown, standing 

water, palustrine, excavated. Source: Wisconsin Wetland Inventory Classification Guide 

(http://dnr.wi.gov/topic/wetlands/documents/WWI_Classification.pdf)

(d) W-055f, W-057f, W-061f, W-062f, W-064f, W-081f, W-084f, and W-501f have portions that exist in 

both the Eastern Transmission Route only and shared Eastern and Western Transmission Routes and 

are broken up for the purposes of denoting the different acres within each project component.

Table 3-43: Wetlands Identified Within the Western Transmission Route Wetland Survey Area

(Total Area - 86.43 acres)

Wetland 

IDa Project Component Association

Wetland 

Classification

Cowardinb

Wetland 

Classification

WWIc

Acreage

in 

Wetland 

Survey 

Area

W-055fd Western Transmission Route Only PEM/PSS E1Kr/S3Kr 3.62

W-055fd Shared Eastern and Western Transmission 

Routes

PEM/PSS E1Kr/S3Kr 1.35

W-057fd Western Transmission Route Only PFO T3Kr 1.47

W-057fd Shared Eastern and Western Transmission 

Routes

PFO T3Kr 0.06

W-058f Western Transmission Route Only PFO T3Kr 0.06

W-059f Western Transmission Route Only PFO T3Kr 1.87

W-061fd Western Transmission Route Only PEM E1Kr 2.21

W-061fd Shared Eastern and Western Transmission 

Routes

PEM E1Kr 1.05

W-062f Shared Eastern and Western Transmission 

Routes

PFO T3Kr 0.32

W-064fd Western Transmission Route Only PEM E1Kr 1.17

W-064fd Shared Eastern and Western Transmission 

Routes

PEM E1Kr 0.04

W-065f Western Transmission Route Only PSS S3Kr 11.6

W-066f Western Transmission Route Only PFO T3Kr 9.07

W-067f Western Transmission Route Only PSS S3Kr 1.37

W-068f Western Transmission Route Only PFO T3Kr 4.11

W-069f Western Transmission Route Only PFO T3Kr 1.4

W-070f Western Transmission Route Only PEM E1Kr 0.21

W-071f Western Transmission Route Only PSS S3Kr 5.82

W-072f Western Transmission Route Only PFO T3Kr 1.1

W-073d Western Transmission Route Only PSS S3Kr 3.96

W-074d Western Transmission Route Only PFO T3Kr 0.33

W-075d Western Transmission Route Only PFO T3Kr 1.15
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Rural Utilities Service 3-95 Dairyland Power Cooperative

Wetland 

IDa Project Component Association

Wetland 

Classification

Cowardinb

Wetland 

Classification

WWIc

Acreage

in 

Wetland 

Survey 

Area

W-076d Western Transmission Route Only PFO T3Kr 1.12

W-077d Western Transmission Route Only PEM E1Kr 0.43

W-078d Western Transmission Route Only PFO T3Kr 5.15

W-081fd Western Transmission Route Only PSS S3Kr 3.80

W-081fd Shared Eastern and Western Transmission 

Routes

PSS S3Kr 0.68

W-082f Western Transmission Route Only PFO T3Kr 0.01

W-083f Western Transmission Route Only PFO T3Kr 0.53

W-084f Shared Eastern and Western Transmission 

Routes

PFO T3Kr 0.75

W-087d Western Transmission Route Only PFO T3Kr 1.74

W-088d Western Transmission Route Only PEM E1Kr 0.47

W-089d Western Transmission Route Only PFO T3Kr 1.31

W-090d Western Transmission Route Only PSS S3Kr 5.14

W-091d Western Transmission Route Only PEM E1Kr 0.27

W-092d Western Transmission Route Only PEM E1Kr 0.05

W-093d Western Transmission Route Only PSS S3Kr 5.26

W-094d Western Transmission Route Only PEM E1Kr 0.28

W-095d Western Transmission Route Only PUB W0Hx 0.48

W-096d Western Transmission Route Only PEM E1Kr 0.31

W-097d Western Transmission Route Only PFO T3Kr 0.72

W-098d Western Transmission Route Only PSS S3Kr 2.08

W-099d Western Transmission Route Only PFO T3Kr 0.73

W-100d Western Transmission Route Only PSS S3Kr 0.15

W-501fd Western Transmission Route Only PFO T3Kr 0.06

W-501fd Shared Eastern and Western Transmission 

Routes

PFO T3Kr 0.58

W-514d Shared Eastern and Western Transmission 

Routes

PFO T3Kr 0.44

W-515d Shared Eastern and Western Transmission 

Routes

PEM E1Kr 0.55

(a) A wetland ID ending in “d” indicates it was delineated via desktop evaluation, while “f” indicates it 

was field delineated.

(b) PEM = palustrine emergent, PSS = palustrine shrub/scrub, and PUB = palustrine unconsolidated 

bottom, PFO = palustrine forested wetland. Source: Based on Cowardin, L. M., V. Carter, F.C. Golet, 
Nemadji Trail Energy Center Affected Environment and Environmental Consequences

Rural Utilities Service 3-96 Dairyland Power Cooperative

and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. 

FWS/OBS-79/31. U.S. Fish and Wildlife Service, Washington, D.C.

(c) E1Kr = emergent/wet meadow, persistent, wet soil, palustrine, red clay complex; S3Kr = shrub/scrub, 

broad-leaved deciduous, wet soil, palustrine, red clay complex; T3Kr = forested, broad-leaved 

deciduous, wet soil, palustrine, red clay complex; W0Hx = open water, subclass unknown, standing 

water, palustrine, excavated. Source: Wisconsin Wetland Inventory Classification Guide 

(http://dnr.wi.gov/topic/wetlands/documents/WWI_Classification.pdf)

(d) W-055f, W-057f, W-061f, W-064f, W-081f, and W-501f has portions that exist in both the Western

Transmission Route only and shared Eastern and Western Transmission routes and are broken up for 

the purposes of denoting the different acres within each project component.

Table 3-44: Wetlands Identified Within the Hill Avenue Site Route Wetland Survey Area (Total Area 

- 18.66 acres)

Wetland IDa

Wetland 

Classification

Cowardinb

Wetland 

Classification

WWIc

Acreage in Wetland Survey Area

W-061f PEM E1Kr 1.17

W-062f PFO T3Kr 0.33

W-101d PEM E1Kr 1.80

W-102d PSS S3Kr 0.42

W-104d PSS S3Kr 0.16

W-106d PSS S3Kr 0.80

W-107d PSS S3Kr 1.00

W-108d PEM E1Kr 0.25

W-115d PSS S3Kr 10.02

W-118d PUB W0Hx 0.07

W-501f PFO T3Kr 0.72

W-503f PEM E1Kr 0.43

W-506d PEM E1Kr 0.69

W-510d PFO T3Kr 0.57

W-513f PSS S3Kr 0.17

W-517f PFO T3Kr 0.06

(a) A wetland ID ending in “d” indicates it was delineated via desktop evaluation, while “f” indicates it 

was field delineated.

(b) PEM = palustrine emergent, PSS = palustrine shrub/scrub, and PUB = palustrine unconsolidated 

bottom, PFO = palustrine forested wetland. Source: Based on Cowardin, L. M., V. Carter, F.C. Golet, 

and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. 

FWS/OBS-79/31. U.S. Fish and Wildlife Service, Washington, D.C.

E1Kr = emergent/wet meadow, persistent, wet soil, palustrine, red clay complex; S3Kr = shrub/scrub, 

broad-leaved deciduous, wet soil, palustrine, red clay complex; T3Kr = forested, broad-leaved 

deciduous, wet soil, palustrine, red clay complex; W0Hx = open water, subclass unknown, standing 

water, palustrine, excavated. Source: Wisconsin Wetland Inventory Classification Guide 

(http://dnr.wi.gov/topic/wetlands/documents/WWI_Classification.pdf)
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Rural Utilities Service 3-97 Dairyland Power Cooperative

For the Eastern Route, approximately 0.017 acre of wetlands would be permanently impacted (0.007 acre 

of PEM wetlands, 0.006 acre of PEM/PSS wetlands, and 0.004 acre of PFO wetlands) from placement of 

structures in wetlands. Similarly, approximately 7.47 acres of wetlands would be temporarily impacted 

(4.36 acres of PEM wetlands, 2.43 acres of PEM/PSS wetlands, 0.66 acre of PFO wetlands, and 0.02 acre 

of PSS wetlands) from temporary wetland matting. As a result of clearing activities, approximately 5.61

acres of PFO wetlands and approximately 5.35 acres of PSS wetlands would be converted to PEM 

wetlands. Additionally, the Eastern Route’s laydown area would temporarily impact 0.99 acre of wetlands 

(0.44 acre of PEM wetlands and 0.55 acre of PFO wetlands). As a result of the temporary laydown area

impacts, approximately 0.55 acre of PFO wetlands would be converted to PEM wetlands.

For the Western Route, approximately 0.046 acre of wetlands would be permanently impacted (0.004 acre 

of PEM wetlands, 0.003 acre of PEM/PSS wetlands, 0.018 acre of PFO wetlands, and 0.021 acre of PSS 

wetlands) from placement of structures in wetlands. Similarly, approximately 16.32 acres of wetlands 

would be temporarily impacted (0.94 acre of PEM wetlands, 1.17 acres of PEM/PSS wetlands, 6.54 acres 

of PFO wetlands, and 7.67 acres of PSS wetlands) from temporary wetland matting. As a result of 

clearing activities, approximately 29.1 acres of PFO wetlands and approximately 35.6 acres of PSS 

wetlands would be converted to PEM wetlands. Additionally, the Western Route’s laydown area would 

temporarily impact 0.99 acre of wetlands (0.44 acre of PEM wetlands and 0.55 acre of PFO wetlands). As 

a result of the temporary laydown area impacts, approximately 0.55 acre of PFO wetlands would be 

converted to PEM wetlands.

For the Hill Avenue Site Alternative Route, approximately 0.015 acre of wetlands would be permanently 

impacted (0.002 acre of PEM wetlands, 0.003 acre of PFO wetlands, and 0.010 acre of PSS wetlands) 

from placement of structures in wetlands. Similarly, approximately 3.37 acres of wetlands would be 

temporarily impacted (0.46 acre of PEM wetlands, 0.23 acre of PFO wetlands, and 2.68 acres of PSS 

wetlands) from temporary wetland matting. As a result of clearing activities, approximately 1.55 acres of 

PFO wetlands and 12.58 acres of PSS wetlands would be converted to PEM wetlands. 

A total of 13 transmission poles would likely be placed in wetlands within the Eastern Transmission 

Route Wetland Survey Area (see Appendix G for maps of transmission line structures near or within 

wetlands). A total of 40 transmission poles would be permanently placed in wetlands within the Western 

Transmission Route Wetland Survey Area. A total of 10 transmission poles would be permanently placed 

in wetlands within the Hill Avenue Site Route Wetland Survey Area.
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Rural Utilities Service 3-98 Dairyland Power Cooperative

Switching station sites that minimized wetland impacts were considered as part of Project development. 

Although both selected switching station sites are entirely within wetland areas, these sites would 

minimize the potential wetland impacts associated with the switching stations. Wetlands are prevalent in 

this area and could not be avoided. Locating the switching stations adjacent to the transmission line 

corridors minimizes additional wetland impacts that could have occurred in association with additional 

transmission line construction, construction access and road/driveway construction. Forested and 

shrub/scrub wetland areas would be cleared of vegetation at the switching station sites. 

For the Parkland Switchyard, approximately 13.33 acres of wetlands would be permanently impacted 

(9.51 acres of PFO wetlands and 3.82 acres of PSS wetlands) from switchyard pad fill. There would be no 

temporary impacts to wetlands from the Parkland Switchyard. 

For the Superior Switchyard, approximately 13.96 acres of wetlands would be permanently impacted 

(6.26 acres of PFO wetlands and 7.70 acres of PSS wetlands) from switchyard pad fill. There would be no 

temporary impacts to wetlands from the Parkland Switchyard. 

3.10.2.1.5 Wastewater

Wastewater impacts would be the same for either the Hill Avenue or Nemadji River Site. Wastewater 

quantity and quality would be the same during operation of either plant site. The Project would be 

responsible for installation of the sewer extension and tie-in to connect to the City’s wastewater system. 

The Owners would work with the City of Superior to install the wastewater discharge interconnection 

facilities to the City’s wastewater treatment plant. While the design of this installation has not been 

completed, it is expected that the plant would be connected as an industrial customer, would utilize 

existing piping to the extent practical, and any new piping would be high-density polyethylene (HDPE) 

and would be routed in existing ROW to the extent practical. Use of the City’s ROW for construction 

would require City Council resolution. Additionally, the City of Superior would require the Owners to 

take ownership of the sewer line extension and lift station because they would be constructed to service a 

single, privately held facility. Delivery meters would also be owned by the Project, and the monthly flow 

rate reading would be communicated to the City of Superior for processing as a wastewater bill.
Nemadji Trail Energy Center Affected Environment and Environmental Consequences

Rural Utilities Service 3-99 Dairyland Power Cooperative

The treatment of process waters (e.g., demineralization, RO, MF/UF) prior to use would generate waste 

streams that contain concentrated dissolved and suspended constituents. The chemical and physical 

attributes of the discharged waters, excluding sanitary wastewater, are provided below in Table 3-45 and 

are based on preliminary municipal water quality. 

Table 3-45: Wastewater Constituent Concentrations

Parameter Estimated Discharge Concentration (mg/L)(1)

Total Alkalinity at CaCO3 <1752

Calcium, Ca <147

Magnesium, Mg <45

Sodium, Na <419

Potassium, K <17

Sulfates, SO4 <599

Chloride, Cl <498

Silica, SiO2 <51

Total Dissolved Solids <1808

Total Alkalinity as HCO3 <213

(1) The estimated concentrations are based on makeup water treatment processes and the municipal water 

quality data received to date. Sanitary wastewater is not included. 

Metal concentrations in wastewaters would be below Federal, State, and City of Superior pretreatment 

limits found in Section 114-26, Article II of the City of Superior, Wisconsin Code of Ordinances and in 

40 CFR 423.17 – Pretreatment standards for new sources. 

The wastewater temperature would range from 40 °F in the cold winter ambient scenarios to about 150 °F 

in the maximum summer ambient scenario. The City of Superior requires discharges to its sewer system 

to have a daily maximum temperature of no more than 150 °F. 

At maximum summer municipal water consumption is estimated to be 1.5 MGD with the maximum 

annual average consumption being around 0.3 MGD. On average, approximately 50 percent of the water 

utilized for the Project, would be lost through evaporation. The remainder would be discharged to the City 

sewer. Delivery meters would be used to collect wastewater volume readings and would be owned by the 
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Rural Utilities Service 3-100 Dairyland Power Cooperative

Project. The maximum (summer) wastewater discharge is estimated to be around 0.6 MGD (0.93 cubic 

feet per second [cfs]) with the maximum annual average discharge being around 0.15 MGD (0.23 cfs). 

The Project would be assessed a charge for discharge into the City wastewater system. User charges 

would include a fixed charge and variable user charge for use of the City’s sewer system to discharge 

industrial wastewaters. The expected fixed charge is $5.50 per month, which is levied against every 

residential, commercial, and industrial connection. Connections which include more than one unit of 

service are charged $5.50 per month per unit of service. The variable user charge for each industrial 

connection is computed according to the discharge characteristics listed in Table 3-46. User charges are 

detailed in Article II, Section 114-62 of the City of Superior, Wisconsin Code of Ordinances. 

Table 3-46: Variable User Charges for Industrial Connections to the City of Superior Sewer System

Discharge Characteristics Unit Charges

BOD (per pound) $0.58

Suspended solids (per pound) $0.46

Phosphorus (per pound) $8.43

Volume (per 1,000 gallons) $3.59

Source: Article II, Section 114-62 of the City of Superior, Wisconsin Code of Ordinances

The WDNR’s Pretreatment Program is a requirement of the Federal Clean Water Act and is administered 

according to the regulations contained in WAC NR 211 and NR 220-297. The City of Superior has 

operated a State-approved Pretreatment Program since 1994 and is a designated “control authority”. 

Therefore, the City of Superior is authorized to issue pretreatment permits to industrial dischargers in 

accordance with Chapter 114, Article II of the City of Superior, Wisconsin Code of Ordinances. Because 

the Project would discharge industrial wastewater to the City’s sewer system and would discharge more 

than 25,000 gallons per day, the Facility is required to obtain an Individual Wastewater Discharge Permit 

from the City of Superior. The Pretreatment Program application materials were submitted to the City of 

Superior on December 18, 2018.
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Rural Utilities Service 3-101 Dairyland Power Cooperative

3.10.2.1.6 Stormwater

The Project Erosion Control Plan and Storm Water Management Plan was formatted and designed to 

meet or exceed compliance with the erosion control and storm water management technical standards and 

the construction and post-construction performance standards identified in WAC NR 151 and 216 as well 

as the City of Superior’s Site Erosion Control Ordinance and Long-Term Stormwater Management

Ordinance. The Erosion Control and Storm Water Management Plan addresses both the control of 

sediment and pollutants during construction until site stabilization is complete and the storm water 

management practices that would be installed during the construction phase to address the discharge of 

total suspended solids, to control peak flow, to provide for infiltration, and to maintain protective areas 

during Facility operation. Site-specific plans would be developed during the final design phase of the 

Project and provided to the WDNR and the City of Superior for review and approval prior to 

commencement of construction.

Non-contaminated storm water runoff on the Nemadji River Site would be collected and directed to an 

onsite storm water detention pond located near the southwestern boundary of the site. The existing pond 

discharges via underground pipe to the Nemadji River and would be expanded to attenuate the increase in 

runoff volume from Project construction. 

Storm water runoff on the Hill Avenue Site would be collected and routed to a new storm water detention 

pond located in the northeast corner of the site. The new pond would be pumped, and storm water would 

be discharged at existing surface grade to the east/northeast to a stream that discharges to Superior Bay.

The post-construction storm water management facilities would be designed to meet the performance 

standards addressed in NR 151. Drains for areas around equipment that could be contaminated with oil 

would be gravity drained and directed through an oil/water separator prior to discharge to the municipal 

sewer system. 

At either Site, the wet detention pond would be used as a sediment basin during Project construction to 

remove sediment loads from storm water runoff in accordance with WAC NR 151.11(6m)(b)2, which 

states that construction sites may discharge no more than 5 tons per acre per year, or to the maximum 

extent practicable, of the sediment load carried in runoff from initial grading to final stabilization. 

Following site stabilization, the sediment basin would be cleaned out and converted to a wet detention 

basin. The detention basin is designed to reduce the total suspended solids load by at least 80 percent, 

based on an average annual rainfall.
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Rural Utilities Service 3-102 Dairyland Power Cooperative

Drains for areas around equipment that could be contaminated with oil would be gravity drained and 

directed through an oil/water separator prior to discharge to the municipal sewer system.

3.10.2.2 No Action Alternative

The No Action Alternative would have no short- or long-term impacts on water resources in the Study 

Area because no construction would occur.

