February 12, 2002

Dear Senator Fitzgerald,

Thank you for sending me a copy of the letter that Wisconsin Electric Cooperative Association (WECA) has sent around. Unfortunately, the viewpoint that they express in that letter, while it may not be patently false, is certainly very misleading.

The bill does create an electrical pollution board, makes it unlawful for a utility or electric cooperative to permit a condition whereby any steady state of electric current flows over its ground conductors for more than five seconds, and establishes a 1/20 of a cent per kilowatt hour rate increase for electric power sold in the state for the remediation necessary for the utilities to comply with the new law.

There is some background necessary for you to understand why the provisions of this bill are so important and why the utility industry will so hotly contest them.

First, the electrical rate increase is not a tax. It is customary for the consumer to pay for line maintenance under the current regulatory system. The difference between the small rate increase proposed by Representative Gronemus and the rate increases made by the Public Service Commission (PSC) to cover line maintenance is that the money from this rate increase will be given to the utilities only if they remedy the current flow problems that exist in their system. The PSC has required the utilities to replace 100 miles of line yearly. The consumers are paying for it in their electrical rate. However, the utilities are not required to install neutral lines that are compliant with either the Electrical Power Research Institute (EPRI) or the Institute of Electronics and Electrical Engineers (IEEE) standards for eliminating electrical earth current. If you go out and look at the new wires you will see that, in many cases, the neutral is undersized. I have yet to see a new neutral wire that is any larger than the phase wires. The PSC is still allowing the utilities to charge the fuel cost adjustment ($0.002460 per kWh) dating back to last year when natural gas costs were very high. That is nearly 5 times the rate increase proposed by Representative Gronemus. If the legislature would like to take the fuel cost adjustment fee away when they pass the new rate increase, the consumers will actually experience a rate decrease.

Second, it is possible to safely eliminate current on the grounding rods and therefore eliminate the electrical earth currents. There are isolation devices that prevent current from traveling on the grounding rods under normal conditions, but do allow flow under fault conditions. This would satisfy both the National Electrical Safety Code (NESC) code requirements for not using the earth as a return path and the keep the safety benefits of a grounded system. Representative Gronemus's definition of "objectionable" would not interfere with the safety function of the grounding rods.

The NESC 92D already forbids the use of the earth as a return path. The section of code dealing with the current allowed to flow on the grounding rod reads "Current in grounding conductor: ground connection points shall be so arranged that under normal circumstances there will be no objectionable flow of current over the grounding conductor." Unfortunately, "objectionable" was left undefined, so it is left to the designer's discretion. The assumption was made that the designers would design systems that followed the spirit of the NESC rules. Unfortunately, that loophole has allowed systems to be designed with the best interests of the utilities pocketbooks in mind. It costs more to have a neutral conductor large enough so that all the return current can flow on it. It is cheaper to allow current to flow over the grounding conductors and back to the substation in the earth. In fact, on page 152 of the NESC Handbook Fourth Edition it says, "When earth returns were used in some rural areas prior to the 1960's they became notorious offenders in dairy areas because circulating currents often caused both step and touch potentials." It concludes "these have adversely affected milking operations by shocking the cattle when they were connected to the milking machines, and have affected feeding." These are exactly the issues that modern farmers are complaining about. These concerns were addressed in 1960 by requiring the neutral wire. Today, because we use electricity differently, larger neutrals are required in order to have all the electricity flow back to the substation on the neutral wire. According to the IEEE the neutral return wire needs to be 225% of the size of the phase wires. In most of Wisconsin the neutral wire is half the size of the phase wires. New neutrals are sometimes as large as the phase wires. Obviously, neutral return capacity is not sufficient according to the IEEE standards.

Representative Gronemus's legislation merely codifies the original intent of NESC 92D. Lack of a concrete definition for "objectionable" has allowed the electrical pollution problem to exist for the last 30 years. Consumers had to prove in court that the electricity returning across their land was objectionable, since complaints directly to the utility companies are frequently ignored.

