PORT WASHINGTON, Wis. - TelAve -- The Responsible Energy Alliance, a citizen coalition ("REA"), filed an expedited motion Monday with the Public Service Commission of Wisconsin ("PSC"), asking the regulatory agency to revoke its December 15, 2025, determination that American Transmission Company's ("ATC") application to build new extra-high-voltage transmission lines through ecologically sensitive greenfields in western Ozaukee and eastern Washington counties was complete.

The motion, filed by REA's counsel, Erik S. Olsen of Eminent Domain Services, LLC, points to sworn testimony by ATC's own customer submitted in the case. In that testimony, Vantage's Vice President of New Site Development agrees with the Responsible Energy Alliance in supporting routing that avoids the sensitive greenfields in Ozaukee and Washington Counties. Tracye Herrington, Vice President of New Site Development for Vantage Data Centers Management Company, LLC, the sole customer the new lines would serve, testified that, after reviewing the routing alternatives, "Vantage has publicly expressed support for selection of the South Alternate Route." The South Alternate Route avoids the sensitive greenfields that the Responsible Energy Alliance is fighting to preserve.

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REA's motion argues that ATC has never explained why its preferred and preferred-contingent routes - the two greenfield routing options - depart from that priority to instead cut new corridors through ecologically sensitive greenfields. A route largely following ATC's own existing right-of-way remains on the table - an alternative that, per Vantage's own testimony, would still meet the project's technical and operational requirements.

The motion includes ATC's own project map, which REA says labels the disputed segment "new transmission line build and replace," undercutting ATC's argument in discovery that the segment should be treated as equivalent to a greenfield route.

The motion also points to the Wisconsin Department of Agriculture, Trade and Consumer Protection, which recommended in its statutorily required Agricultural Impact Statement that the PSC approve the South Alternate Route - the route that avoids the greenfield segments - because of its lower impact on prime agricultural land, hydric soils, and existing farmland preservation and managed forest land programs.

REA's motion is also supported by testimony from wildlife biologist Dr. Gary Casper, who states that routing the lines through either greenfield option "most definitely will cause harm, there is no question about that," and that "neither the Preferred or Preferred-Contingent routes are acceptable."

Dr. Casper's testimony further explains that the project's compressed timeline has not allowed adequate seasonal survey work - noting, for example, that confirming the presence of a federally endangered dragonfly species in the project area requires verification during its July-August flight season, a step that has not yet occurred. Dr. Casper recommends that ATC withdraw the preferred and preferred-contingent proposals and use the existing right-of-way for the alternative route instead.

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REA's motion asks the PSC to take one of two actions: either revoke its completeness determination outright and require ATC to reapply or, alternatively, order ATC to file a revised application that permanently withdraws the preferred and preferred-contingent greenfield segments from consideration.

REA says the motion is time-sensitive: the deadline for parties to file direct testimony in the case is Friday at 1:30 p.m., with hearings currently scheduled for August 25-28. REA argues that timeline is not workable while the unresolved greenfield routing question remains on the table.

"Friday's confusing filings by ATC only underscored that this application was never complete in the first place," Olsen said. "But what should put this beyond doubt is that ATC's own customer has told the PSC, under oath, that the alternative route which avoids the sensitive greenfields works perfectly well for Vantage. Why are ecologically sensitive greenfields even being considered for such massive transmission lines when Vantage itself seems perfectly fine with the route that spares these special lands and follows Wisconsin law? I just don't get it."

If the PSC agrees to revoke its completeness determination, ATC would have to file a new application, restarting the review process. ATC asserts that the up-to-360 day delay caused by refiling would be problematic. REA says that outcome is not a delay opponents should fear, but rather the process protection Wisconsin law is supposed to provide for a project of this size and cost.