October 8, 2001

Dear Mr. Reines,
I have been unable to find any evidence that there has been an increase in the frequency of lightening strikes in WI, as you mentioned had occurred at the July 30, 2001 meeting at the capitol. The state office of climatology says that they only keep track of damage, injury, or death caused by lightening. There has been no increase in these measures over time, in spite of the increase in population. I would like to know what database you used to make the determination that lightening strikes have increased sufficiently to warrant driving additional grounding rods. According to my understanding, an increase in the frequency of lightening strikes alone would not warrant driving additional grounding rods. The simultaneity of the lightening strikes would also have to increase. The old system with reduced grounding was sufficient for handling any one lightening strike, so unless we began to get multiple lightening strikes simultaneously an increase in lightening strikes would not necessitate an increased number of grounding rods. Please let me know where you obtained the data that caused the PSC such concern that they allowed the utilities to put in grounding rods at every pole.

The grounding rods were not installed to provide protection from increased lightening strikes. They were installed to relieve overloading of a primary neutral that was overloaded because it was not sized properly to carry modern loads. Something had to be done because the overloading was causing wires to heat up which in turn increased the likelihood of electrical fires. It was easier and cheaper to relieve the overloading by adding additional grounding rods in 1992 than to rewire with an appropriately sized neutral, as would have been proper. This results in the earth being part of the return path for electrical current. A Minnesota study found that over 70% of the current returns to the substation via the earth in some areas. It is forbidden by the National Electrical Safety Code (NESC) 92D for the earth to be used as the neutral return. 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." They go on to say that "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. How can there be dairy or human health problems due to electricity returning through the earth, since we do have a neutral wire now? In 1957 10,040,180,000 Kilowatt-hours of electricity were sold statewide. In 1992 50,926,000,000 Kilowatt-hours of electricity were sold statewide. Finally, in 2000 64,689,000,000 Kilowatt-hours of electricity were sold statewide. Assuming problems occurred prior to 1960 with a total earth neutral return, all current returning via the earth, 10,040,180,000 Kilowatt-hours of electricity flowing through the earth caused health problems for cattle. Now, assuming that 70% of the electricity returns via the earth in 1992 and 2000, there are 35,648,200,000 and 45,282,300,000 Kilowatt-hours returning through the earth in those years respectively. This means that there is nearly five times as much electricity returning through the earth now than there was in 1957. In order to have as little electricity traveling through the ground as there was in the 1950's only 19.7% of the total kilowatt-hours in 1992 and 15.5% of the total kilowatt-hours sold in the state in 2000 could return through the earth. Even at these levels of earth return, problems are still likely to occur since they did in the 1950's, necessitating the advent of the neutral wire. In effect, what this shows is that in spite of having the wire, we are worse off now than we were in the 1950's when the neutral wire became a requirement.

Please let me know where you obtained the data showing such an increase in the frequency and simultaneity of lightening strikes that it necessitated adding grounding rods at each pole. Please also include how this was justified in light of the fact that it increased the use of the earth as a neutral, thereby increasing animal and human health problems due to direct electrical exposure. As you answer these questions, keep in mind PSC rule 113.0507 subsection 2a. This subsection prohibits utilities from taking "advantage of the lack of knowledge, ability, experience, or capacity of customers". While you are an employee of the PSC, not a utility, the same standard should apply.

Sincerely,

Catherine Kleiber

cc: Ave Bie, Public Service Commission
Mark Cook, Public Service Commission
Jim Loock, Public Service Commission
William Fannucchi, Public Service Commission
Secretary Harsdorf, DATCP
Secretary Phyllis Dube, Health & Family Services
Governor Scott McCallum
DATCP Board
Randy Romanski, Office of the Attorney General
Representative Ward
Representative Gronemous
Representative Petrowski
Senator Fitzgerald
Tom Still, Editor, Wisconsin State Journal
John Nichols, Editor, The Capitol Times
Gil Halsted, Wisconsin Public Radio
Chris Hardie, LaCrosse Tribune
Kurt Gutknecht, WI Agriculturist