3.10.3 Mitigation Measures

Minimization efforts will be utilized to the extent practical where wetland impacts are unavoidable. 

Construction activities will be prioritized during winter months to take advantage of ground freeze and 

use of ice roads to limit ground disturbance. Outside of winter months, matting will be used in wetland 

areas to spread out heavy vehicle loads and minimize soil disturbance. Additionally, tracked vehicles will 

be used to the extent practical to further spread out vehicle loads throughout wetland area with matting.

Existing site entrances will be used to the extent practical to reduce the number of new roadside and 

wetland crossings required for construction vehicles to access the site. BMPs outlined in the SWPPP will 

be used to avoid and minimize stormwater sedimentation and disturbance within wetland areas.

The Sites will be designed to avoid and minimize temporary and permanent impacts to waterways. The 

post-construction storm water management facilities would be designed to meet the performance 

standards addressed in NR 151.

To the extent practicable, off-ROW access roads eliminate the need to cross wide waterways during 

construction. For smaller intermittent and ephemeral waterways within the ROW, temporary 

prefabricated span bridges will be used to span waterways. Following the removal of all temporary 

bridges, contours will be regraded to pre-construction conditions as needed. 

A Spill Prevention, Control and Countermeasures (SPCC) plan has been created for the Project. This plan 

establishes procedures, methods and equipment, and other requirements for equipment to prevent the 

discharge of oil from non-transportation-related onshore and offshore facilities into or upon the navigable 

waters of the United States or adjoining shorelines. The equipment at the site is outside the 100-year and 

500-year floodplain. 

The wetlands and waterways WDNR permit application materials were submitted on December 18, 2018. 

USACE was sent a wetland delineation report to review in preparation for PSCW decision. The Owners 

will provide the USACE with wetland permit information throughout the CPCN application process. An 
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Rural Utilities Service 3-103 Dairyland Power Cooperative

Individual Permit application was sent to the USACE on March 31 for the NTEC 625-megawatt (MW) 

gas turbine generation facility, natural gas supply pipeline, and 345-kilovolt transmission line, new 

switching station, staging areas, and laydown yards. Pre-construction notification was sent to the USACE 

on March 31 for the 10-inch natural gas pipeline relocation for Section 404 permit coverage under the 

Utility Regional General Permit. Pre-construction notification was sent to the USACE on March 31 for 

the transmission line relocation for Section 404 permit coverage under the Utility Regional General 

Permit and authorization under Section 10 of the Rivers and harbors Act. The USACE published these 

applications for 30-day public review and comment on September 14, 2020 (Appendix G). The Owners 

will comply with permit application requirements for wetlands and waterways.

3.11 Summary of Impacts

The following table (Table 3-47) provides a summary of potential impacts by Alternative.
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Table 3-47: Summary of Potential Impacts

Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

Air Quality

The existing air quality in the Douglas 

County area is designated as attainment or 

unclassifiable in regard to the NAAQS for 

all criteria pollutants. Construction of the 

Project has the potential for short-term 

adverse effects on air quality in the 

immediate area around the site. Minor and 

temporary generation of criteria pollutants 

and GHGs would occur during construction. 

It is anticipated that the Project would not 

affect the attainment status for Douglas 

County. The Owners would comply with the 

issued WDNR construction air permit that 

would include emission limitations, 

monitoring requirements, and other terms 

and conditions. The Project would not 

cumulatively contribute to significant 

adverse air quality impacts.

No unique impacts anticipated for this 

alternative. 

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.

Biological 

Resources

Temporary impacts from the Project could 

occur as a result of the increased presence of 

human and vehicle disturbance during 

construction. Temporary displacement of 

species might occur due to increased human 

activity in the area, vehicle traffic, and 

material transfer. Impacts to wildlife as a 

result of vehicle collisions would also be an 

increased risk during construction and 

operation. The majority of species affected 

would be mobile and able to move away 

from any impacts, but others could be 

vulnerable. 

Construction and operation of the Project 

would result in the permanent loss of 

vegetation communities, wildlife habitat, and 

plant and animal populations within the 

construction footprint. Additionally, some of 

the wildlife communities that occur at and in 

the vicinity of the Project would be 

temporarily displaced to surrounding areas 

where habitat is available. 

Construction of the either the Superior 

Switching Station or the Parkland Switching 

Station would impact approximately 14 

acres of woody vegetation in forested lands 

No forest or grassland communities 

occurs at the Hill Avenue Site. The Hill 

Avenue Site Route would require clearing 

in forested areas for new ROW and along 

the existing shared utility corridors. 

Woody vegetation clearing would occur 

along approximately 14.3 acres of the Hill 

Avenue Site Route in forested lands and 

shrubland habitats.

The Eastern Transmission Route would 

require approximately 23.1 acres of 

woody vegetation to be cleared from 

forested lands and shrubland habitats to 

widen the corridor and accommodate the 

additional line. Woody vegetation would 

be removed where additional, new ROW 

is needed and along the edges of the 

existing utility corridor.

No forest or grassland communities 

occurs at the Hill Avenue Site. The Hill 

Avenue Site Route would require 

clearing in forested areas for new ROW 

and along the existing shared utility 

corridors. Woody vegetation clearing 

would occur along approximately 14.3 

acres of the Hill Avenue Site Route in 

forested lands and shrubland habitats.

The Western Transmission Route would 

require clearing in forested areas for 

new ROW in addition to minor impacts 

to forested land along the existing 

shared utility corridors. Woody 

vegetation clearing would occur along 

approximately 79.1 acres of the Western 

Transmission Route in forested lands 

and shrubland habitats. Woody 

vegetation would be removed where 

additional, new ROW is needed and 

along the edges of the existing utility 

corridor.

Construction of the proposed project at 

the Nemadji River Site would 

permanently impact approximately 7.1 

acres of forest (approximately 4.6 acres 

of the quaking aspen forest in the 

northeastern portion of the site and 

approximately 2.5 acres of the mixed 

quaking aspen and black willow forest in 

the southeastern portion of the site) as 

well as impact approximately 7.2 acres of 

the forage grassland and wetland meadow 

communities

The proposed project footprint at the 

Nemadji River Site avoids clearing trees 

and vegetation along the banks, 

immediately adjacent to the Nemadji 

River. A vegetation buffer with a 

minimum width of 100 feet would be 

maintained between the proposed project 

footprint and the Nemadji River. The loss 

of plant and animal habitat would occur 

adjacent to existing areas that have 

already been developed. The Nemadji 

River Site is adjacent to an existing tank 

farm and utility corridors. This area has 

experienced some level of habitat 

fragmentation associated with 

Construction of the proposed project at 

the Nemadji River Site would 

permanently impact approximately 7.1 

acres of forest (approximately 4.6 acres 

of the quaking aspen forest in the 

northeastern portion of the site and 

approximately 2.5 acres of the mixed 

quaking aspen and black willow forest in 

the southeastern portion of the site) as 

well as impact approximately 6.47.2

acres of the forage grassland and wetland 

meadow communities

The proposed project footprint at the 

Nemadji River Site avoids clearing trees 

and vegetation along the banks, 

immediately adjacent to the Nemadji 

River. A vegetation buffer with a 

minimum width of 100 feet would be 

maintained between the proposed project 

footprint and the Nemadji River. The loss 

of plant and animal habitat would occur 

adjacent to existing areas that have 

already been developed. The Nemadji 

River Site is adjacent to an existing tank 

farm and utility corridors. This area has 

experienced some level of habitat 

fragmentation associated with 
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Rural Utilities Service 3-105 Dairyland Power Cooperative

Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

and shrubland habitats. No grassland habitat 

is present within the footprint of the 

switching station site.

Forested areas adjacent to the Project could 

provide potential habitat for the northern 

long eared bat. Snags that include potential 

summer roost trees for the northern longeared bat were observed during the site visit 

along Bear Creek, adjacent to Study Area. 

No potential summer roost habitat was 

observed at either proposed facility site. No 

caves were identified within the Study Area. 

no bald or golden eagle nests were observed 

during field surveys that occurred within the 

Study Area.

One invasive plant species, reed canary 

grass, was identified along all portions of the 

transmission line route and switching station 

site during the wetland delineation field. The 

three other invasive plant species were more 

sparsely distributed and were not observed at 

each Project component.

development in and around the City of 

Superior.

The Eastern Transmission Route would 

require approximately 23.1 acres of 

woody vegetation to be cleared from 

forested lands and shrubland habitats to 

widen the corridor and accommodate the 

additional line. Woody vegetation would 

be removed where additional, new ROW 

is needed and along the edges of the 

existing utility corridor.

development in and around the City of 

Superior.

The Western Transmission Route would 

require clearing in forested areas for new 

ROW in addition to minor impacts to 

forested land along the existing shared 

utility corridors. Woody vegetation 

clearing would occur along 

approximately 79.1 acres of the Western 

Transmission Route in forested lands and 

shrubland habitats. Woody vegetation 

would be removed where additional, new 

ROW is needed and along the edges of 

the existing utility corridor.

Cultural 

Resources

Based on the distance from NRHP properties 

and the concurrence from SHPO that no 

historic properties would be affected, it is 

anticipated that the Project would not have 

adverse impacts on cultural resources. 

No unique impacts anticipated for this 

alternative. 

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.
Nemadji Trail Energy Center Affected Environment and Environmental Consequences

Rural Utilities Service 3-106 Dairyland Power Cooperative

Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

Geology and 

Soils

Both Project sites would need to be graded 

and grading design would change the 

topography to facilitate storm water drainage 

patterns. Storm water runoff on the Nemadji 

River Site would be collected and directed to 

an onsite storm water detention pond. Storm 

water runoff on the Hill Avenue Site would 

be collected and routed to a new storm water 

detention pond. 

Both sites require excavation for 

underground utilities and deep structures 

such as pump pits. For the transmission line, 

foundation construction would occur after 

vegetation clearing is complete. Excavated 

soils from foundation drilling would be used 

for foundation backfill if appropriate. 

Surplus soils would be spread within upland 

areas of the right of way and stabilized. 

After all line construction is complete, the 

ROW is restored.

Construction and operation of any Project 

alternative is not expected to affect 

geological formations. Soils at the Project 

site would be converted to plant site 

development with much of the area occupied 

by the facilities and covered by concrete and 

gravel areas. The transmission line corridor 

would be cleared but only soil areas at the 

structure locations would be permanently 

excavated. Other areas of hydric and 

statewide important soils would remain 

largely unaffected by construction and 

following any necessary stabilization would 

be available for agriculture and other 

activities.

No unique impacts anticipated for this 

alternative. 

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.
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Rural Utilities Service 3-107 Dairyland Power Cooperative

Infrastructure, 

Transportation, 

Public Health 

and Safety, and 

Hazardous 

Materials

Utilities: Outages would be required on the 

Line No. 160 transmission line and the Line 

No. 761 transmission line to construct the 

new double circuit 345-kV The Project 

would require an outage to connect to the 

Arrowhead to Stone Lake 345 kV 

transmission line. The Project would require 

minor construction of water and wastewater 

pipelines to connect with the municipal 

system. 

Transportation: The daily automobile traffic 

to the site would increase from 

approximately 25 to 50 vehicles per day in 

the initial stages of construction to 

approximately 200 to 260 vehicles per day 

during peak months (April through 

December 2023). The traffic would begin to 

decrease until it reaches approximately 25 

vehicles per day near construction 

completion. Material and equipment 

deliveries are anticipated to average between 

15 and 25 trucks per day. Bulk deliveries for 

materials such as crushed stone, hot asphalt 

paving, and redi-mix concrete may 

occasionally exceed 25 vehicles on a given 

day.

No permanent changes to existing roads are 

anticipated as part of this Project. No 

permanent damage to roads is anticipated 

with the implementation of mitigation 

measures. There is currently no connection 

or proposed connection to rail lines related 

to the Project. Rail lines would be spanned 

by the Project transmission lines. The FAA 

issued Determination of No Hazard/Does 

Not Exceed (DNE) letters for the stacks at 

the Project sites. The FAA issued a 

Determination of No Hazard/DNE letter for 

all the transmission line structures that were 

studied on October 2, 2018. The Project 

would require off-ROW access roads.

Public health and safety: Access roads 

would be blocked from public access. 

Existing healthcare facilities are anticipated 

to be sufficient for the Project during 

construction and operation, and no necessary 

improvements are anticipated. The Project 

would have fire suppression measures of its 

At the beginning of the Eastern 

Transmission Route, an existing 115-kV 

line would be replaced with a double 

circuit 345/161-kV line, and the 115-kV 

line would be shifted onto the existing 

161-kV structures. 

The Western Transmission Route 

extends southeast from the Nemadji 

River Site to the existing Line No. 160. 

The Western Transmission Route would 

be built double circuit with the 161kV 

Line 160 for a couple spans before 

extending southwest as a single-circuit 

transmission line. 

The existing electric transmission lines 

that traverse the Nemadji River Site 

would need to be relocated to facilitate 

construction of the generation plant.

At the beginning of the Eastern 

Transmission Route, an existing 115-kV 

line would be replaced with a double 

circuit 345/161-kV line, and the 115-kV 

line would be shifted onto the existing 

161-kV structures. 

The fiberoptic cable between the Nemadji 

River Site and the Hill Avenue Site 

would need to be relocated if the Nemadji 

River Site is constructed. An existing 10-

inch natural gas line would need to be 

relocated at the Nemadji River Site.

The existing electric transmission lines 

that traverse the Nemadji River Site 

would need to be relocated to facilitate 

construction of the generation plant

The Western Transmission Route extends 

southeast from the Nemadji River Site to 

the existing Line No. 160. The Western 

Transmission Route would be built 

double circuit with the 161kV Line 160 

for a couple spans before extending 

southwest as a single-circuit transmission 

line. 

The fiberoptic cable between the Nemadji 

River Site and the Hill Avenue Site 

would need to be relocated if the Nemadji 

River Site is constructed. An existing 10-

inch natural gas line would need to be 

relocated at the Nemadji River Site.
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Rural Utilities Service 3-108 Dairyland Power Cooperative

Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

own, as well as facilities for the storage of 

hazardous materials. No City fire department 

improvements are anticipated. Police 

protection would be provided by the City of 

Superior and the Wisconsin State Patrol 

during both construction and operations, and 

no improvements are anticipated.

Waste management: Local waste disposal 

and sanitation facilities are not anticipated to 

be adversely affected by the additional waste 

streams generated during construction and 

operation of the Project. No additional solid 

wastes would be generated by the Project as 

byproducts from the production of 

electricity.
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Rural Utilities Service 3-109 Dairyland Power Cooperative

Land Use, 

Recreation, 

Farmland, and 

Coastal 

Facilities

Land use: Construction of either switching 

station would convert approximately 14 

acres of woody vegetation in forested lands 

and shrubland habitats to a switching station 

with electric transmission infrastructure.

It is anticipated that most of the impacts to 

grasslands along the transmission route 

would only be temporary construction. Some 

permanent impacts to grassland habitats 

would occur where transmission line poles 

and foundations would be set. No grassland 

habitat is present within the footprint of 

either switching station site.

Recreation: No direct impact to parks 

anticipated. While the Sites may be visible 

from these parks and loud Site noise such as 

from steam blows may be heard offsite, 

several streets with homes, combined with 

nearby commercial and industrial areas 

provide visual and sound buffers between 

the Sites and the existing parks. The 

transmission line routes primarily extend 

through undeveloped wooded areas. The 

switching station sites are also mostly 

surrounded by woodland, which helps 

provide visual buffers. The 18th Street and 

Nemadji canoe launch access may be 

impacted during construction of facilities 

through temporary road closures and 

temporary increased noise. The Project may 

impact visitors to the Orange Trail by 

increased traffic crossing the trail or 

temporary closures during Project 

construction, as well as slightly increased 

traffic crossing the trail during Project 

operation. Construction traffic and any road 

closures would be temporary in nature and 

cease after construction is complete. 

The Eastern and Western Transmission 

Routes south of the Nemadji River Site 

would require clearing woodland in a portion 

of the Allouez Area Parcel 1 hunting area. 

The routes generally follows existing 

transmission line and natural gas line 

through this area. Clearing would remove 

woodland habitat and result in a minor 

change to the habitat mix on these areas. 

Land use: The Hill Avenue Site consists 

entirely of undeveloped lowland 

scrub/shrub wetland community. No 

forest or grassland community occurs at 

the Hill Avenue Site. 

The Hill Avenue Site Route would require 

clearing in forested areas for new ROW 

and along the existing shared utility 

corridors. Woody vegetation clearing 

would occur along approximately 14.3 

acres of the Hill Avenue Site Route in 

forested lands and shrubland habitats.

The Eastern Transmission Route for the 

transmission line would likely be 

constructed within an existing utility 

corridor that contains a natural gas 

pipeline and overhead electrical 

transmission lines; however, 

approximately 23.1 acres of woody 

vegetation would be cleared from forested 

lands and shrubland habitats to widen the 

corridor and accommodate the additional 

line. Woody vegetation would be removed 

where additional, new ROW is needed 

and along the edges of the existing utility 

corridor. 

Recreation: The Hill Avenue Site would 

reduce the size of the Murphy Oil – 5 

hunting area by approximately 72 acres. 

The Eastern Transmission Route would 

cross the Itasca Area hunting area and the 

Annex hunting area. The route generally 

follows existing transmission line and 

natural gas line through these parcels. The 

transmission line route from the Hill 

Avenue Site south to the Nemadji River 

would also remove a portion of the 

Murphy Oil – 5 hunting area from hunting 

activities. Clearing would remove 

woodland habitat and result in a minor 

change to the habitat mix on these areas. 

Access to all or portions of these areas 

may also be controlled during 

construction. Once completed, access to 

these areas would be restored. 

The connecting facilities extending from 

the Hill Avenue Site to the southeast 

Land use: The Hill Avenue Site consists 

entirely of undeveloped lowland 

scrub/shrub wetland community. No 

forest or grassland community occurs at 

the Hill Avenue Site. 

The Hill Avenue Site Route would 

require clearing in forested areas for 

new ROW and along the existing shared 

utility corridors. Woody vegetation 

clearing would occur along 

approximately 14.3 acres of the Hill 

Avenue Site Route in forested lands and 

shrubland habitats.

The Western Transmission Route would 

require more clearing in forested areas 

for new ROW in addition to minor 

impacts to forested land along the 

existing shared utility corridors. Woody 

vegetation clearing would occur along 

approximately 79.1 acres of the Western 

Transmission Route in forested lands 

and shrubland habitats. Woody

vegetation would be removed where 

additional, new ROW is needed and 

along the edges of the existing utility 

corridor.

Recreation: The Hill Avenue Site would 

reduce the size of the Murphy Oil – 5 

hunting area by approximately 72 acres. 

The Western Transmission Route would 

cross a small portion of the Allouez 

Area Parcel 2 hunting area. The 

transmission line route from the Hill 

Avenue Site south to the Nemadji River 

would also remove a portion of the 

Murphy Oil – 5 hunting area from 

hunting activities. Clearing would 

remove woodland habitat and result in a 

minor change to the habitat mix on these 

areas. Access to all or portions of these 

areas may also be controlled during 

construction. Once completed, access to 

these areas would be restored. 

