Navigating a Complex Permitting Process for a Lake Michigan Power Plant

Elm Road Generating Facility


Elm Road Generating Facility


Oak Creek, WI


We Energies

AKRF prepared the necessary 316(b) permit applications for We Energies' new Elm Road Generating Facility, a coal-fired power plant on Lake Michigan.

We Energies added two electrical generating units that share common facilities with an existing four-unit plant on the site. Cooling towers, the U.S. Environmental Protection Agency’s (USEPA) then-preferred cooling technology, were—and are—costly. We Energies preferred to use alternative technology to minimize impingement and entrainment of aquatic organisms. The proposed alternative was to move the existing intake offshore and to install wedge-wire screens.

Due to complex circumstances and a shifting regulatory climate caused by litigation over the USEPA 316(b) rules, AKRF prepared three separate permit applications for this project, as three distinct sets of rules were in effect to regulate new and existing facilities over a period of several years.

Ultimately, AKRF demonstrated that the offshore intake met both state and USEPA requirements and the utility secured authorization to use the offshore intake for the existing and additional units and was able to meet its construction schedule.

Permitting & Compliance Overview