The utilities and the PSC have created a problem called "stray voltage" which is defined as 60 Hz voltage greater than 1 volt between two contact points in an animal confinement area. The PSC has raised the voltage required to meet the definition of "stray voltage" three times since "stray voltage" was invented. It was deliberately defined at the point of animal contact. This makes it impossible for "stray voltage" to cause human health problems and it makes it nearly impossible to pin the problem on a flaw in the utility system. The PSC has also disallowed "stray voltage" measurements that are not made with their approved instrumentation. The approved instrumentation quite deliberately does not include instruments that can measure the presence of high frequencies or "dirty" power. A number of dairy farmers that have problems with electrical ground currents have found that their problems are worse when the electrical ground currents were "dirtier."

The idea that the provisions of Representative Gronemus's legislation are "unwise, unnecessary, unsafe, or all of the above" is preposterous. Her legislation merely codifies the intent of the NESC. EPRI and the IEEE both identify poor power quality, touch potentials, and electrical earth currents as problems. EPRI and the IEEE also describe safe ways to remedy them. It costs money and the utilities do not want to spend it. They have been resisting doing so for nearly 30 years. There is an increasing amount of evidence surfacing that they have known how much damage they are causing by not upgrading their system in accordance with the IEEE standards for much of that time.

Electrical pollution is intimately related to "Radio Wave Sickness." Electrical pollution is high frequencies riding on the 60 Hz sine wave and the associated electrical earth currents. The WECA letter states, "For the most part, utilities do not produce radio waves." True, but the utilities do distribute them. The high frequencies enter the system through a number of agencies related to use of the system. One such source of radio frequencies from utilities is the switching of power factor correction capacitors. Blinking Christmas lights also generate radio frequencies. We are exposed to the high frequencies on our electrical wires 24 hours a day, 7 days a week through capacitive coupling. The same high frequencies that are on those electrical wires travel through our body due to capacitive coupling. We are also exposed to electrical pollution from the electrical earth currents when we do such everyday things as stand on the earth, wash dishes, or shower. Electrical engineers for the utilities will be quite happy to tell you that these exposures are insignificant. The proof, however, is in the pudding. There are an increasing number of people recovering from disabling illness by changing their electrical environment. Many have installed filters that reduce the high frequencies on their wiring and they recover substantially. Further, they get sick again if they go places that have poor power quality. I am one such person. Enclosed you will find a letter from another such person.

The utilities would like you to believe that this legislation is to benefit a few crazy farmers. The reality is quite different. The farmers are not crazy and this legislation will benefit each and every citizen of Wisconsin. California recently passed Wisconsin by as the top producing dairy state. An interesting but little known fact is that California has a different and newer electrical distribution system, so they do not have the same problem with electrical ground currents.

In order for the utilities to meet the standards set in the legislation for objectionable current, the utilities would probably have to clean up the "dirty" power. There are filters that they could install that would do just that, decreasing the necessity for wire upgrades. They are likely to need a combination of filters and larger wires. In the closing paragraph WECA states they "continue to offer assistance programs to farmers who want to improve the wiring on their farms." So, why are they objecting so strenuously to assistance from ratepayers to improve utility owned wires?

This legislation is really about fixing a serious public health threat in Wisconsin. The incidence of Chronic Fatigue Syndrome (CFS) and Fibromyalgia is on the rise. People have recovered remarkably from these illnesses in response to cleaning up the "dirty" power in their homes. The health effects go well beyond CFS and Fibromyalgia. Exposure to high frequencies has been related in the literature to depression, cancer, miscarriages, and birth defects, as well as many other health problems. I think that the citizens of this state will agree that $1.20 a month is a very cheap price to pay for a healthier future. Please continue your support of Representative Gronemus's landmark legislation and help educate the rest of the legislature about the misleading nature of the utilities' claims.

Sincerely,

Catherine Kleiber

Enclosures