The connecting facilities extending from 

the Hill Avenue Site to the southeast 

Land use: Construction of the proposed 

project at the Nemadji River Site would 

permanently convert approximately 7.1 

acres of forest and approximately 7.2 

acres of the forage grassland and wetland 

meadow communities to power 

generation use. This use is compatible 

with adjacent land uses, which include an 

oil tank farm and an oil refinery. 

Recreation: Increased traffic and 

operation noise near the fishing access at 

18th Street during operation. Traffic 

during operation of the Project would 

increase vehicles on nearby roads but is 

not anticipated to significantly increase 

traffic due to the number of employees 

anticipated or reduce access to these 

facilities. 

The Eastern Transmission Route would 

cross the Itasca Area hunting area and the 

Annex hunting area. The route generally 

follows existing transmission line and 

natural gas line through these parcels. 

Clearing would remove woodland habitat 

and result in a minor change to the habitat 

mix on these areas. Access to all or 

portions of these areas may also be 

controlled during construction. Once 

completed, access to these areas would be 

restored. 

Farmland: The Eastern Transmission 

Route extends along the edge of a row 

crop field north of its intersection with 

County Road Z for approximately 930 

feet. The row crop field crossed by the 

Eastern Transmission Route would be 

impacted during construction of the 

Project. This section of route is within 

existing ROW, limiting impacts to 

already impacted areas. Soil along this 

portion of the route would likely be 

disturbed during transmission line 

construction and temporary access. If 

planted, crops in the ROW could be 

damaged during construction. After 

construction is complete in the area, 

farming activities can resume.

Land use: Construction of the proposed 

project at the Nemadji River Site would 

permanently convert approximately 7.1 

acres of forest and approximately 7.2 

acres of the forage grassland and wetland 

meadow communities to power 

generation use. This use is compatible 

with adjacent land uses, which include an 

oil tank farm and an oil refinery. 

The Western Transmission Route would 

require more clearing in forested areas for 

new ROW in addition to minor impacts 

to forested land along the existing shared 

utility corridors. Woody vegetation 

clearing would occur along 

approximately 79.1 acres of the Western 

Transmission Route in forested lands and 

shrubland habitats. Woody vegetation 

would be removed where additional, new 

ROW is needed and along the edges of 

the existing utility corridor.

Recreation: Increased traffic and 

operation noise near the fishing access at 

18th Street during operation. Traffic 

during operation of the Project would 

increase vehicles on nearby roads but is 

not anticipated to significantly increase 

traffic due to the number of employees 

anticipated or reduce access to these 

facilities. 

The Western Transmission Route would 

cross a small portion of the Allouez Area 

Parcel 2 hunting area. Clearing would 

remove woodland habitat and result in a 

minor change to the habitat mix on these 

areas. Access to all or portions of these 

areas may also be controlled during 

construction. Once completed, access to 

these areas would be restored. 
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Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

Access to all or portions of these areas may 

also be controlled during construction. Once 

completed, access to these areas would be 

restored.

Farmland: No farming activities currently 

occur at either Site. No farming has occurred 

in the recent past. The Western Transmission 

Route and Hill Avenue Site Route do not 

cross farmland. No known agricultural 

buildings and animal dairy confinement 

operations are located near the Project. In 

addition, the Project’s electrical clearances 

and ROW width are designed to limit 

neutral-to-earth and induced voltages that 

can create concern with livestock operations.

Coastal: No coastal facilities are located 

within the Project Study Area or macrocorridors. The nearest CBRS area is located 

approximately 30 miles northeast of the 

Project area along the Lake Superior 

shoreline in Bayfield County. No impacts to 

coastal facilities are anticipated due to the 

Project.

would introduce a new utility corridor 

through the hunting area. 

Farmland: The Eastern Transmission 

Route extends along the edge of a row 

crop field north of its intersection with 

County Road Z for approximately 930 

feet. The row crop field crossed by the 

Eastern Transmission Route would be 

impacted during construction of the 

Project. This section of route is within 

existing ROW, limiting impacts to already 

impacted areas. Soil along this portion of 

the route would likely be disturbed during 

transmission line construction and 

temporary access. If planted, crops in the 

ROW could be damaged during 

construction. After construction is 

complete in the area, farming activities 

can resume.

would introduce a new utility corridor 

through the hunting area. 
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Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

Noise

Project construction would result in 

temporary and minor noise impacts in the 

surrounding area. Construction-related 

sounds would vary in intensity and duration 

depending on specific stages and activities of 

construction but would not be permanent. 

Nearby residences may temporarily 

experience increased noise during 

construction. Minor temporary disturbances 

to wildlife could occur. 

Steam blows have the potential to 

significantly increase sound levels near the 

Project during their temporary and 

infrequent occurrence. Following the initial 

steam blow for commercial operation, 

subsequent steam blows would be rare 

occurrences, anticipated once every 10 to 15 

years as part of major system maintenance. 

Because these are rare and not long-term 

sources of noise, their impact is expected to 

be minimal. 

A preliminary noise study was conducted 

incorporating dry cooling equipment. The 

results of this study showed noise levels that 

would be in excess of EPA noise guideline 

levels. These levels were discussed with the 

finned heat exchanger suppliers and they 

confirmed the EPA noise guideline levels are 

achievable for the required equipment with 

proper mitigation measures. The Project will 

incorporate appropriate noise mitigation 

required to achieve EPA noise guideline 

levels.

No unique impacts anticipated for this 

alternative. 

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.
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Socioeconomics 

and 

Environmental 

Justice

During construction, the Project would 

create up to 260 jobs during peak activity. 

The number of workers onsite would begin 

at nominal levels at the beginning of 

construction and steadily increase over time, 

declining as major construction activities are 

completed. Local businesses near the 

Facility, such as gas stations, convenience 

stores, and restaurants, may experience 

increases in business during construction due 

to construction workers onsite. Local 

materials such as concrete, lumber, and 

general hardware may be purchased from 

local businesses. This increased demand 

would cease after construction is complete 

and would not add considerably to the 

demand on existing business, services, or 

community facilities.

The Project would create up to 25 full-time 

permanent jobs. These new permanent 

employees may be from the local workforce 

or may relocate to the area for the position. 

Considering the population of the City of 

Superior and Douglas County, the addition 

of 25 jobs is not anticipated to considerably 

increase demand for housing, schools, or 

other local services.

The City of Superior and Douglas County 

would receive payments in lieu of taxes of 

around one million dollars annually (twothirds to the city; one-third to the county) 

from the State of Wisconsin for hosting a 

generation facility. The City of Superior 

would also receive considerable fees from 

the facility for increased use of the City’s 

wastewater treatment system. County sales 

tax revenues are likely to increase over time, 

especially during the intense construction 

phase. There could be a negative local 

budget impact due to the increased use of 

31st Avenue East, which is currently a shortpaved road with an extended gravel portion 

that would need to be paved and maintained 

over time. Regional economic benefits are 

estimated at around one billion dollars over 

20 years.

Census Tract 210 is considered to be in an 

environmental justice low-income area. 

Census Tract 210 within the Study Area 

contains 52 residences. The nearest 

residence is located approximately 230 

feet west of the Eastern Transmission 

Route on 42nd Avenue East. This portion 

of transmission line is within an existing 

transmission line corridor. The ROW is 

surrounded by trees in this area, which 

provide a partial visual buffer. The 

minimal impacts within Census Tract 210 

do not constitute disproportionately high 

and adverse impacts to this environmental 

justice area.

No environmental justice areas crossed 

by Hill Avenue 2

Census Tract 210 is considered to be in 

an environmental justice low-income 

area. Census Tract 210 within the Study 

Area contains 52 residences. The nearest 

residence is located approximately 230 

feet west of the Eastern Transmission 

Route on 42nd Avenue East. This portion 

of transmission line is within an existing 

transmission line corridor. The ROW is 

surrounded by trees in this area, which 

provide a partial visual buffer. The 

minimal impacts within Census Tract 210 

do not constitute disproportionately high 

and adverse impacts to this environmental 

justice area.

No environmental justice areas crossed 

by Nemadji River 2
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Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

The Project would not directly impact any 

residences, public facilities, farming 

structures, cemeteries, religious facilities, or 

other structures. Temporary disruptions to 

normal traffic may occur during construction 

as equipment and employees commute to 

and from the Project. The frequency of the 

daily workforce automobile traffic would 

follow the Project workforce numbers onsite 

at a given time. The daily automobile traffic 

to the site would increase from 

approximately 25 to 50 vehicles in the initial 

stages of construction to approximately 200 

to 260 vehicles for peak months (April 

through December 2023). The traffic would 

begin to decrease until it reaches 

approximately 25 vehicles near construction 

completion and during operation.

Visual 

Resources

The aesthetics of the surrounding area would 

be altered by the Project. Vegetation would 

need to be cleared permanently for the 

Project Site, transmission line ROW, and 

switching station site. The Project site would 

require lighting for safety and security. Light 

emissions at the Project Site would increase 

compared to current levels of light emissions 

as a result of facility lighting. The dominant 

visual features of the Project would be a 

stack, a finned heat exchanger, and other 

facility equipment at the Project Site.

The transmission line routes parallel existing 

linear infrastructure for the majority of its 

length. The switching station sites are 

surrounded by undeveloped forested and 

shrubland habitats. None of the Project 

facilities are out of character with features 

already present across the visual landscape 

and the Project does not generally introduce 

new visual elements into the viewshed, 

keeping new facilities in proximity to 

already developed locations. Due to these 

factors and the distance from these scenic 

byways, it is anticipated that the Project 

would not significantly impact visual 

resources in the area.

The Hill Avenue Site has no light emitting 

sources currently onsite. Wooded areas 

located offsite of the Hill Avenue Site 

would provide a buffer to help mitigate 

light impacts to surrounding development. 

The stack and transmission line would be 

visible from multiple viewpoints 

throughout the area; most of the 

transmission line route is within 

undeveloped forested areas along existing 

utilities as well as within existing 

transmission line corridors. The tallest 

features of the site would be the stack, 

which would be approximately 171 feet 

above ground level at the Hill Avenue 

Site. 

The Hill Avenue Site is undeveloped 

lowland scrub/shrub surrounded by 

wooded areas and Hill Avenue on the 

west side. 

The Hill Avenue Site has no light 

emitting sources currently onsite. 

Wooded areas located offsite of the Hill 

Avenue Site would provide a buffer to 

help mitigate light impacts to 

surrounding development. 

The stack and transmission line would 

be visible from multiple viewpoints 

throughout the area; most of the 

transmission line route is within 

undeveloped forested areas along 

existing utilities, however, as well as 

within existing transmission line 

corridors. The tallest features of the site 

would be the stack, which would be 

approximately 171 feet above ground 

level at the Hill Avenue Site

The Hill Avenue Site is undeveloped 

lowland scrub/shrub surrounded by 

wooded areas and Hill Avenue on the 

west side. 

The lighting regime near the Nemadji 

River Site is currently influenced by 

lighting at the existing oil and gas 

facilities located immediately adjacent to 

the site property, although no light 

emitting sources currently occur on the 

site itself. The trees on the eastern 

boundary of the Nemadji River Site 

would provide a buffer and help mitigate 

additional lighting impacts.

The stack and transmission line would be 

visible from multiple viewpoints 

throughout the area; most of the 

transmission line route is within 

undeveloped forested areas along existing 

utilities, however, as well as within 

existing transmission line corridors. The 

tallest features of the site would be the 

stack, which would be approximately 194 

feet above ground level at the Nemadji 

River Site.

The Nemadji River Site is located 

adjacent to existing industrial areas. 

The lighting regime near the Nemadji 

River Site is currently influenced by 

lighting at the existing oil and gas 

facilities located immediately adjacent to 

the site property, although no light 

emitting sources currently occur on the 

site itself. The trees on the eastern 

boundary of the Nemadji River Site 

would provide a buffer and help mitigate 

additional lighting impacts.

The stack and transmission line would be 

visible from multiple viewpoints 

throughout the area; most of the 

transmission line route is within 

undeveloped forested areas along existing 

utilities, however, as well as within 

existing transmission line corridors. The 

tallest features of the site would be the 

stack, which would be approximately 194 

feet above ground level at the Nemadji 

River Site.

The Nemadji River Site is located 

adjacent to existing industrial areas. 
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Water 

Resources

Surface Water: Considering the distance of 

the Project from Outstanding or Exceptional 

Resource Waters; trout streams; and wild 

and scenic rivers, and with the 

implementation of mitigation measures 

described in Section 3.10.3, it is anticipated 

that construction and operation of the Project 

would not result in impacts to these features. 

Groundwater: No groundwater would be 

used for the Project. Therefore, there would 

be no impacts to groundwater. No impacts to 

domestic or high capacity pumping wells are 

anticipated.

Floodplain: The Superior Switching Station, 

Parkland Switching Station, and all laydown 

yards are not within 100-year floodplain. All 

rivers would be spanned by the transmission 

line. Two transmission line structures would 

need to be placed within the Nemadji River 

floodplain due to the floodplain width.

Wetlands/Riparian: The switching station 

sites would be placed entirely within wetland 

areas. Forested and shrub/scrub wetland 

areas would be cleared of vegetation at the 

switching station sites. 

Wastewater: The Project would be 

responsible for installation of the sewer 

extension and tie-in to connect to the City’s 

wastewater system. It is expected that the 

plant would be connected as an industrial 

customer, would utilize existing piping to 

the extent practical, and any new piping 

would be high-density polyethylene and 

would be routed in existing ROW to the 

extent practical. The City of Superior would 

require the Owners to take ownership of the 

sewer line extension and lift station because 

they would be constructed to service a 

single, privately held facility. 

Approximately 0.6 MGD) would be 

discharged to the City sewer. Delivery 

meters would be used to collect wastewater 

volume readings and would be owned by the 

Project.

No unique impacts anticipated for this 

alternative. 

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.

No unique impacts anticipated for this 

alternative.
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Resource

Impacts common to all Project 

Alternatives Hill Avenue 1 Impacts Hill Avenue 2 Impacts Nemadji River 1 Impacts Nemadji River 2 Impacts

Stormwater: The post-construction storm 

water management facilities would be 

designed to meet the performance standards 

addressed in NR 151. Drains for areas 

around equipment that could be 

contaminated with oil would be gravity 

drained and directed through an oil/water 

separator prior to discharge to the municipal 

sewer system. At either Site, the wet 

detention pond would be used as a sediment 

basin during Project construction to remove 

sediment loads from storm water runoff in 

accordance with WAC NR 151.11(6m)(b)2. 

Following site stabilization, the sediment 

basin would be cleaned out and converted to 

a wet detention basin. The detention basin is 

designed to reduce the total suspended solids 

load by at least 80 percent, based on an 

average annual rainfall.
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4.0 CUMULATIVE IMPACTS

This chapter lists the past, present, and reasonably foreseeable future actions (RFFAs) in the Study Area 

that may affect the resources analyzed in this EA. An assessment of cumulative effects of the Project for 

each resource is provided as well. The CEQ regulations implementing NEPA defines cumulative impacts 

as, “the impact on the environment which results from the incremental impact of the action when added to 

other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or nonFederal) or person undertakes such action.” (40 CFR §1508.7). 

4.1 Past, Present, and Reasonably Foreseeable Future Actions

Past, present, and RFFAs that have affected the resources of the Douglas County include:

• Construction of a new 16-inch natural gas line from the Nemadji River Site to the existing Great 

Lakes Transmission natural gas line

• Relocation of 10-inch natural gas line at the Nemadji River Site

• Relocation of the fiberoptic cable between the Nemadji River Site and the Hill Avenue Site

• Relocation of existing electric transmission at the Nemadji River Site

• Construction of two parallel single circuit electric transmission lines from the Superior Switching 

Station to a tap point on the existing Arrowhead to Stone Lake transmission line (if the Superior 

Switching Station Alternative is constructed)

• Past residential and business development in the surrounding area

• Existing Husky Energy Superior Refinery operations and April 2018 fire

• Forest management and timber harvesting in Douglas County

4.2 Cumulative Impacts by Resource

The following sections provide anticipated cumulative impacts by resource. 

provides a summary of cumulative impacts.

4.1.1 Air Quality

Previous activities in the Study Area that have impacted air quality include construction activities 

associated with residential and business development, and forest management activities. The existing 

Husky Energy Superior Refinery had a fire in April 2018. Residents were evacuated in the surrounding 

area. The incident at the refinery included the combustion of oil and asphalt, which contributed to air

emissions in the area. 
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Table 4-1: Summary of Cumulative Impacts Assessment

Resource Cumulative Impacts

Contribution of Proposed 

Project to Cumulative

Effects

Air Quality Emissions from NTEC facility and 

vehicles/equipment used during construction

Minor. Minimal effects on the 

NAAQS or PSD Class I area 

or Class II area increment

Biological 

Resources

Removal of vegetation/habitat; temporary 

displacement of wildlife during construction due 

to increased traffic and noise; permanent 

displacement of wildlife at Nemadji River Site 

and where vegetation permanently removed; 

potential mortality to wildlife individuals 

Minor; most wildlife 

displacement would be 

temporary, habitat loss 

minimal compared to overall 

available

Cultural 

Resources

No adverse impacts on cultural resources with 

the implementation of proposed mitigation 

measures

None anticipated

Geology and 

Soils

Potential for erosion. Soil disturbance at site and 

along transmission line ROW. No cumulative 

geological effects are anticipated, and Project not 

anticipated to contribute considerably to 

cumulative soil impacts

Minor with implementation of 

mitigation measures

Infrastructure, 

Transportation, 

Public Health 

and Safety, and 

Hazardous 

Materials

Temporary impact of outages and minimal 

impacts to other existing infrastructure; 

temporary impact of construction traffic and offROW access roads

Project not anticipated to 

create considerable additional 

demands on existing 

infrastructure that would 

contribute to adverse 

cumulative effects

Land Use

Clearing of wooded areas and conversion to open 

grassland or paved/gravel surfaces as part of 

infrastructure facilities and ROW

Minor with implementation of 

mitigation measures. Changes 

generally consistent with 

existing land uses.

Noise

Temporary increases in noise levels during 

construction. Modeling showed the Project 

would be below EPA guideline noise levels at 

nearest residential properties during operation.

No considerable adverse 

cumulative noise effects are 

expected

Socioeconomics

and 

Environmental 

Justice

Jobs generated, temporary construction-related 

economic benefits, and the economic benefits of 

the Project during operation

Project would not contribute 

cumulatively to adverse 

socioeconomic impacts. 

Would provide some financial 

benefits due to permanent jobs 

and tax collection

Visual Resources

Visual landscape would be altered by the Project 

through vegetation clearing, increased light 

emissions, construction, and operation of the 

Project. Project facility site is located adjacent to 

industrial areas. Transmission line parallels 

existing utilities for the majority of length. 

Minor
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Resource Cumulative Impacts

Contribution of Proposed 

Project to Cumulative

Effects

Water Resources

Several water resources crossed by the Project or 

within Project footprint. Several wetlands would 

be located within Project footprint.

