Wisconsin PSC Launches Review of Energy Project Filing Requirements

On July 27, 2026, the Wisconsin Public Service Commission (“PSCW”) opened ten new dockets[1] for 2026 updates to the Application Filing Requirements (“AFRs”) for all generation, transmission, storage, abandonment, and ownership interest acquisition dockets.  Still to this date, the dockets do not have documents or information filed in them. However, their title suggests that the Commission will issue suggested changes in the upcoming months. The opening of the dockets is the first step in the Commission's update process and signals that proposed changes are forthcoming.

These changes will impact a broad range of entities whose projects or infrastructure are regulated by the PSCW. Impacted stakeholders include investor-owned utilities, independent power producers, renewable energy developers (solar, wind, and energy storage), natural gas generation and pipeline developers, electric transmission developers, municipal utilities and municipal electric companies, electric cooperatives, and any entity seeking to acquire an ownership interest in or abandon existing energy infrastructure. In short, if your organization builds, owns, operates, or plans to develop regulated generation, transmission, storage, or pipeline assets in Wisconsin, or is considering the acquisition or retirement of such assets, these proceedings are directly relevant to you.

The AFRs are the PSCW’s detailed guidance documents that specify what information an applicant must include in a Certificate of Public Convenience and Necessity (“CPCN”) or Certificate of Authority (“CA”) application. Each AFR corresponds to a particular type of project. For example, there are separate AFRs for transmission lines, wind generation, solar generation, energy storage, natural gas pipelines, substations, abandonment proceedings, and ownership interest acquisitions. The AFRs outline the specific studies, data, analyses, and supporting documentation that must accompany an application so that PSCW Staff can evaluate whether the filing is complete and ready for review. Completeness review is important, because in many cases, that a finding of completeness starts the clock for a decision on the application. 

When an applicant files a CPCN or CA application with the PSCW, one of the first procedural steps is a “completeness determination.”  That is a review by Commission Staff to confirm that all required information has been submitted. The AFRs serve as the benchmark for this determination. If an application does not include the information specified in the applicable AFR, Staff may issue a deficiency notice, which delays the start of the formal review timeline. In practice, an incomplete filing can add weeks or even months to the overall project approval timeline. Ensuring alignment with the current AFRs from the outset is therefore critical to keeping a project on schedule.  The PSCW made recent news by revoking completeness mid-stream in an application, which makes the AFRs even more critical to any project under its jurisdiction.

Yes. The PSCW typically conducts these AFR update proceedings with an opportunity for public comment. Once the Commission posts proposed revisions in the newly opened dockets, interested parties, including utilities, developers, trade associations, municipalities, and other stakeholders, will generally have the opportunity to submit written comments on the proposed changes. Stakeholders should monitor the ten dockets listed above for notices of comment periods and any scheduled public meetings or listening sessions. Participating in the comment process can help shape the final filing requirements to reflect practical considerations that project developers and applicants encounter in the field.

Potentially, yes. If your project will require a CPCN or CA from the PSCW, changes to the AFRs could directly affect the scope and content of your future application. Commenting on the proposed changes now gives you the opportunity to flag practical concerns.  for example, if a proposed new data requirement may not make sense in the context of your project.  Even if you are early in project development, engaging in these proceedings can provide valuable insight into the Commission’s expectations and help you plan your application strategy accordingly. Organizations that anticipate filing in 2026 or 2027 should pay particularly close attention, as the updated AFRs are likely to apply to their filings.

Michael Best's Energy team will continue monitoring these proceedings and any proposed revisions issued by the PSCW. Because changes to the AFRs can significantly affect project schedules, application requirements, and overall permitting strategy, stakeholders should evaluate the potential impacts early in the process. If you have questions about these proceedings, the AFR update process, or how potential revisions may affect a current or planned Wisconsin energy project, please contact your Michael Best attorney or a member of our Energy team for assistance.

[1] 5-AFR-101 (Transmission Lines), 5-AFR-201 (Electric Generation – except Wind and Solar), 5-AFR-301(Wind Generation), 5-AFR-401 (Municipal Electric Generation), 5-AFR-501 (Natural Gas Pipelines), 5-AFR-601 (Substations), 5-AFR-702 (Solar Generation), 5-AFR-801 (Energy Storage), 5-AFR-3000 (Abandonment), 5-AFR-3100(Ownership Interest Acquisition).