Minimal with implementation 

of mitigation measures

Husky Energy monitored air quality between April 2018 and June 2018 at the Superior Refinery site and 

in the surrounding area. None of that monitoring showed concentrations above health-based thresholds.

The following RFFAs would contribute to vehicle emissions in the area: construction of a new 16-inch 

natural gas line from the Nemadji River Site to the existing Great Lakes Transmission natural gas line; 

relocation of a 10-inch natural gas line at the Nemadji River Site; the relocation of the fiberoptic cable 

between the Nemadji River Site and the Hill Avenue Site; the relocation of existing electric transmission 

at the Nemadji River Site; and construction of two parallel single circuit electric transmission lines from 

the Superior Switching Station to a tap point on the existing Arrowhead to Stone Lake transmission line 

(if the Superior Switching Station is constructed). These construction activities are anticipated to be 

intermittent and temporary in nature, ceasing after construction is complete. During operation, the 

transmission line, pipelines, and fiberoptic cable may require periodic inspection and maintenance. 

Vehicles used during these activities would contribute to vehicle emissions in the area, though these 

activities would also be intermittent and temporary in nature. 

During construction of the Project, exhaust emissions, fugitive dust, and other construction-related 

emissions would occur. However, these increases would be temporary in nature and cease when 

construction is complete. As such, these emissions are not anticipated to substantially impact the overall

air quality in the region, and no cumulative impacts to air quality would occur as a result of construction 

activities. 

Based on the air quality modeling results for the Project during operation, it has been predicted that the 

Project would have minimal effects on the NAAQS and PSD Class I and Class II Increment. No other 

industrial projects are known in the Study Area. It is anticipated that the Project would not cause or 

contribute to adverse ambient air quality impacts. Because this Class II modeling considered cumulative 

effects of other existing and proposed sources, the Project would not cumulatively contribute to adverse 

air quality impacts. 
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4.1.2 Biological Resources

Other past, present, and RFFAs that may have affected biological resources in the region include 

residential and business development (including the Husky Energy Superior Refinery), particularly near 

the City of Superior; forest management and timber harvesting; the planned 16-inch natural gas line; the 

relocation of the 10-inch natural gas line at the Nemadji River Site; the relocation of the fiberoptic cable 

between the Nemadji River Site and the Hill Avenue Site; the relocation of the existing electric 

transmission lines at the Nemadji River Site; and construction of two parallel single circuit electric 

transmission lines from the Superior Switching Station to a tap point on the existing Arrowhead to Stone 

Lake transmission line (if the Superior Switching Station is constructed). These activities would cause 

permanent loss of vegetation communities and wildlife habitat through ROW clearing and may increase 

plant and animal mortalities within the construction footprint. Also, these RFFAs may temporarily 

displace wildlife communities during construction due to increased human and vehicle presence in the 

area and increase the risk for wildlife vehicle collisions during construction and operation. 

As discussed in Section 3.2.2, the Project is not anticipated to affect Canada lynx, gray wolf, Kirtland’s 

warbler, piping plover, rufa red knot, or Fassett’s locoweed. The Project footprint contains potential 

habitat for the northern long-eared bat and bald eagle. Invasive species were also identified along the 

transmission line alternatives during wetland delineations. With the implementation of mitigation 

measures described in Section 3.2.3.1, it is not anticipated that these species and their habitats would be 

considerably affected by the Project. The Owners would implement the mitigation measures in Sections

3.2.3.3 and 3.2.3.4 to minimize the spread of invasive species. As such, the project would not contribute 

considerable adverse cumulative effects to protected species in the Project area.

Temporary impacts to biological resources include displacement of wildlife communities during 

construction due to increased human and vehicle presence in the area. Impacts to wildlife as a result of 

vehicle collisions would also be an increased risk during construction and operation. Most species 

affected would be mobile and able to move away from any impacts, but individuals or other less mobile 

species could be vulnerable. It is anticipated that most of the impacts to grasslands along the transmission 

route would only be temporary construction impacts to existing grassland habitat along existing utility 

corridors. Temporary impacts from the Project could occur as a result of the increased presence of human 

and vehicle disturbance during construction. These temporary impacts due to construction would cease 

once construction is complete. 

Construction and operation of the Project would result in the permanent loss of vegetation communities, 

wildlife habitat, and some limited mortality to individuals within the plant and animal populations in the 
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construction footprint (Table 4-2). For the Nemadji River Site, the loss of plant and animal habitat would 

occur adjacent to existing areas that have already been developed. The Nemadji River Site is adjacent to 

an existing tank farm and utility corridors. This area has experienced some level of habitat degradation 

and fragmentation associated with development in and around the City of Superior. The Hill Avenue Site 

is in the same general vicinity as the Nemadji River Site but would require more woody vegetation 

clearing in lowland scrub/shrub wetland and is not immediately adjacent to the existing tank farm.

Table 4-2: Summary of Habitat Loss

Project Component

Habitat 

Permanently 

Impacted

Impacted 

Habitat 

(acres)

Total Habitat in 

Douglas 

Countya(acres)

Percentage of 

Douglas County 

Acres Impacted

Nemadji River Site Forested and 

shrubland areasb

7.1 754,342.2 < 0.1

Nemadji River Site Forage grassland and 

wetland meadow

7.2 64,237.9 < 0.1

Hill Avenue Site Lowland scrub/shrub 

wetland community

75.5 37,921.4 0.2

Eastern 

Transmission line Forested areas

6.7 715,768.1 < 0.1

Eastern 

Transmission line Grassland 16.3 48,047.7 < 0.1

Eastern 

Transmission line

Non-forested 

wetland

28.7 16,190.2 0.2

Western 

Transmission Line Forested areas 34.7 715,768.1 < 0.1

Western 

Transmission Line Grassland 3.0 48,047.7 < 0.1

Western 

Transmission Line

Non-forested 

wetland

45.1 16,190.2 0.3

Hill Avenue Site 

Route Forested area 1.6 715,768.1 < 0.1

Hill Avenue Site 

Route Grassland 0.3 48,047.7 < 0.1

Hill Avenue Site 

Route

Non-forested 

wetland

17.0 16,190.2 0.1

Parkland Switching 

Station

Forested lands and 

shrubland areas

14.0 754,342.2 < 0.1

a – Wiscland2 dataset used to calculate Douglas County landcover totals

b – “Forested areas” include forested wetland and upland forests
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As shown in Table 4-2, the Nemadji River Site would remove less than 0.1 percent of forest and 

shrubland land from Douglas County overall. The Nemadji River Site would remove less than 0.1 percent 

of forage grassland and wetland meadow. The Hill Avenue Site, however, would remove 0.2 percent of 

lowland scrub/shrub wetland community from Douglas County overall. The Eastern and Western 

Transmission Routes would remove less than 0.1 percent of forested areas and grassland from Douglas 

County overall. The Eastern Transmission Route would require ROW in non-forested wetland, crossing 

0.2 percent of the non-forested wetland in Douglas County. The Western Transmission Route would cross 

0.3 percent of non-forested wetland in Douglas County. If the Hill Avenue Site were constructed, the Hill 

Avenue Site Route would require crossing an additional 0.1 percent of Douglas County’s non-forested 

wetland. Much of this is along the transmission line route near existing utility corridors. Lastly, the 

Parkland Switching Station would require clearing less than 0.1 percent of the forested lands and 

shrubland areas in Douglas County. This level of clearing and changes in habitat are insignificant 

compared to the changes and disturbance to wildlife and vegetation associated with clearing, harvesting, 

and replanting of timber resources. Due to the small percentages of land cover cleared, cumulative effects 

on biological resources due to habitat loss are not considered significant. 

4.1.3 Cultural Resources

Other past, present, and RFFAs that may have affected the cultural resources in the region include 

residential and business development, including the existing Husky Energy Superior Refinery; forest 

management and timber harvesting; the planned 16-inch natural gas line; the relocation of the 10-inch 

natural gas line at the Nemadji River Site; the relocation of the fiberoptic cable between the Nemadji 

River Site and the Hill Avenue Site; the relocation of the existing electric transmission lines at the 

Nemadji River Site; and construction of two parallel single circuit electric transmission lines from the 

Superior Switching Station to a tap point on the existing Arrowhead to Stone Lake transmission line (if 

the Superior Switching Station is constructed). These activities may have or may impact cultural 

resources through construction activities that require grading, excavation, or other disturbance of soils.

On February 4, 2019, the RUS submitted a finding of no historic properties affected to the WHS in 

accordance with 36 CFR § 800.4(d)(1) and provided the cultural resources survey report as 

documentation for review and consideration (see Gottsfield et al. 2019). The WHS concurred with this 

determination in March 2019 (Appendix C). Based on the distance from NRHP properties, the 

concurrence from SHPO that no historic properties will be affected, and the mitigation measures proposed 

in Section 3.3.3, it is anticipated that the Project would not have adverse impacts on cultural resources. As 

a result, the Project is not anticipated to result in adverse cumulative effects on cultural resources with the 

implementation of mitigation measures described in Section 3.3.3.
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4.1.4 Geology and Soils

Past and present actions that have affected geology in the Study Area include the establishment of 

industrial facilities (particularly the nearby tank farm), businesses and residential development, 

particularly development where wells were installed. RFFAs that may impact geology include the planned 

16-inch natural gas line; the relocation of the 10-inch natural gas line at the Nemadji River Site; the 

relocation of the fiberoptic cable between the Nemadji River Site and the Hill Avenue Site; the relocation 

of the existing electric transmission lines at the Nemadji River Site; and construction of two parallel 

single circuit electric transmission lines from the Superior Switching Station to a tap point on the existing 

Arrowhead to Stone Lake transmission line (if the Superior Switching Station is constructed). Installation 

and relocation of the pipelines and fiberoptic cable would require excavation of a trench for placement of 

the pipeline. Trench excavation would be relatively shallow and would not be expected to have any 

impact on the area geology. Transmission line structures would require foundations be installed. Care 

would need to be taken during excavation and installation of pipeline, fiberoptic cable, and transmission 

line structures to minimize overall soil disturbance, control runoff, and avoid mixing of soil profiles and 

compaction during storage and trench backfilling. Should trenchless techniques be used for installation of 

pipeline and fiberoptic cable at some locations, potential disturbance to soils would be reduced compared 

to trench installation.

The Project Site would be graded and grading design would change the topography to facilitate site 

construction and storm water drainage patterns. Storm water runoff on the Nemadji River Site would be 

collected and directed to an onsite storm water detention pond, which would be enlarged. Storm water 

runoff on the Hill Avenue Site would be collected and routed to a new storm water detention pond located 

in the northeast corner of the site. The new pond would be pumped, and storm water would be discharged 

at existing surface grade to the east/northeast to a stream that discharges to Superior Bay. There would be 

some excavation for underground utilities and deep structures such as pump pits and the suitable material 

from these excavations would be used for trench backfill and site grading. Installation of the sheet pile 

wall would require excavation and select material backfill.

Transmission line structures will require excavation limited to structure foundation locations. Holes for 

the 345-kV structure foundations will range from approximately 55 feet to 95 feet deep and 7 to 12 feet in 

diameter, depending on soil conditions and design. Foundation construction would begin with drilling for 

structure foundations. After the structure bases are installed, the remaining structure is assembled at each 

pole location by a crane. Excavated soils would be used for foundation backfill if appropriate. Surplus 

soils would be spread within the right of way and stabilized. After all line construction is complete, the 

ROW would be restored.
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At the Project Sites, soils would be converted to plant site development with much of the area occupied 

by the facilities and covered by concrete and gravel areas. The transmission line corridor would be 

cleared but only soil areas at the structure locations would be permanently excavated. Other soil 

disturbance would be limited to surface disturbance from clearing and construction activities. Areas of 

hydric and statewide important soils would remain largely unaffected by construction and following any 

necessary stabilization would be available for agriculture and other activities.

Based on the amount of excavation required, the type of substrate at the Project sites, and erosion control 

techniques that would be implemented (see Section 3.4.4), construction and operation of the Project is not 

expected to affect geological formations and is not anticipated to considerably impact soils. Therefore, no 

cumulative geological effects are anticipated and it is not anticipated that the Project would contribute 

considerably to cumulative soil impacts.

4.1.5 Infrastructure, Transportation, Public Health, and Waste Management

Human health and safety infrastructure in the Study Area are used by existing residential and business 

development. Forest management workers also use the local health and safety infrastructure. RFFAs that 

may impact human health and safety include the planned 16-inch natural gas line; the relocation of the 

10-inch natural gas line at the Nemadji River Site; the relocation of the fiberoptic cable between the 

Nemadji River Site and the Hill Avenue Site; the relocation of the existing electric transmission lines at 

the Nemadji River Site; and construction of two parallel single circuit electric transmission lines from the 

Superior Switching Station to a tap point on the existing Arrowhead to Stone Lake transmission line (if 

the Superior Switching Station is constructed).

Infrastructure: The 16-inch natural gas line would require the construction of a tap point on the existing 

Great Lakes Transmission natural gas line. Several existing transmission lines would be affected by the 

Project and outages would be required on the Line No. 160 transmission line and the Line No. 761 

transmission line to construct the new double circuit 345-kV Transmission Line. Extended outages on the 

Line No. 761 are difficult to accommodate and would need to be minimized as much as practical to 

maintain reliable service to the area. During outages, the Owners would need to coordinate with local 

electrical service providers to provide for continued electrical service with minimal, if any, service 

interruptions. The Project would require minor construction of water pipelines to connect with the 

municipal system. There would be no adverse impact to the municipal water system or change in capacity 

requirements needed to the system related to the Project because the existing municipal sewer and water 

systems have sufficient capacity to accommodate the Project needs.
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Transportation: The RFFAs will increase traffic during construction and during maintenance activities. 

These impacts would be intermittent and temporary in nature. Project construction traffic accessing the 

Project site would primarily consist of automobile traffic for craft labor, construction management staff, 

contractors, equipment, and vendors. Material and equipment deliveries may be made by large trucks as 

well as heavy haul vehicles. Onsite, traffic is anticipated to primarily consist of heavy construction 

equipment and material transport equipment. The construction site would be operated as a closed 

worksite. Designated walk paths to working locations would be constructed for craft workers to use. 

The frequency of the daily workforce automobile traffic would follow the Project workforce numbers 

onsite at a given time. The traffic would begin to decrease until it reaches approximately 25 vehicles near 

construction completion. When possible, bulk deliveries would be scheduled to avoid peak traffic on local 

roads. The Nemadji River Site would include pull over areas for material delivery trucks to reduce 

congestion.

No permanent changes to existing roads are anticipated as part of this Project. No permanent damage to 

roads is anticipated with the implementation of mitigation measures proposed in Section 3.5.3. The 

Owners would work with the appropriate county or municipal authority on solutions to potential traffic 

congestion that may develop as a result of the construction traffic. There is currently no connection or 

proposed connection to rail lines related to the Project. 

The FAA issued Determination of No Hazard/Does Not Exceed (DNE) letters for the plant stacks on 

October 3, 2017. The FAA also issued a Determination of No Hazard/DNE letter for all transmission line 

structures that were studied on October 2, 2018.

The Project requires several temporary off-ROW access roads for construction access along the 

transmission line route. Temporary off-ROW access roads would be restored to pre-existing conditions, 

subject to the request of the landowner.

Public health and safety: RFFAs have the potential to increase risks to public health and safety. Any 

construction and operation activities related to the aforementioned RFFAs would be required to comply 

with applicable Federal, state, and local permits and regulations.

The Project would minimize potential human health and safety impacts through restricting site access 

during construction and operation of the Project to employees, construction workers, emergency

equipment, police, and fire protection. The roads serving the Project are adequate (width, grade, 
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construction, overall safety and design capacity) to carry current and all prospective traffic. Access roads 

would be blocked from public access. 

The Project would comply with all relevant Federal, state, and local requirements, including all 

requirements concerning public health and safety, including but not limited to requirements addressing 

land use, noise, and traffic. 

Existing healthcare facilities are anticipated to be sufficient for the Project during construction and 

operation, and no necessary improvements are anticipated. The Project would have fire suppression 

measures of its own, as well as facilities for the storage of hazardous materials. This storage would 

require coordination activities with the City Fire Department. No improvements are anticipated to be 

required due to the Project related to the City Fire Department. Police protection would be provided by 

the City of Superior and the Wisconsin State Patrol during both construction and operations, and no 

necessary improvements are anticipated related to police patrols.

Waste Management: The aforementioned RFFAs have the potential to generate solid waste through 

construction, wastes produced by construction workers, and waste produced by employees during future 

operations and maintenance activities. Wastes produced during operation would likely be minimal as 

operations and maintenance activities would be intermittent and temporary in nature.

Solid waste produced during the Project would occur from construction debris, wastes produced by 

construction workers, and wastes produced by employees onsite during operation of the Project. These 

wastes would be collected in trash containers throughout the Project site and sent to a local landfill. Local 

waste disposal and sanitation facilities are not anticipated to be adversely affected by the additional waste 

streams generated during construction and operation of the Project. No additional solid wastes would be 

generated by the Project as byproducts from the production of electricity.

Summary: Based on the temporary impact of outages and minimal impacts to other existing 

infrastructure; temporary impact of construction traffic and off-ROW access roads; compliance with 

relevant Federal, state, and local public health and safety requirements; and proposed waste management 

procedures, it is not anticipated that the Project would create noticeable additional demands on existing 

infrastructure that would contribute to adverse cumulative effects. 
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4.1.6 Land Use

Land use in the Study Area has been altered by existing residential and business development, including 

the Husky Energy Superior Refinery, and forest management and timber harvesting. RFFAs that may 

impact land use in the Study Area include the planned 16-inch natural gas line; the relocation of the 10-

inch natural gas line at the Nemadji River Site; the relocation of the fiberoptic cable between the Nemadji 

River Site and the Hill Avenue Site; the relocation of the existing electric transmission lines at the 

Nemadji River Site; and construction of two parallel single circuit electric transmission lines from the 

Superior Switching Station to a tap point on the existing Arrowhead to Stone Lake transmission line (if 

the Superior Switching Station is constructed).

Land use: RFFAs will cause permanent loss of vegetation through ROW clearing. Land use would be 

converted from current uses to pipeline, fiberoptic cable, or transmission line ROW use.

Construction of the Project at the Nemadji River Site would permanently convert approximately 7.1 acres 

of forest and approximately 6.4 acres of the forage grassland and wetland meadow communities to power 

generation use. This use is compatible with adjacent land uses, which include an oil tank farm and an oil 

refinery. The proposed project footprint at the Nemadji River Site avoids clearing trees and vegetation 

along the banks, immediately adjacent to the Nemadji River. A vegetation buffer with a minimum width 

of 100 feet would be maintained between the plant footprint and the Nemadji River. Based on the results 

of a site survey that was conducted in October 2017, the Hill Avenue Site consists entirely a lowland 

scrub/shrub wetland community. No forest or grassland community occurs at the Hill Avenue Site.

The Eastern Transmission Route for the transmission line would likely be constructed within an existing 

utility corridor that contains a natural gas pipeline and overhead electrical transmission lines; however, 

approximately 23.1 acres of woody vegetation, forested and shrub lands, would be cleared to widen the 

corridor and accommodate the additional line. Woody vegetation would be removed where additional, 

new ROW is needed and along the edges of the existing utility corridor. 

The Western Transmission Route would require more clearing in forested areas for new ROW in addition 

to minor impacts to forested land along the existing shared utility corridors. Woody vegetation clearing 

would occur along approximately 79.1 acres of the Western Transmission Route in forested lands and 

shrubland habitats. Woody vegetation would be removed where additional, new ROW is needed and 

along the edges of the existing utility corridor.
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The Hill Avenue Site Route would require clearing in forested areas for new ROW and along the existing 

shared utility corridors. Woody vegetation clearing would occur along approximately 14.3 acres of the 

Hill Avenue Site Route in forested lands and shrubland habitats.

Construction of the either the Superior Switching Station or the Parkland Switching Station would 

convert approximately 14 acres of woody vegetation in forested lands and shrubland habitats to a 

switching station with electric transmission infrastructure.

It is anticipated that most of the impacts to existing grasslands along the transmission route would only be 

temporary construction impacts. Some permanent impacts to grassland habitats would occur where 

transmission line poles and foundations would be set. No grassland habitat is present within the footprint 

of either switching station site.

Recreation: RFFAs have the potential to impact nearby recreation resources during construction and 

operation, depending on the location of routes. Impacts may include increased traffic near recreational 

trails, temporary road closures, and increased noise. These impacts would likely be intermittent and 

temporary in nature. During operation of the aforementioned RFFAs, inspection and maintenance 

activities may cause minor impacts via slightly increased traffic and noise.

No parks are located within 0.5 mile of the Nemadji River Site, Hill Avenue Site, or within the macrocorridors; therefore, impacts to any parks are not expected. While the Sites may be visible from parks 

outside the study area and macro-corridors and loud Site noise such as from steam blows may be heard 

offsite, the Project would likely only potentially impact visitors to the Orange Trail, fishing access at 18th 

Street, and the Nemadji canoe launch. Impacts would include increased traffic crossing the trail or 

temporary closures during Project construction, as well as increased traffic crossing the trail during 

Project operation. Construction traffic and any road closures would be temporary in nature and cease after 

construction is complete. 

The transmission line route south of the Nemadji River Site would require clearing woodland in a portion 

of the Allouez Area Parcel 1 hunting area. The Eastern Transmission Route will cross the Itasca Area 

hunting area, and the Annex hunting area. The route generally follows existing transmission line and 

natural gas line through these parcels, however. The Hill Avenue Site would reduce the size of the 

Murphy Oil – 5 hunting area by approximately 72 acres. This would reduce the amount of area available 

for hunting in the northern portion of the hunting area. The transmission line route from the Hill Avenue 

Site south to the Nemadji River would also remove a portion of the Murphy Oil – 5 hunting area from 

hunting activities. The eastern and western transmission line routes would both cross the Allouez Area 
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Parcel 1 hunting area. The Eastern Transmission Route would also cross the Itasca Area hunting area as 

well as the Annex hunting area. The Western Transmission Route would cross a small portion of the 

Allouez Area Parcel 2 hunting area. The connecting facilities extending from the Hill Avenue Site to the 

southeast would introduce a new utility corridor through the hunting area. Clearing would remove 

woodland habitat and result in a minor change to the habitat mix on these areas. Access to all or portions 

of these areas may also be controlled during construction. Once completed, access to these areas would be 

restored.

Farmland: The RFFAs may cross farmland. These areas may be unavailable for agricultural activities 

during construction and may have vegetation restrictions during operation of the RFFAs. Construction 

activities will impact soils in the ROW for these RFFAs through soil disturbance associated with 

trenching, drilling, or transmission line structure installation. 

No farming activities currently occur at either Site and no farming has occurred in the recent past. The 

transmission line route extends along the edge of a row crop field north of its intersection with County 

Road Z for approximately 930 feet. This length is entirely within existing ROW, however. 

The Western Transmission Route and Hill Avenue Site Route do not cross farmland. The row crop field 

crossed by the transmission line route would be impacted during construction of the Project. This section 

of route is within existing ROW, however, which helps limit impacts to already impacted areas. Soil 

along this portion of the route would likely be disturbed during transmission line construction and 

temporary access. If planted, crops in the ROW could be damaged during construction. After construction 

is complete in the area, farming activities can resume.

No known agricultural buildings and animal dairy confinement operations are located near the Project. In 

addition, the Project’s electrical clearances and ROW width are designed to limit neutral-to-earth and 

induced voltages that can create concern with livestock operations.

An agricultural impact notice was sent to the Wisconsin DATCP on December 18, 2018. An Agricultural 

Impact Statement is not required as the Project does not cross private agricultural land. See Appendix D

for correspondence with the Wisconsin DATCP as well as the formal release letter.

Coastal facilities: No coastal facilities are located within the Study Area or the macro-corridors.

Summary: As described in Section 4.2.2, the clearing of the Project Site, transmission line ROW, and 

switching station site would contribute to the cumulative loss of habitat throughout the Study Area. The 

Project would introduce industrial and utility land uses compatible with current land uses that are already 
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present in the surrounding area. Only temporary impacts to recreation facilities are anticipated. The 

Project is not anticipated to adversely impact agricultural lands. No coastal facilities are located in the 

Study Area. Due to this, cumulative effects on land use are not considered significant. 

4.1.7 Noise 

Existing industrial, residential, and business development, forest management, and associated traffic all 

currently contribute to noise in the Study Area. RFFAs that may contribute to existing noise include these 

current activities and construction of the planned 16-inch natural gas line; the relocation of the 10-inch 

natural gas line at the Nemadji River Site; the relocation of the fiberoptic cable between the Nemadji 

River Site and the Hill Avenue Site; the relocation of the existing electric transmission lines at the 

Nemadji River Site; and construction of two parallel single circuit electric transmission lines from the

Superior Switching Station to a tap point on the existing Arrowhead to Stone Lake transmission line (if 

the Superior Switching Station is constructed). Any noise increases associated with these RFFAs are 

anticipated to be temporary in nature and cease upon completion of construction.

Project construction would result in temporary and minor noise impacts in the surrounding area. 

Construction-related sounds would vary in intensity and duration depending on specific stages and 

activities of construction but would not be permanent. Nearby residences may temporarily experience 

increased noise during construction. Minor temporary disturbances to wildlife could occur. 

The modeled noise results for the operation of a facility at the Nemadji River Site show a maximum total 

A-weighted sound level emitted from the Project that would be below the EPA guideline noise levels at 

the nearest residential properties. The Nemadji River Site can meet the EPA guidelines without further 

mitigation. Modeled results for the Hill Avenue Site show a maximum predicted A-weighted sound level 

emitted from the Project that would be in excess of the EPA guideline noise levels at the nearest 

residential property. The Hill Avenue Site would need further mitigation to reduce sound level to below 

the EPA guidelines. Steam blows have the potential to significantly increase sound levels near the Project 

during their temporary operation. Because these are rare and not long-term sources of noise, their impact 

is expected to be minimal. Based on this, no adverse cumulative noise effects are expected as a result of 

the Project.

4.1.8 Socioeconomics and Environmental Justice

Past and present actions that have affected socioeconomics in the Study Area include the establishment of 

businesses and residential development, particularly in the City of Superior. Construction of the planned 

16-inch natural gas line; the relocation of the 10-inch natural gas line at the Nemadji River Site; the 
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relocation of the fiberoptic cable between the Nemadji River Site and the Hill Avenue Site; the relocation 

of the existing electric transmission lines at the Nemadji River Site; and construction of two parallel 

single circuit electric transmission lines from the Superior Switching Station to a tap point on the existing 

Arrowhead to Stone Lake transmission line (if the Superior Switching Station is constructed) would have 

little if any impacts to the socioeconomic conditions of the area, although they may provide a small 

number of temporary jobs, temporarily increase traffic on local surrounding roads and increase sales of 

lodging, food, fuel, and building materials during construction. 

During construction, the Project would create up to 260 jobs during peak activity. The workforce may be 

sourced from different locations locally or nationwide. Local businesses near the Facility may experience 

increases in business during construction due to construction workers onsite. Local materials may be 

purchased from local businesses. This increased demand would cease after construction is complete and 

would not add considerably to the demand on existing businesses, services, or community facilities.

The Project would require up to 25 full-time permanent jobs. These new permanent employees may be 

from the local workforce or may relocate to the area for the position. Considering the population of the 

City of Superior (26,473 residents) and Douglas County (43,503 residents), the addition of 25 jobs is not 

anticipated to considerably increase demand for housing, schools, or other local services. 

The City of Superior and Douglas County would receive payments in lieu of taxes of around one million 

dollars annually (two-thirds to the city; one-third to the county) from the State of Wisconsin for hosting a 

generation facility. The City of Superior would also receive considerable fees from the facility for 

increased use of the City’s wastewater treatment system. County sales tax revenues are likely to increase 

over time, especially during the intense construction phase. Increased use of 31st Avenue East, which is 

currently a short-paved road with an extended gravel portion may require additional maintenance due to 

increased construction traffic.

Census Tract 210 is considered to be in an environmental justice low-income area, based on the 

environmental justice analysis described in Section 3.8.1.4. Census Tract 210 within the Study Area 

contains 52 residences. The nearest residence is located approximately 230 feet west of the proposed 

transmission line route on 42nd Avenue East. This portion of transmission line is within an existing 

transmission line corridor. The ROW is surrounded by trees in this area, which provide a partial visual 

buffer. The Project would not directly impact any residences, public facilities, farming structures, 

cemeteries, religious facilities, or other structures. Temporary disruptions to normal traffic may occur 
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during construction. The minimal impacts within Census Tract 210 do not constitute disproportionately 

high and adverse impacts to this environmental justice area.

Regional economic benefits are estimated at around one billion dollars over 20 years. The facility owners 

are both active in their other host communities and intend to continue that commitment to the City of 

Superior and Douglas County. For example, the Owners have co-sponsored a bike sharing program in the 

City for the next two years. The Project is in discussions with local partners to create a trail near the 

facility and to upgrade the canoe launch near the facility.

Due to the 25 jobs generated, the temporary nature of construction-related economic benefits, and the 

economic benefits of the Project, it is anticipated that the Project would not contribute cumulatively to 

adverse socioeconomic impacts. Due to the lack of residences in the area and the distances from 

residences in the census tract, it is anticipated that the Project would not have disproportionately high and 

adverse impact on environmental justice communities in this area. As such, the Project is not anticipated 

to contribute to environmental justice cumulative impacts.

4.1.9 Visual Resources

The landscape of Douglas County has been altered by industrial, residential and business development,

timber harvesting, and forest management. Construction of the planned 16-inch natural gas line; the 

relocation of the 10-inch natural gas line at the Nemadji River Site; the relocation of the fiberoptic cable 

between the Nemadji River Site and the Hill Avenue Site; the relocation of the existing electric 

transmission lines at the Nemadji River Site; and construction of two parallel single circuit electric 

transmission lines from the Superior Switching Station to a tap point on the existing Arrowhead to Stone 

Lake transmission line (if the Superior Switching Station is constructed) will require vegetation clearing. 

The aesthetics of the surrounding area would be altered by the Project. Vegetation would need to be 

cleared and light emissions at the Project Site would increase compared to current levels of light 

emissions as a result of facility lighting. The stack at the facility, other facility equipment, transmission 

line structures, and switching station would introduce new features to the landscape.

The Nemadji River Site is located adjacent to existing industrial areas. The trees on the eastern boundary 

of the Nemadji River Site would provide a buffer and help mitigate additional lighting impacts. The Hill 

Avenue Site is undeveloped lowland scrub/shrub surrounded by wooded areas and Hill Avenue on the 

west side. Wooded areas located offsite of the Hill Avenue Site would provide a buffer to help mitigate 

light impacts to surrounding development. The transmission line routes parallel existing transmission for 

the majority of its length. The switching stations are surrounded by wooded, undeveloped areas. None of 
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the Project facilities are out of character with features already present across the visual landscape and the 

Project does not generally introduce new visual elements into the viewshed, keeping new facilities in 

proximity to already developed locations. Due to these factors and the distance from these scenic byways, 

it is anticipated that the Project would not significantly impact visual resources in the area. As such, no 

considerable contribution to cumulative impacts on visual resources is anticipated due to the Project.

4.1.10 Water Resources

Past and present actions in the watershed may have impacted water resources, including residential and 

business development, the Husky Energy Superior Refinery, and forest management and timber 

harvesting. The construction of the planned 16-inch natural gas line; the relocation of the 10-inch natural 

gas line at the Nemadji River Site; the relocation of the fiberoptic cable between the Nemadji River Site 

and the Hill Avenue Site; the relocation of the existing electric transmission lines at the Nemadji River 

Site; and construction of two parallel single circuit electric transmission lines from the Superior 

Switching Station to a tap point on the existing Arrowhead to Stone Lake transmission line (if the 

Superior Switching Station is constructed) has the potential to impact water resources. 

Surface Water: The RFFAs have the potential to impact surface water resources in the area. The 16-inch 

natural gas pipeline will likely require surface water crossings between the Project site and the tap 

location on the Great Lakes Limited natural gas pipeline. 

Waterways would be crossed by the transmission line route. With the implementation of mitigation 

measures proposed in Section 3.10.3, impacts to these streams would be minimized. 

Considering the distance of the Project from Outstanding or Exceptional Resource Waters; trout streams; 

and wild and scenic rivers, it is anticipated that construction and operation of the Project would not result 

in any impacts to these features. 

Groundwater: No domestic or high capacity wells are located within a 0.5-mile radius of the Nemadji 

River Site. The nearest high capacity groundwater user is located over 3 miles west of the Nemadji River 

Site (Precision Foods). The nearest high capacity municipal groundwater user is the Village of Oliver, 

which is located 7.3 miles west of the Nemadji River Site. 

Only two municipal water users are located within 10 miles of the Nemadji River Site: the City of 

Superior and the Village of Oliver. The City of Superior obtains its water supply from a surface water 

source (Lake Superior) and would not be impacted by new groundwater withdrawals for the Project. As

no domestic or high capacity pumping wells are located within a 0.5-mile radius of the Nemadji River 
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Site, no impacts to domestic or high capacity pumping wells are anticipated. No high capacity wells 

would be installed as part of this project. No additional impacts to groundwater would occur.

Floodplain: Construction of the 16-inch natural gas pipeline is anticipated to cross areas of floodplain in 

the Study Area. Construction and installation of pipelines in floodplains would require clearing of rightof-way and excavation. No surface facilities to reduce flood storage or obstruct flood waters are 

anticipated to be placed in floodplains due to the aforementioned RFFAs.

The Nemadji River Site is located adjacent to the Nemadji River floodplain and a small portion of the 

property boundary extends into the 100-year and 500-year floodplain. All equipment for the facility is 

located outside the 100-year and 500-year floodplain, however. The Hill Avenue Site is not within 100-

year floodplain. The switching stations and all laydown yards are not within 100-year floodplain. Both 

transmission line alternatives would require crossing floodplain associated with the Nemadji River, Bear 

Creek, and Bluff Creek. The macro-corridors contain both 100-year and 500-year floodplain. All rivers 

would be spanned by the transmission line. Two transmission line structures would potentially need to be 

placed within the Nemadji River floodplain due to the floodplain width. 

Wetlands/riparian areas: The aforementioned RFFAs have the potential to impact wetlands and riparian 

areas in the Study Area due to the abundance of wetland areas in the region. Impacts may include placing 

transmission line structures in wetlands, trenching or drilling in or under wetlands, and moving 

construction equipment through or near wetlands.

The Nemadji River Site contains six wetlands (7.4 acres). One wetland (totaling 75.6 acres) was 

delineated within the Hill Avenue Site. A total of 30 wetlands (49.5 acres) were delineated within the 

Eastern Transmission Line Wetland Survey Area. A total of 42 wetlands (totaling 86.4 acres) were 

delineated within the Western Transmission Route Wetland Survey Area. A total of 16 wetlands (totaling 

18.7 acres) were delineated within the Hill Avenue Site Route Wetland Survey Area. A total of 13 

transmission poles would likely be placed in wetlands within the Eastern Transmission Route Wetland 

Survey Area. A total of 40 transmission poles would be permanently placed in wetlands within the 

Western Transmission Route Wetland Survey Area. A total of 10 transmission poles would be 

permanently placed in wetlands within the Hill Avenue Site Route Wetland Survey Area. Additionally, 

the switching station would be placed entirely within wetland areas. Forested and shrub/scrub wetland 

areas would be cleared of vegetation at the switching station sites. 
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Wastewater: The aforementioned RFFAs are not anticipated to generate wastewater. The Project would 

be responsible for installation of the sewer extension and tie-in to connect to the City’s wastewater 

system. The Owners would work with the City of Superior to install the wastewater discharge 

interconnection facilities to the City’s wastewater treatment plant.

Stormwater: The aforementioned RFFAs have the potential to contribute to erosion and increased 

suspended solids in stormwater runoff. The RFFAs would need to implement and adhere to the mitigation 

measures in their respective SWPPPs and erosion control plans to minimize impacts related to 

stormwater.

The Erosion Control and Storm Water Management Plan addresses both the control of sediment and 

pollutants during construction until site stabilization is complete and the storm water management 

practices that would be installed during the construction phase to address the discharge of total suspended 

solids, to control peak flow, to provide for infiltration, and to maintain protective areas during Facility 

operation. Site-specific plans would be developed during the final design phase of the Project and 

provided to the WDNR and the City of Superior for review and approval prior to commencement of 

construction.

Non-contaminated storm water runoff on the Nemadji River Site would be collected and directed to an 

onsite storm water detention pond. The existing pond discharges via underground pipe to the Nemadji 

River and would be expanded to attenuate the increase in runoff volume from Project construction. Storm 

water runoff on the Hill Avenue Site would be collected and routed to a new storm water detention pond 

located in the northeast corner of the site. The new pond would be pumped, and storm water would be 

discharged at existing surface grade to the east/northeast to a stream that discharges to Superior Bay. The 

post-construction storm water management facilities would be designed to meet the performance 

standards addressed in NR 151. Drains for areas around equipment that could be contaminated with oil 

would be gravity drained and directed through an oil/water separator prior to discharge to the municipal 

sewer system. The wet detention pond would be used as a sediment basin during Project construction to 

remove sediment loads from storm water runoff. Following site stabilization, the sediment basin would be 

cleaned out and converted to a wet detention basin. The detention basin is designed to reduce the total 

suspended solids load by at least 80 percent, based on an average annual rainfall. 

Summary: The Project would require crossing multiple waterways. Also, transmission line structure may 

need to be placed within the Nemadji River floodplain due to the floodplain width at the river crossing 

location. The Project would require clearing of forested and shrub/scrub wetland areas.
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The Owners would implement the mitigation measures detailed in Section 3.10.3 to minimize impacts to 

wetlands, waterways, and floodplain. With the implementation and maintenance of these measures, the 

cumulative impact of the Project, when added to other past, present, and RFFAs affecting water resources 

in the area, would be minimal. No adverse impacts are anticipated related to groundwater, wastewater, or 

stormwater.
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5.0 SUMMARY OF MITIGATION

The following is a summary of mitigation proposed for the Project by resource.

5.1 Air Quality

During construction, steps will be taken to prevent excessive emissions of particulate matter resulting 

from construction activities and vehicular traffic. These steps may include compacting, seeding, covering, 

paving, wetting, sweeping, or otherwise controlling particulate matter emissions. 

Post-construction, the areas disturbed during construction will receive final cover to eliminate dust. All 

exposed soil areas will be seeded to grow grass, lesser-traveled road surfaces will be graveled and 

compacted, and the new main roads on-site will be surfaced with asphalt. The roads will be monitored 

and either wetted or swept to clean any fugitive dust that may occur due to on-site wheeled traffic. 

The SCR and oxidation catalyst will be integrated into the HRSG design by the supplier of the HRSG. 

The HRSG supplier will also provide ports in the stack to monitor HRSG stack emissions. The CEMS 

will monitor the HRSG NOx stack emissions through these ports.

The Project will require a PSD major source construction air permit pursuant to the requirements 

specified in the WAC Chapter Natural Resources (NR) 405. The PSD permit application contains the 

following analyses/assessments regarding emissions of regulated pollutants associated with the 

construction and operation of the Project: 

• Evaluation of ambient air quality in the area for each regulated pollutant for which the Project 

will result in a significant net emissions increase

• Demonstration that emissions increases resulting from the Project will not cause or contribute to 

an increase in ambient concentrations of pollutants exceeding the remaining available PSD 

increment and the NAAQS

• Assessment of any adverse impacts on soils, vegetation, visibility, and growth in the area

• A BACT analysis for each regulated pollutant for which the Project will result in a significant net 

emissions increase

The Owners submitted the PSD permit application for the Project to WDNR and will adhere to conditions 

and requirements of the application during operation of the Project. The WDNR provided notification of 

the air permit approval on September 1, 2020 (Appendix A).
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5.2 Biological Resources

The following sections describe the avoidance, minimization measures, and WDNR-identified actions for 

the Project to help conserve federally protected species, Wisconsin’s rare species, and high-quality natural 

communities.

5.2.1.1 Northern Long-eared Bat

Reproductive females and their young are highly vulnerable to mass mortality during their maternity 

period (June 1 – July 31) because they aggregate in maternity colonies. Young northern long-eared bats 

start flying by 18 to 21 days after birth and therefore cannot leave the roost for several weeks after birth 

(USFWS 2015; Federal Register 2016). To follow the USFWS 4(d) rule for the Northern Long-Eared Bat, 

one of the following options should be implemented to avoid take of the NLEB: 

1. Assume the bats are present within suitable habitat and avoid removal of known occupied maternity 

roost trees or any trees within 150 feet of a known occupied maternity roost tree from June 1 – July 31. 

For suitable habitat that occurs outside of 150 feet of a known occupied maternity roost tree or outside of 

0.25 miles of a NLEB hibernaculum, implement the avoidance measures outlined in the Cave Bat Broad 

Incidental Take Permit and Authorization. According to the WDNR, if the Project can implement these 

avoidance measures, there will not be any further Project restrictions related to the NLEB. If the Project 

cannot completely avoid take of the NLEB, WDNR recommends that the BNHC Incidental Take 

Coordinator be contacted to determine possible Project-specific avoidance measures. If take cannot be 

avoided, consultation with the USFWS will be necessary. 

2. Not assume the NLEB is present within suitable habitat along the alternative routes and have a 

qualified biologist conduct surveys to determine if the NLEB is present (a copy of the survey biologist’s 

credentials and a copy of the survey protocols must be sent to the WDNR Endangered Resources Review 

Program for approval prior to the initiation of surveys). According to the WDNR, if the NLEB is not 

found within the Study Area as a result of the surveys, there will be no Project restrictions related to these 

species. If surveys are conducted and the NLEB or maternity colonies are detected, option 1 must be 

followed. Survey results should be submitted to the Endangered Resources Utility Liaison.

5.2.1.2 Eagles

While the bald eagle was removed from the Federal Endangered Species list in August 2007, it is still 

federally protected by the BGEPA and the MBTA. Golden eagles are considered a nonbreeding, 

infrequent inhabitant in Wisconsin. Eagles can be sensitive to human disturbance, especially during the 

breeding and nesting seasons. Per the USFWS National Bald Eagle Management Guidelines (2007), 
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human activity within 660 feet of an active nest should be avoided from January 15 – July 30. No bald 

eagle nests were observed during field surveys that occurred within the Study Area; however, if a bald 

eagle nest should be identified within the Survey Area, the USFWS National Bald Eagle Management 

Guidelines (2007) would be followed.

5.2.1.3 Invasive Species

In compliance with WAC Chapter NR 40 Invasive Species Identification, Classification and Control 

Rule, the Owners will mitigate the potential to spread invasive plant species during Project activities. 

Invasive plant species locations will be shown on the construction plans and flagged on-site to avoid 

during construction, where feasible. In areas where impacts to the invasive plant species are unavoidable, 

equipment will be cleaned prior to moving from an infested area to a non-infested area. 

Equipment cleaning will primarily be conducted by brush, broom, or other hand tools along the Project. 

The Owners may periodically require equipment to be cleaned by compressed air. Equipment used during 

ground disturbing activities will be cleaned prior to leaving the Project ROW to reduce the risk of 

spreading invasive plant species beyond the Project ROW. 

Construction equipment brought on-site will be required to be free of muck and invasive species. In 

accordance with Wisconsin DATCP Chapter 20, WAC, seed mixtures that contain potentially invasive 

species or species that may be harmful to native plant communities will be avoided.

5.2.1.4 Revegetation

Construction activities will include clearing, grubbing, grading, excavation, infrastructure construction, 

and re-vegetation. In areas were restoration is required, seeding and mulching will be completed in 

accordance with WDNR Technical Standard 1059 – Seeding for Construction Site Erosion Control. The 

seed mix used will be appropriate to the surrounding area and similar to pre-construction conditions. The 

seedbed will be adequately prepared to promote successful germination. Seed mixes will not contain 

invasive species. Permanent seed mixtures will be selected to produce dense vegetation based on soil and 

site conditions, along with intended final use. Temporary seeding will be applied to areas of exposed soil 

where the establishment of vegetation is desired, but the areas have not been brought to final grade or on 

which land-disturbing activities will not be performed for a period greater than 30 days, but vegetative 

cover is required for less than 1 year. Areas needing protection during periods when permanent seeding is 

not applied, will be seeded with annual species.

Upon completion of restoration, each work location will be monitored to document stabilization and revegetation. Monitoring will continue until vegetative cover reaches 70 percent of previous cover.
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5.2.1.5 Migratory Birds

The MBTA prohibits the take of migratory birds and their eggs, young, or active nests. The loss of plant 

and animal habitat within the footprint of the proposed Project, would primarily occur adjacent to existing 

areas that have already been developed or are associated with existing utility and public road ROWs. The 

Nemadji River Site is adjacent to an existing tank farm and utility corridors and this area has experienced 

some level of habitat fragmentation associated with development in and around the City of Superior. The 

Eastern Transmission Route for the transmission line would be constructed within an existing utility 

corridor that contains a natural gas pipeline and overhead electrical transmission lines or the Western 

Transmission Route would be constructed parallel to existing linear infrastructure; however, woody 

vegetation would be cleared from forested lands and shrubland habitats along the edges of the existing 

utility corridor to widen the corridor and accommodate the additional line. During the extent of the 

Project, trees that would be removed would be done so outside of the migratory bird nesting period for 

Wisconsin (May 15 to August 1) to avoid impacts to nesting migratory birds (U.S. Department of 

Agriculture, 2018).

5.3 Cultural Resources

If the Archaeological Study Area configuration is changed, additional archaeological investigations;

documentation of historic-age, non-archaeological resources; and NRHP evaluations may be necessary.

If buried cultural resources are encountered during Project construction, land-disturbing activities in the 

immediate area must be halted, and the investigators and WHS/SHPO archaeologists must be notified. 

Any exposed cultural resources will be evaluated for their significance and appropriate actions to address 

these finds coordinated with WHS/SHPO.

5.4 Geology and Soils

Best management practice (BMP) erosion control techniques will be used to mitigate soil impacts. 

Topsoil will be kept separate from subsoils and will be stockpiled in a different location than subsoils. 

This topsoil will be used after construction to resurface areas disturbed by construction activities. 

Compacted soils will be disked prior to final stabilization. It is not anticipated that any subsoil removed 

for excavations will be spread in upland cropland or pasture. The Storm Water Management Technical 

Standards from WDNR will be used during construction and operation. 

A Storm Water Pollution Prevention Plan (SWPPP) will be submitted to WDNR as part of Project 

permitting activities. The Owners will implement, monitor, and maintain BMPs, described in the SWPPP 

to minimize erosion and sedimentation. The Owners will comply with the construction site storm water 
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discharge permit (Wis. Admin. Code NR 216) that was submitted to WDNR for the Project in December 

2018.

5.5 Infrastructure, Transportation, Public Health, and Waste Management

The following presents mitigation measures for transportation, public health, and waste management

resources for the Project. No mitigation measures related to utility infrastructure are proposed.

Transportation

The Owners do not anticipate permanent damage to roads. As a precautionary measure, the Owners will 

video-document the condition of all roads on the construction vehicle routes to document the road 

condition prior to the start of construction. Any documented adverse impacts to the roads incurred due to

the construction of the Project will be addressed through consultation with applicable road authorities 

regarding the Owners’ responsibility for repairing the adversely impacted roads. 

The Owners will coordinate the proper construction signage on the roads used by construction vehicles 

for the Project to make drivers aware of the increased hazards associated with the construction vehicle(s) 

presence.

Public Health and Safety

The Owners will develop a Health and Safety Plan to address public and worker safety during the 

construction and operation of the Project. The Health and Safety Plan would identify any requirements for 

temporary fencing around staging, excavation, and laydown areas during construction, as well as 

protocols for emergency responses. The Owners would work with local first responders to develop 

emergency response procedures in the plan. The plan would also include provisions for worker protection 

as is required under Occupational Safety and Health Administration (OSHA) CFR1926. During 

construction, all employees, contractors, and sub-contractors would be required to adhere to OSHA safety 

procedures, which will be taught in a mandatory training for all construction works on site. All heavy 

equipment would be up to OHSA safety standards and personal safety equipment would be required for 

all workers on site. Any accidents or incidents would be reported to the designated safety officer. During 

construction there is a risk of accidental fires being started by human activities such as refueling heavy 

equipment or the use of vehicles in dry vegetated areas. The Health and Safety Plan will have procedures 

in place to address and restrict the various activities that have a fire-related risk. A fire-suppression 

system will be incorporated into Project design. The Project will implement industry-approved design 

measures to reduce fire-related risks. 
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Waste Management

A Spill Prevention, Control and Countermeasures (SPCC) plan16 has been created for the Project (SSE, 

Dairyland, Burns & McDonnell, 2019). This plan establishes procedures, methods and equipment, and 

other requirements for equipment to prevent the discharge of oil from non-transportation-related onshore 

and offshore facilities into or upon the navigable waters of the United States or adjoining shorelines. 

The oil/water separator will be designed to remove 20 micron and larger oil droplets to concentrations of 

less than 10 ppm. It will be designed to store 1,000 gallons of oil. The oil/water separator will be 

constructed as a double walled buried tank and will have a leak monitor to detect a breech in the inner 

tank wall. The tank will be cathodically protected. Any oil collected will be pumped out as required for 

disposal. 

The Project will have a construction superintendent responsible for oil spill containment and cleanup. The 

construction superintendent will report spills and supervise cleanup and disposal of any contaminated soil 

and spill cleanup materials for any significant volume (defined as 55 gallons or more) of chemicals such 

as lubricants, fuel, grease, or other oil. Diesel and gasoline fuel will be temporarily stored at the Project 

site during construction in aboveground tanks. Preventative measures will be implemented during refueling or transfer of these fuels to reduce the risk of spills. Lubricating oils and certain other industrial 

chemicals required for the project will be stored in specially designed and covered containment areas. 

Also, equipment will be kept in good working condition through routinely inspections and service to 

reduce the risk of leaks of transmission, hydraulic, or brake fluid. Chemical storage areas will be well 

marked and include eye wash stations, first aid kits, safety showers, hose stations, and spill kits with 

absorbent pads and/or material. 

Larger spills will be removed from the containment area using a vacuum tank truck or will be pumped 

into a suitable container for cleanup. Contaminated soil and/or absorbent pads or products used to cleanup 

a spill will be immediately removed, stored, and disposed of in accordance with Wisconsin state 

regulations. Absorbent pads or other manufactured absorbent products will be used to cleanup minor 

spills. These pads and absorbent products will be stored on maintenance trucks and/or in a dedicated 

cabinet that is readily accessible. 

16 The SPCC Plan is available on the PSCW website at: 

http://apps.psc.wi.gov/vs2015/ERF_search/content/searchResult.aspx?UTIL=9698&CASE=CE&SEQ=100&STAR

T=none&END=none&TYPE=none&SERVICE=none&KEY=none&NON=N. PSC Reference No. 357005.
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The oil contaminated gravity drain system collects waste liquid which has the potential of containing 

quantities of oil and conveys the waste through an oil/water separator. Permanent combination safety 

shower/emergency eyewash stations with tepid water conditioning skid will be installed at all battery 

rooms and chemical storage areas including near the aqueous ammonia storage tank and SCR 

vaporization skids.

The Project site will be maintained to contain debris and waste in approved containers and locations. 

Regular trash and waste removal from the site will occur and a recycling program implemented for the 

site. Wastes are anticipated to be removed and disposed of at a local landfill by a local service provider. 

Recycling pickup services are anticipated to be provided by a local disposal company.

5.6 Land Use

During construction, portions of the Project site will be cleared, grubbed, graded, excavated, and 

revegetated. In areas not impacted by these activities, such as riparian vegetation along the Nemadji River 

outside the ROW and areas of the transmission line ROW that do not require clearing, existing vegetation 

will be preserved where practicable. The amount of soil exposed during construction will be minimized. 

Seed mixtures will be selected to produce dense vegetation based on soil and site conditions, along with 

intended final use. In areas were restoration is required, seeding and mulching will be completed in 

accordance with WDNR Technical Standard 1059 – Seeding for Construction Site Erosion Control, 

Chapter DATCP 20, WAC regarding noxious weed seed content and labeling, and Wisconsin Department 

of Transportation (WisDOT) Mix 75 – Erosion Control Native Mix. 

Temporary seeding will be applied to areas of exposed soil where the establishment of vegetation is 

desired, but the areas have not been brought to final grade or on which land-disturbing activities will not 

be performed for a period greater than 30 days, but vegetative cover is required for less than 1 year. Areas 

needing protection during periods when permanent seeding is not applied, must be seeded with annual 

species. 

Final stabilization is achieved when all soil-disturbing activities at the site have been completed and a 

uniform (i.e., evenly distributed, without large bare areas) perennial vegetation cover with a density of 70 

percent of the native background vegetative cover has been established on all unpaved areas or areas not 

covered by permanent structures or with alternative surfacing, such as riprap or crushed rock. 

During construction, areas that have been seeded will be inspected by a qualified person at least once 

every 7 days and within 24 hours after every precipitation event that produces 0.5 inch of rain or more 

during a 24-hour period. Where areas of concern are identified, the area will be re-seeded and watered, 
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and fertilizer will be applied, if applicable. The Project site will be inspected at least once per month to 

monitor vegetative growth until final stabilization is achieved after construction and stabilization 

activities are complete.

The Owners will comply with WAC, Chapter Natural Resources (NR) 40, WAC – Invasive Species 

Identification, Classification and Control during monitoring and management of invasive plant species. 

The Owners will control any prohibited plant species identified onsite during inspection and monitoring 

activities and will minimize the spread of restricted plant species beyond their known boundaries 

throughout the duration of the Project.

In accordance with the Wisconsin DATCP Chapter 20, WAC, seed mixtures that contain potentially 

invasive species or species that may be harmful to native plant communities will be avoided. Seed will be 

tested for purity, germination, and noxious weed seed content, and will meet the minimum requirements 

prescribed in the current edition of Rules for Testing Seed, published by the Association of Official Seed 

Analysts. 

To minimize impacts to agricultural areas, construction of the transmission line will occur after harvest 

and/or before spring planting and be contained within the existing ROW to the greatest extent practicable, 

to reduce the potential for loss of crop production. Outside of winter months, matting will be used in wet 

areas to spread out heavy vehicle loads and minimize soil disturbance.

The Owners will coordinate the proper construction signage near recreation area access points on the 

roads used by construction vehicles for the Project to make drivers aware of the increased hazards 

associated with the construction vehicle(s) presence.

5.7 Noise 

Within twelve months of the date when the project is fully operational, and within two weeks of the 

anniversary date of the pre-construction ambient noise measurements, sound level measurements will be 

repeated both with and without the Project in operation to verify noise levels do not exceed contractually 

guaranteed levels, as well as EPA guideline levels. Sound measurements will be taken at the same 

measurement points that were analyzed for the ambient measurements. The Owners will provide notice to 

nearby residents of expected timeframes for steam blow operation.
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5.8 Socioeconomics and Environmental Justice

Construction activities will primarily be scheduled between the hours of 7:00 a.m. and 10:00 p.m. to 

minimize noise impacts to nearby residences. The Owners will provide notice to nearby residents of 

expected timeframes for steam blow operation.

The Owners do not anticipate permanent damage to roads. As a precautionary measure, the Owners will 

video-document the condition of all roads on the construction vehicle routes to document the road 

condition prior to the start of construction. Any documented adverse impacts to the roads incurred due to

the construction of the Project will be addressed through consultation with applicable road authorities 

regarding the Owners’ responsibility for repairing the adversely impacted roads. 

The Owners will coordinate the proper construction signage on the roads used by construction vehicles 

for the Project to make drivers aware of the increased hazards associated with the construction vehicle(s) 

presence.

Contractors will be chosen from a competitive bid process and will be local whenever practical. Local 

materials such as concrete, lumber, and general hardware may be purchased from local businesses.

5.9 Visual Resources

Building entrances will be illuminated with fixtures mounted directly above doors. Outdoor light fixtures 

will be fully shielded and directed downward to minimize light visible from adjacent properties and to 

reduce glare in the area. Any floodlights required for the operation of the Project will be directed inward 

towards the facility and will have top and side shields.

Cleared ROW would be revegetated as soon as practicable as described in Section 3.2.3.5. Existing 

vegetation outside the plant footprint, ROW, switching station areas, and laydown yards will be left intact 

to reduce visibility of the Project and provide screening. During construction, work areas would be 

maintained in an orderly manner and trash and construction debris removed to help avoid unsightly areas. 

All disturbed areas would be restored as soon as practicable. Disturbance would be limited to those areas 

necessary for construction, limiting clearing and ground disturbance.

5.10 Water Resources

Minimization efforts will be utilized to the extent practical where wetland impacts are unavoidable. 

Construction activities will be prioritized during winter months to take advantage of ground freeze and
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use of ice roads to limit ground disturbance. Outside of winter months, matting will be used in wetland 

areas to spread out heavy vehicle loads and minimize soil disturbance. Additionally, tracked vehicles will 

be used to the extent practical to further spread out vehicle loads throughout wetland area with matting.

Existing site entrances will be used to the extent practical to reduce the number of new roadside and 

wetland crossings required for construction vehicles to access the site. BMPs outlined in the SWPPP will 

be used to avoid and minimize stormwater sedimentation and disturbance within wetland areas.

The Sites will be designed to avoid and minimize temporary and permanent impacts to waterways. The 

post-construction storm water management facilities would be designed to meet the performance 

standards addressed in NR 151.

To the extent practicable, off-ROW access roads eliminate the need to cross wide waterways during 

construction. For smaller intermittent and ephemeral waterways within the ROW, temporary 

prefabricated span bridges will be used to span waterways. Following the removal of all temporary 

bridges, contours will be regraded to pre-construction conditions as needed. 

A Spill Prevention, Control and Countermeasures (SPCC) plan has been created for the Project. This plan 

establishes procedures, methods and equipment, and other requirements for equipment to prevent the 

discharge of oil from non-transportation-related onshore and offshore facilities into or upon the navigable 

waters of the United States or adjoining shorelines. The equipment at the site is outside the 100-year and 

500-year floodplain. 

The wetlands and waterways WDNR permit application materials were submitted on December 18, 2018. 

The USACE Section 401 and 404 permit application is anticipated to be submitted in Spring 2020. The 

Owners will provide the USACE with wetland permit information throughout the CPCN application 

process. The Owners will comply with permit application requirements for wetlands and waterways.
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6.0 COORDINATION, CONSULTATION, AND CORRESPONDENCE

This chapter describes the public outreach for the Project as well as the coordination, consultation, and 

correspondence with Federal, tribal, state, and local agencies.

6.1 Public Involvement

The Owners developed a communication plan to inform the public about the Project and to request 

feedback from stakeholders. The ongoing communication efforts include:

• Establishing and updating a website (http://www.nemadjitrailenergycenter.com/) 

• Issuing news information to media outlets

• Holding public meetings related to the Project

• Providing regular updates to public officials and area legislators

The RUS formal scoping meeting was held on September 21, 2017, at the Elks Lodge in Superior in 

Douglas County, WI. A legal notice and a paid advertisement were placed in the Superior Telegram with 

distribution in the Study Area announcing the Public Scoping Meeting. The legal notice and paid 

advertisement ran three times prior to the meeting (September 12, 15, and 19). Mailing information was 

obtained from current county tax parcel records. Landowners who own parcels within one mile of the 

Project were identified and mailed a postcard on September 14, 2017, inviting them to the meeting. It also 

included anyone that attended a previous stakeholder workshop or open house. A total of 13 people 

attended the scoping meeting. 

In addition to the RUS formal scoping meeting, a stakeholder meeting was held in Superior, Wisconsin, 

on July 13, 2017, providing an opportunity for various leaders in the community to learn more about the 

Project. The meeting consisted of open house style presentations by SSE and Dairyland Power 

Cooperative staff about the NTEC Project, a mapping exercise, and a question and answer portion. Also, 

three open houses were held for the Project. On September 7, 2017, two open houses were held at the 

Elks Lodge in the City of Superior and on November 12, 2018, an additional open house was held at the 

Belgian Club in the City of Superior. The meetings were a similar format to the RUS formal scoping 

meeting held for the Project. 

A total of 109 people attended the three open houses. Table 6-1 provides a breakout of attendance by 

open house day and time along with the number of comment forms submitted during each open house. 
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Table 6-1: Open House and RUS Formal Scoping Meeting Attendance

Meeting Type Date Time

Attendees 

(no.)

Comment 

Forms (no.)

Open House Thursday, September 7, 

2017

11:00 am – 1:00 

pm

44 9

Open House Thursday, September 7, 

2017

5:00 pm – 7:00 

pm

19 5

Open House November 12, 2018 4:00 pm – 7:00 

pm

46 7

Total 109 21

RUS Formal 

Scoping 

Meeting

Thursday, September 21, 

2017

4:00 pm – 7:00 

pm

13 2

The following table provides a summary of comments received during public open houses and meetings.

A summary of public involvement and stakeholder materials is provided in Appendix H.

Table 6-2: Summary of Comments by Topic

Topic Number of Comments

Air quality 3

Geology 1

Land Value Impacts 2

Noise 1

Public health and safety 1

Public involvement 5

Socioeconomics and job opportunities 9

Transportation 3

Vegetation 1

Water resources 3

6.2 Agency Consultation

Letters or postcards were sent to agencies to inform agency contacts of the stakeholder meeting, three 

open house meetings, and the RUS formal scoping meeting. The meetings provided agencies and the 

general public with information on the Project as well as an opportunity to ask questions and provide 

initial feedback. Agency correspondence is provided in Appendix A. Table 6-3 provides a list of agencies 

invited to each meeting.
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Table 6-3: Open House and RUS Formal Scoping Meeting Attendance

Meeting Date(s)

Agencies Invited

Federal

Agencies Invited 

State

Agencies Invited 

Local

Stakeholder 

Meeting 7/13/17

• U.S. Army Corps of 

Engineers 

• Office of Congressman 

Sean Duffy

• Office of U.S. Senator Ron 

Johnson

• Office of U.S. Senator 

Tammy Baldwin

• Wisconsin Department of 

Natural Resources

• Wisconsin Department of 

Administration

• Wisconsin Indianhead 

Technical College (WITC) –

Superior

• Wisconsin State Assembly

• Wisconsin State Senate

• City of Superior

• Douglas County

• Richard I. Bong Airport

• Superior School District

• Sky Harbor Regional Airport

• Superior Chamber of Commerce

• University of Wisconsin – Superior

Open 

Houses and 

RUS 

Scoping 

Meeting

Open 

Houses:

7/7/17

11/12/18

RUS 

Meeting: 

7/21/17

• Federal Aviation 

Administration

• Office of Congressman 

Sean Duffy

• Office of U.S. Senator Ron 

Johnson

• Office of U.S. Senator 

Tammy Baldwin

• Rural Utilities Service

• U.S. Army Corps of 

Engineers

• U.S. Fish and Wildlife 

Service

• Public Service Commission 

of Wisconsin

• State of Wisconsin Armory

• Wisconsin Department of 

Administration

• Wisconsin Department of 

Natural Resources

• Wisconsin Department of 

Transportation

• Wisconsin State Assembly

• Wisconsin State Senate

• Douglas County Highway Department

• Housing Development Corp of 

Superior, Wisconsin

• City of Superior

• Douglas County

• Parkland Sanitary District No. 1

• Richard I. Bong Airport

• School District of Superior

• Sky Harbor Regional Airport

• Superior Chamber of Commerce

• Superior Housing Authority

• Superior School District

• Town of Parkland

• University of Wisconsin – Superior

• WITC – Superior
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6.2.1 Federal Agency Coordination

The following sections provide details about specific Federal agency coordination and correspondence, as 

well as a list of Federal permits required for the Project.

6.2.1.1 FAA

The Owners initially consulted with the WisDOT Bureau of Aeronautics and the City of Superior 

regarding Project structure heights. The WisDOT Bureau of Aeronautics indicated that Project structures 

were under the authority of the City of Superior since the Project was located within City limits. The City 

of Superior stated that the FAA determinations were sufficient for their purposes and the City would not 

require additional tall structure permits. 

Any structure (including permanent structures and temporary construction equipment) on the Project site 

that exceeds 200 feet above ground level in height would be considered an obstruction to navigable 

airspace and could impact aircraft safety unless it is marked and lighted in accordance with criteria set 

forth by the FAA. A Determination of No Hazard to Air Navigation was issued by the FAA on October 3, 

2017, after stack height limitations were agreed to by the Owners. The general contractor would be 

responsible for filing pre-construction notification for the temporary cranes. 

6.2.1.2 USFWS

The USFWS Information for Planning and Consultation (IPaC) on-line tool was reviewed for information 

on potential threatened and endangered species and other sensitive resources to be included and discussed 

in the previous sections on Project- related impacts (IPaC results are included in Appendix B). 

Additionally, the Owners and their contractors (on behalf of the Owners) have had telephone meetings 

with the USFWS (as well as WDNR and PSCW) where potential impacts to state- and federally listed 

species were discussed. USFWS was also invited to the three open houses for the Project as well as the 

RUS formal scoping meeting. RUS initiated consultation with USFWS under Section 7 of the Endangered 

Species Act and prepared a Biological Assessment. The Biological Assessment was submitted for 

USFWS review and concurrence on June 24, 2020. The USFWS concurred with the Biological 

Assessment on September 2, 2020, indicating potential impacts to the northern long-eared bat would be 

covered under the January 5, 2016, Programmatic Biological Opinion on Final 4(d) Rule for the Northern 

long-eared Bat and Activities Excepted from Take Prohibitions. USFWS determined the project would 

have no impacts to other identified species (Appendix B).
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6.2.1.3 USACE

USACE was sent a wetland delineation report to review in preparation for PSCW decision. The Owners 

will provide the USACE with wetland permit information throughout the CPCN application process. An 

Individual Permit application was sent to the USACE on March 31 for the NTEC 625-megawatt (MW) 

gas turbine generation facility, natural gas supply pipeline, and 345-kilovolt transmission line, new 

switching station, staging areas, and laydown yards. Pre-construction notification was sent to the USACE 

on March 31 for the 10-inch natural gas pipeline relocation for Section 404 permit coverage under the 

Utility Regional General Permit. Pre-construction notification was sent to the USACE on March 31 for 

the transmission line relocation for Section 404 permit coverage under the Utility Regional General 

Permit and authorization under Section 10 of the Rivers and harbors Act. The USACE published these 

applications for 30-day public review and comment on September 14, 2020 (Appendix G). The Owners 

will comply with permit application requirements for wetlands and waterways.

6.2.1.4 Federal Permitting

Table 6-4 provides the Federal permits and approvals required for the Project.

Table 6-4: Federal Permits and Approvals

Agency Planned Activity Type of Approval Status

FAA1

Construction or alteration of 

structures more than 200 feet 

above ground level.

7460 Notice of Proposed 

Construction or Alteration (14 Code 

of Federal Regulations S77.13)

Submitted 2018. 

Extension request 

letters submitted in 

April 2019.

USFWS2 Various land disturbance 

construction activities

Endangered Species Act and National 

Bald Eagle Management Guidelines 

Guidelines to be 

followed

USACE3

Discharge of dredged or fill 

material into waters of the U.S.

Clean Water Act - Section 404 

Permit

USACE reviewing 

wetland delineation 

reports and processing 

Permit Applications

USEPA4

Storage of petroleum products Spill Prevention, Control and 

Countermeasures Plan and Facility 

Response Plan (40 CFR 112)

To be implemented and 

kept on site.

1FAA – Federal Aviation Administration

2USFWS – U.S. Fish and Wildlife Service

3USACE – U.S. Army Corps of Engineers

4USEPA – U.S. Environmental Protection Agency
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6.2.2 Tribal Coordination

On August 11, 2017, letters that provided preliminary Project details were mailed by the Owners to the 

Red Cliff Band of Chippewa, Bad River Bands of Chippewa, and the Fond du Lac Band of Lake Superior 

Chippewa (Appendix C). In addition to providing preliminary Project details, the letters invited the tribes 

to participate with the Owners in the pre-filing process and requested feedback regarding cultural 

resources in the APE. The letters included an invitation to a public meeting held on September 7, 2017.

Advertisements were run in the paper for the open house on September 1 and 5, 2017. On August 16, 

2017, the Owners met with the Fond du Lac Band of Lake Superior Chippewa to discuss the Project. On 

August 21, 2017, the Owners met with Red Cliff and Bad River Bands of Chippewa (separately) to 

discuss the Project. The Owners met with the Lac Courte Oreilles Band on January 8, 2019. The Owners 

also reached out to the St. Croix and Forest County Potawatomi Bands, but have not yet received a reply. 

Jill Hoppe, Tribal Historic Preservation Officer for the Fond du Lac Band of Lake Superior Chippewa, 

sent the Owners an image of approximate locations of some cultural sites from their cultural database. 

Three of the locations fall within the Project Study Area and two are adjacent to the APE but outside of it. 

A letter was sent to tribal contacts on June 11, 2019, in regard to the SHPO concurrence that the Project 

would have no impact on historic properties. This letter was sent to the St. Croix Chippewa Community, 

Lac Courte Oreilles Band of Lake Superior Chippewa, Bad River Bands of Lake Superior Chippewa,

Forest County Potawatomi Community, and Red Cliff Band of Chippewa. A letter was given to the Fond 

du Lac Band of Lake Superior Chippewa during a meeting on August 5, 2019. The letter requested 

responses be sent within 30 days. No responses were received. The Fond du Lac Band of Lake Superior 

Chippewa discussed potential monitoring options during construction at the August 5, 2019, meeting. The 

group planned to send SSE a proposal by September 9, 2019. 

By letter dated March 16, 2020, the following additional Tribes were contacted in regard to the SHPO 

concurrence that the Project would have no impact on historic properties:

• Fort Belknap Indian Community – Fort Belknap Reservation of Montana

• White Earth Band of the Minnesota Chippewa Tribe

• Lac Vieux Desert Band of Lake Superior Chippewa Indians of Michigan

• Lac du Flambeau Band of Lake Superior Chippewa Indians – Lac du Flambeau Reservation of 

Wisconsin

• Lac Courte Oreilles Band of Lake Superior Chippewa Indians – Wisconsin

• Menominee Indian Tribe of Wisconsin

• Grand Portage Band of the Minnesota Chippewa Tribe 
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• Keweenaw Bay Indian Community – Michigan

• St. Croix Chippewa Indians of Wisconsin

• Minnesota Chippewa Tribe

• Sokaogon Chippewa Community – Wisconsin

• Mille Lacs Band of Ojibwe (Mille Lacs Band of the Minnesota Chippewa Tribe Mille Lacs Band 

of Ojibwe)

• Leech Lake Band of the Minnesota Chippewa Tribe

• Miami Tribe of Oklahoma

• Ho-chunk Nation

• Stockbridge-Munsee Community Band of Mohican Indians

• Oneida Nation of Wisconsin

No responses have yet been received.

6.2.3 State Agency Coordination

The following sections provide details about specific State agency coordination and correspondence, as 

well as a list of state permits required for the Project.

6.2.3.1 DATCP

An agricultural impact notice was sent to the Wisconsin DATCP on December 18, 2018. The DATCP 

determined that an Agricultural Impact Statement is not required as the Project does not cross private 

agricultural land. The agricultural land crossed by the Project transmission line is owned by Douglas 

County, Parkland Sanitary District No. 1, and the City of Superior. No impacts are anticipated to 

agricultural lands due to the Project. See Appendix D for correspondence with the Wisconsin DATCP.

6.2.3.2 Wisconsin Legislative Black Caucus

On March 12, 2019, representatives of Dairyland met with representatives of the Wisconsin Legislative 

Black Caucus (Caucus). The Caucus is interested in working with Dairyland and SSE to provide 

opportunities for employment to a diverse workforce, including minorities, women and veterans. 

Dairyland explained the process for Project approval and future actions related to hiring contractors for 

the project. As construction is still some time off, assuming the Project is approved, Dairyland and SSE

will continue to coordinate with the Caucus to understand their concerns and identify opportunities to 

address them.
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6.2.3.3 PSCW

Under Wisconsin Statutes (Wis. Stat.) § 196.491(3) and Wisconsin Administrative (Wis. Admin. Code) 

Code Chapter PSC 111, the Owners submitted two separate CPCN applications to the PSCW for the 

construction of a natural gas electric generation facility and a new 345-kV electric transmission line on 

January 8, 2019. The PSCW provided completeness determinations for both CPCNs on February 15, 

2019. In addition to these CPCN application, two Certificate of Authority (CA) applications were 

submitted by one of the interconnecting utilities to the PSCW on January 8, 2019, under Wisconsin 

Statutes (Wis. Stat.) § 196.49 and Wisconsin Administration (Wis. Admin.) Code § PSC 133.03 to 

construct a new lateral natural gas line from the location of the generation facility to a tap point on the 

Great Lakes Gas Transmission pipeline and to relocate an existing 10-inch SWL&P natural gas line at the 

Nemadji River Site.

On January 31, 2020, the Public Service Commission of Wisconsin (PSCW) issued its final decision on 

the generation facility (Docket Number 9698-CE-100). The Certificate of Public Convenience and 

Necessity (CPCN) application was approved and the PSCW authorized the Nemadji River Site as the 

location for NTEC. On January 30, 2020, the PSCW issued its final decision on the electric transmission 

line for the Project (Docket Number 9698-CE-101). The transmission line CPCN was approved and the 

PSCW authorized the eastern route.

6.2.3.4 WDNR

Multiple permits from the WDNR are required for the Project. The following sections describe 

coordination correspondence with WDNR related to these permits.

6.2.3.4.1 Air Permitting

The Owners and their contractor held two Project pre-application meetings concerning air permitting with 

WDNR on October 18, 2017, and June 7, 2018. Pursuant to the requirements specified in the Wisconsin 

Administrative Code Chapter NR 405, the Owners submitted a PSD construction air permit application on 

December 18, 2018.

A public hearing meeting was held on January 23, 2020, for the air pollution control permit application 

review at the Douglas County Government Center in Superior, Wisconsin. The hearing was coordinated 

by WDNR Air Quality Division responsible for permitting the Project. WDNR presided over the meeting, 

which had approximately 50 to 60 attendees. WDNR outlined the Wisconsin air permitting and comment 

process, described protocol for the public hearing, and provided a brief overview of the Project and the 

draft permits. Sixteen attendees provided oral comments. The 30-day public comment period for the 
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permit ended January 23, 2020 at close of business. In addition to the sixteen oral comments received at 

the public hearing, written and emailed comments were received during the 30-day public comment 

period. The WDNR provided notification of the air permit approval on September 1, 2020 (Appendix A). 

6.2.3.4.2 Pretreatment Program

The WDNR’s Pretreatment Program is a requirement of the Federal Clean Water Act and is administered 

according to the regulations contained in WAC NR 211 and NR 220-297. The City of Superior has 

operated a State-approved Pretreatment Program since 1994 and is a designated “control authority”. 

Therefore, the City of Superior is authorized to issue pretreatment permits to industrial dischargers in 

accordance with Chapter 114, Article II of the City of Superior, Wisconsin Code of Ordinances. Because 

the Project would discharge industrial wastewater to the City’s sewer system and would discharge more 

than 25,000 gallons per day, the Facility is required to obtain an Individual Wastewater Discharge Permit 

from the City of Superior. The Pretreatment Program application materials were submitted to the City of 

Superior on December 18, 2018.

6.2.3.4.3 Protected Species

The Owners and their contractors (on behalf of the Owners) have had telephone meetings with the 

WDNR (as well as the PSCW and USFWS) where potential impacts to state- and federally listed species 

were discussed. In addition, contractors (on behalf of the Owners) discussed potential species issues with 

the WDNR via email and telephone conversations. An Environmental Resource Review (ER Review) was 

completed for each Project component and submitted to the WDNR for review and approval. The final 

ER Review was submitted with the CPCN applications. 

6.2.3.4.4 Wetlands and Waterways

The wetlands and waterways WDNR permit application materials were submitted on December 18, 2018. 

The Owners provided the USACE with wetland permit information throughout the CPCN application 

process. USACE was sent a wetland delineation report to review in preparation for PSCW decision. An 

Individual Permit application was sent to the USACE on March 31 for the NTEC 625-megawatt (MW) 

gas turbine generation facility, natural gas supply pipeline, and 345-kilovolt transmission line, new 

switching station, staging areas, and laydown yards. Pre-construction notification was sent to the USACE 

on March 31 for the 10-inch natural gas pipeline relocation for Section 404 permit coverage under the 

Utility Regional General Permit. Pre-construction notification was sent to the USACE on March 31 for 

the transmission line relocation for Section 404 permit coverage under the Utility Regional General 

Permit and authorization under Section 10 of the Rivers and harbors Act. The USACE published these 
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applications for 30-day public review and comment on September 14, 2020 (Appendix G). The Owners 

will comply with permit application requirements for wetlands and waterways.

6.2.3.4.5 WPDES

In the State of Wisconsin, projects that will disturb one or more acres of land must obtain coverage under 

the WPDES General Permit No. WI-S067831-5 (WPDES General Permit), which authorizes the 

discharge of storm water associated with land-disturbing construction activities into State waters. 

Coverage under the WPDES General Permit is obtained by developing Erosion Control and Storm Water 

Management Plan (SWMP) and submitting a Water Resources Application for Project Permits 

(WRAPP)17 to the WDNR for approval prior to the start of Project construction. For this Project, the 

Erosion Control Plan and SWMP were written as a single document. The WRAPP documents were 

submitted to WDNR on January 8, 2019. Once final Project design is complete, the Erosion Control Plan 

and SWMP will be submitted to WDNR.

6.2.3.5 WisDOT

See Section 6.2.1.1 for a discussion of coordination with the WisDOT Bureau of Aeronautics.

6.2.3.6 Wisconsin Historical Society

The WHS provides several functions in support of cultural resources studies for Projects in Wisconsin. 

The WHS curates and distributes previously reported cultural resources archaeological sites, architectural 

resources, and studies. It also issues the Wisconsin Public Lands Field Archaeological Permit for cultural 

resource studies on state-owned lands, reviews and processes newly recorded site data, and reviews 

Projects for section 106 compliance. The Owners have consulted with WHS on each of these four aspects 

of the Project: (1) record retrieval; (2) state permit acquisition, (3) new site recordation, and (4) section 

106 report review. The Owners requested and received cultural datasets from WHS on three separate 

occasions: September 12, 2016; October 10, 2017; and December 8, 2018. WHS signed the state permit 

(Number 17-130) for this Project in October 2017. The Owner filed five new sites with the WHS in 

October 2017 and WHS accepted the sites in November 2017. RUS filed the cultural resources report for 

Section 106 review on February 4, 2019. On March 14, 2019, DPC received SHPO concurrence that no 

historic properties will be affected by the Project.

17 A WRAPP is also referred to as a Notice of Intent. 
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6.2.3.7 State Permitting

Table 6-5 provides the state permits and approvals required for the Project. The table includes permits 

that are related to the overall NTEC Project, including permits that are the responsibility of entities other 

than the Owners.

Table 6-5: State Permits and Approvals

Agency Planned Activity Type of Approval Status

PSCW1,2

Building and operating 

generating units and 345-kV 

transmission line

Certificate of Public 

Convenience and Necessity 

(Wis. Stat. §196.491(3))

Submitted

January 8, 2019

Completeness 

determination 

February 15, 2018

Approved January 

30, 2020

PSCW1,2

Relocation of the existing 10-

inch gas pipeline currently 

located on the Nemadji River 

Site

Certificate of Authority 

(Wis. Stat. § 196.49)

Submitted

January 8, 2019. 

Approved March 3, 

2020.

PSCW1,2

Construction of 16-inch 

pipeline to serve Project

Certificate of Authority 

(Wis. Stat. § 196.49)

Submitted

January 8, 2019. 

Approved March 3, 

2020.

PSCW1,2

Relocation of existing 

transmission assets currently 

located on the Nemadji River 

Site

Affiliated Interest 

Agreement approval of 

agreement between SWL&P 

and its affiliate SSE (Wis. 

Stat. § 196.52)

Filing date TBD

PSCW1,2

Relocation of existing 10-inch 

gas pipeline currently located 

on Nemadji River Site

Affiliated Interest 

Agreement approval of 

agreement between SWL&P 

and its affiliate SSE (Wis. 

Stat. § 196.52)

Filing date TBD

PSCW1,2

Construction of 16-inch 

pipeline to serve Project

Affiliated Interest 

Agreement approval of 

Development Agreement 

between SWL&P and its 

affiliate SSE (Wis. Stat. § 

196.52)

Approved in Docket 

No. 5820-AG-100 

on May 7, 2018

PSCW1,2

Construction of 16-inch 

pipeline to serve Project

Affiliated Interest 

Agreement approval of 

Construction and Service 

Agreement between SWL&P 

and its affiliate SSE (Wis. 

Stat. § 196.52)

Filing date TBD
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Agency Planned Activity Type of Approval Status

WDNR3

Construction and operation of 

new source of air emissions

Construction and operating 

permits: (Wis. Admin. Code 

NR 405 through 407, 40, 

CFR Part 52.21), and acid 

rain permit (40 CFR Part 75 

and NR 409)

PSD (NR 405 and 

40 CFR Part 52.21) 

submitted 

December 18, 2018

NR 406 

(Construction 

Permits), NR 407 

(Operation 

Permits), and acid 

rain permit (40 CFR 

Part 75 and NR 

409) TBD

Public hearing for 

air pollution control 

permit January 23, 

2020

Approved 

September 1, 2020

WDNR3

Erosion control and storm 

water management for land 

disturbance during construction

Construction site storm 

water discharge permit

(Wis. Admin. Code NR 216)

Submitted 

December 18, 2018

WDNR3

Hydrostatic test water for water 

supply system water

Wis. Stat. § 283 Submitted 

December 18, 2018;

Approved

WDNR3 Nontransient Noncommunity 

Public Water System

Public Water Supply (NR 

809 and NR 810)

TBD

WDNR3

Operational storm water 

pollution prevention plan

Industrial storm water 

discharge permit

(Wis. Admin. Code NR 216)

Submitted 

December 18, 2018

WDNR3

Various land disturbance 

construction activities

Potential impact to Federal 

and state threatened and 

endangered species

Guidelines to be 

followed

WDNR3

Placement of structure within a 

waterway; placing [temporary] 

bridges over navigable 

waterway

Wis. Stat. Chapter 30 

(Navigable Waters, Harbors 

and Navigation) Permit: 

Wis. Stat. §§ 30.12 and 

30.123 and Wis. Admin. 

Code NR 320

USACE reviewing 

wetland delineation 

reports and 

processing Permit 

Applications

WDNR3

Required for issuance of 

USACE Section 404/10 

permits unless waived by 

WDNR

Section 401 Water Quality 

Certification (Application 

for Wetland Water Quality 

Certification, Form 3500-

53N)

USACE reviewing 

wetland delineation 

reports and 

processing Permit 

Applications
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Agency Planned Activity Type of Approval Status

WDNR3

Invasive Species management 

for land disturbance during 

construction

Chapter NR 40 Invasive 

Species Identification, 

Classification and Control 

(Ch. NR 40, Wis. Adm. 

Code)

Guidelines to be 

followed

Wisconsin 

Department 

of Safety 

And 

Professional 

Services

Construction of all buildings 

and structures

Approval of plans and 

specifications (Wis. Stat. § 

101.02)

To be filed

Wisconsin 

Department 

of Safety 

And 

Professional 

Services

Installation of fuel or 

lubricating oil storage tanks

Approval of plans and 

specifications (Wis. Stat. § 

101.09)

To be filed

Wisconsin 

Department 

of Safety 

And

Professional 

Services

Installation of dust filtering and 

HVAC equipment

Approval of plans and 

specifications (Wis. Stat. § 

101.12)

To be filed

Wisconsin 

Department 

of Safety 

And 

Professional 

Services

Installation and registration of 

boilers, pressure vessels, and 

power piping

Machines and boilers, safety 

requirements (Wis. Stat. 

101.17)

To be filed

WisDOT4 Delivery of equipment to the 

construction site

Oversized Equipment 

Delivery Permit

To be filed

Wisconsin 

Historical 

Society

Site preparation and grading Approval of archaeological 

surveys (Wis. Stat. § 44.40) 

and Section 106 Cultural 

Resources Clearance

Filed with CPCN 

Application

1PSCW – Public Service Commission of Wisconsin

2Other PSCW Dockets filed for the NTEC Project: Docket Number 9698-CE-101, Docket Number 5820-CG-105, 

and Docket Number 5820-CF-106

3WDNR – Wisconsin Department of Natural Resources

4WisDOT – Wisconsin Department of Transportation

6.2.4 Local Coordination

The City of Superior, Douglas County, local airport officials, the Superior School District, Superior 

Chamber of Commerce, and University of Wisconsin – Superior were invited to the stakeholder meeting 

on July 13, 2017. These agencies and organizations were also invited to the open houses and RUS formal 
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Rural Utilities Service 6-14 Burns & McDonnell

scoping meeting, as well as the Douglas County Highway Department, the Housing Development Corp of 

Superior, Parkland Sanitary District No. 1, Superior Housing Authority, Town of Parkland, and WITC –

Superior (see Section 6.2). The City of Superior provided GIS data to the Project team, including 

elevation, imagery, recreational areas, transportation data, and utility locations. 

Table 6-6 below provides a preliminary list of the local permits and regulatory approvals anticipated for 

the Project. 

Table 6-6: Anticipated Local Permits and Approvals

Agency Planned Activity Type of Approval Status

Douglas 

County

Delivery of large/heavy 

components over countycontrolled roads

Heavy Haul/Oversized Load permits, as 

authorized by Wis. Stats. §§ 348.25-

348.28; Douglas County Highway 

Department 2018 Weight Limits

TBD

City of 

Superior

Construction of facilities Building, electrical, and plumbing 

permits, Superior Code of Ordinances 

Chapter 34 (Construction Code) 

TBD

City of 

Superior

Delivery of large/heavy 

components over Citycontrolled roads

Heavy Haul/Oversized Load permits, as 

authorized by Wis. Stats. §§ 348.25-

348.28, Superior Code Chapter 112 

Section 112-33 (Heavy traffic [truck] 

route)

TBD

City of 

Superior

Pretreatment permit for 

discharge of wastewater to 

a municipal treatment 

facility

WPDES1 permit

(City of Superior is an authorized control 

authority for permit; Wis. Admin Code 

NR 108, 211 and 220-297)

TBD

1WPDES – Wisconsin Pollutant Discharge Elimination System 

6.3 Locations for Public Review of EA

A Notice of Availability was published in the Superior Telegram which informed the public of the 

availability of this EA and the 30-day public comment period from October 30th to November 30th,

2020. Table 6-7 provides a list of libraries that received the EA for public review.18 These libraries also 

received copies of the PSCW CPCN applications. The EA was also made available online.19

18 Due to the COVID-19 pandemic, it is advised that anyone wishing to view the EA at a public library contact 

library staff prior to arrival to confirm hours, availability of the EA materials, and schedule an appointment, if 

necessary. 

19 A copy of the EA may be viewed online at the following websites: Rural Utilities Service at 

http://www.rd.usda.gov/resources/environmental-studies/assessments/ project name, on the Dairyland Power 

Cooperative website at https://www.dairylandpower.com/NTEC/EA, and the project website at 

http://www.nemadjitrailenergycenter.com/resources.html.
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Table 6-7: List of Library Locations

Library Address and Phone Number

Superior Public Library

1530 Tower Avenue

Superior, WI 54880

(715) 394-8860

Jim Dan Hill Library

University of Wisconsin – Superior

907 N. 19th Street

Superior, WI 54880

(715) 394-8343

La Crosse Public Library

800 Main Street

La Crosse, WI 54601

(608) 789-7100

Murphy Library Resource Center

University of Wisconsin – La Crosse

1631 Pine Street

La Crosse, WI 54601

(608) 785-8505
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7.0 REFERENCES

CEQ (Council on Environmental Quality) 1997. Considering Cumulative Effects Under the National 

Environmental Policy Act. January. Accessed January 2019 at: 

https://www.energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/G-CEQConsidCumulEffects.pdf.

EPA. (2018b). EJSCREEN: Environmental Justice Screening and Mapping Tool. Retrieved 19 December 

2018 from https://www.epa.gov/ejscreen.

EPA. 2019. Geospatial Data Download Service – FRS KMZ. Retrieved 2-4-19 from: 

https://www.epa.gov/enviro/geospatial-data-download-service

Federal Register. 2013. General Provisions; Revised List of Migratory Birds, Federal Register Vol.78 

No.212, 65844-65864 [pdf] Washington D.C.: Department of the Interior, Fish and Wildlife 

Service Available at: https://www.fws.gov/migratorybirds/pdf/policies-andregulations/MBTAListofBirdsFinalRule.pdf [Accessed 2 December 2018]

Federal Register. 2016. Endangered and Threatened Wildlife and Plants; 4(d) Rule for the Northern LongEared Bat, Federal Register Vol.81 No.9, 1900-1922 [pdf] Washington D.C.: Department of the 

Interior, Fish and Wildlife Service. Available at: 

https://www.fws.gov/midwest/endangered/mammals/nleb/pdf/FRnlebFinal4dRule14Jan2016.pdf 

[Accessed 2 December 2018]

Gottsfield et al. 2019. Phase I Cultural Resources Survey Report for the Nemadji Trail Energy Center

Project, Douglas County, Wisconsin. Burns & McDonnell Engineering Company, Inc. 

International Commission on Non-Ionizing Radiation Protection. (2010). ICNIRP Guidelines for limiting 

exposure to time-varying Electric and Magnetic Fields (1 Hz – 100 kHz). Retrieved 19 November 

2018 from https://www.icnirp.org/cms/upload/publications/ICNIRPLFgdl.pdf

National Institute of Environmental Health. (2002). Electric and Magnetic Fields Associated with the Use 

of Electric Power. Downloaded 19 November 2018 from 

https://www.niehs.nih.gov/health/materials/electric_and_magnetic_fields_associated_with_the_u

se_of_electric_power_questions_and_answers_english_508.pdf

PSCW. 2017. EMF – Electric & Magnetic Fields. Downloaded March 2019 from 

https://psc.wi.gov/Pages/ForConsumers/EMF.aspx.

South Shore Energy, LLC, Dairyland Power Cooperative, Burns & McDonnell Engineering Company, 

Inc. 2019a. Application for Certificate of Public Convenience and Necessity for the Nemadji 

Trail Energy Center Combined Cycle Project. Submitted to the PSCW January 2019. Available 

at: 

http://apps.psc.wi.gov/vs2015/ERF_search/content/searchResult.aspx?UTIL=9698&CASE=CE&

SEQ=100&START=none&END=none&TYPE=none&SERVICE=none&KEY=none&NON=N.

South Shore Energy, LLC, Dairyland Power Cooperative, Burns & McDonnell Engineering Company, 

Inc. 2019b. Application for Certificate of Public Convenience and Necessity for the Nemadji 

Trail Energy Center. Submitted to the PSCW January 2019. Available at: 
Nemadji Trail Energy Center References

Rural Utilities Service 7-2 Burns & McDonnell

http://apps.psc.wi.gov/vs2015/ERF_search/content/searchResult.aspx?UTIL=9698&CASE=CE&

SEQ=101&START=none&END=none&TYPE=none&SERVICE=none&KEY=none&NON=N

U.S. Census Bureau (USCB). (2017). 2013-2017 American Community Survey 5-Year Estimates.

Retrieved 19 December 2018 from https://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml.

U.S. Census Bureau (USCB). (2010). 2010 Decennial Census. Retrieved 19 December 2018 from 

https://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml.

U.S. Census Bureau (USCB). (2000). 2000 Decennial Census. Retrieved 19 December 2018 from 

https://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml.

U.S. Department of Agriculture (USDA). (2012). NSSH Part 622. Retrieved 5 December 2017 from 

https://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/survey/tools/?cid=nrcs142p2_054226

U.S. Department of Agriculture (2018) Primary Nesting Season Dates and Durations. [pdf] U.S. 

Department of Agriculture, Farm Service Agency. Available at: 

https://www.fsa.usda.gov/Assets/USDA-FSA-Public/usdafiles/Conservation/PDF/MAPPrimary%20Nesting%20Season_5_10_2018.pdf [Accessed 11 March 2019]

U.S. Fish and Wildlife Service. 2015. Northern Long-Eared Bat Myotis septentrionalis. [pdf] U.S. Fish 

and Wildlife Service. Available at: 

https://www.fws.gov/Midwest/endangered/mammals/nleb/pdf/NLEBFactSheet01April2015.pdf 

[Accessed 2 December 2018]

USFWS. (2018). Information for Planning and Consultation. Accessed 26 September 2018 from

https://ecos.fws.gov/ipac/. 

WDNR. 2019a. Wildlife and Your Land. Available at 

https://dnr.wi.gov/files/PDF/pubs/wm/WM0244.pdf. Accessed January 7, 2019.

WDNR. 2019b. Water Condition Viewer. Retrieved February 2019 from 

https://dnrgis.wi.gov/H5/?viewer=Water_Condition_Viewer.

WDNR 2010. Wisconsin's Statewide Forest Action Plan 2010, Part 1: Statewide Forest Assessment, 

Appendix B: Cultural History of Wisconsin’s Forests. Available at 

https://dnr.wi.gov/topic/ForestPlanning/documents/AppendixB_100721.pdf. Accessed January 7, 

2019.

Weidman, S. and A. Schultz. (1913). The Underground and Surface Water Supplies of Wisconsin. 

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Nemadji Trail Energy Center List of Preparers

Rural Utilities Service 8-1 Burns & McDonnell

8.0 LIST OF PREPARERS

The environmental review for the Project was prepared by Burns & McDonnell under the direction of 

RUS and Dairyland Power Cooperative. The following is a list of preparers of this document.

RUS

• Dennis Rankin

• Lauren Cusick

• Kenneth Solano

• Owen Edoohonba

Dairyland Power Cooperative

• Brad Foss, Manager, Environmental Impact

• Ron Franz, Manager, Wholesale Services

Burns & McDonnell

• Steve Thornhill, Project Manager

• Molly Hughes, Environmental Scientist

• Kate Samuelson, Environmental Scientist

• Tyler Beemer, PWS, Senior Wetland Scientist

• Minda Nelson, Environmental Engineer

• Andrew Gottsfield, PhD, RPA

• Brian Roh, Environmental Specialist

• Luca DeAngelis, Geological Engineer