Good Letter From Mr. Thurston to LURC

Dear Marcia,

I read with interest the report that is included in the agenda (item #4) of the upcoming LURC meeting. There is a lot of good analysis and it commendable that LURC is making the effort to understand the many impacts of wind power.

Not included in the analysis, however, is one issue that I believe is essential for keeping in perspective the goals established by the Governor's Task Force and adopted by the legislature as the Expedited Process Wind Law, namely, the amount of electricity represented by 2700 MW of land based wind power.

Maine is part of the ISO-NE grid. The grid operates at an average peak daily demand of about 16,000 MW per hour, rising during the day and falling to about 12,000 MW per hour at night. The following link opens a real time map of electricity consumption throughout the ISO-NE service area: http://www.iso-ne.com/portal/jsp/lmpmap/Index.jsp

At the moment I am writing this, at 9:00 pm, the grid is using about 13,800 MW and the real time price being paid for generation is $37 per MW hour. The cost of wind power, according to the Electricity Institute of America, in 2008 levelized costs for new power plant construction, is $149.50 per MW, 4 times the cost being paid for the current mix of generation sources. The following table is in this IEA report: http://www.eia.doe.gov/oiaf/aeo/electricity_generation.html

This gap in the cost differential between wind power and the market value of electricity is made up in subsidies of one form or another. To be fair, other sources of generation also receive subsidies, which are reflected in the market price. However, the per MW value of subsidies for other generation sources are as follows, according to this report on the IEA website at this link:

http://tonto.eia.doe.gov/energy_in_brief/energy_subsidies.cfm

As you can see in the above table, the subsidies provided to coal and natural gas are less than $1 per MW compared to wind power at $23 per MW.

Maine's goal of 2700 MW of wind generation, at a capacity factor of 25%, which is in line with the capacity factors achieved by wind projects in Maine to date, will provide about 675 MW of electricity to the grid per hour. This is about 4.5% of the average daily demand of the grid. The grid has existing, committed generation capacity of about 35,000 MW. 675 MW is less than 2% of the generation capacity of the grid. These are insignificant percentages if the goal is to substantially reduce fossil fuel consumption.

No matter how you slice it, wind power is absurdly expensive, and will alter Maine's landscape permanently with little benefit in emissions reductions in return. NRCM's wind power advocate Dylan Voorhees admitted to me at the Common Ground Fair last weekend that wind generation in Maine may not reduce fossil fuel generation in Maine, because natural gas plants in other states may be the generators that provide the regulating reserves that are affected by the variable output of wind turbines. Wind power will not decrease coal or oil generation because coal plants in the ISO-NE service area run 24/7 as baseload capacity, and oil is used very rarely - only when demand peaks as on hot summer days when wind power is typically not available.

I would also like to correct the table that is included in your report that shows Record Hill Wind in Roxbury as "under construction". Angus King and Rob Gardiner have applied for a DOE Federal Loan Guarantee for this project, which is currently suspended. The draft permit for this project contained the standard DEP condition that financial capacity must be demonstrated prior to construction. The final permit, issued 5 days later, changed the word "construction" to "operation". There is nothing in the record to indicate why this change was made. This permit condition was relied upon by King and Gardiner to begin construction of the project, and it was only after appellants challenged the absence of financial capacity, and the DEP was forced to acknowledge the improper language of the condition (they called it a "drafting error"), that the project was suspended. The recent application for a Federal Loan Guarantee is evidence that RHW has never had financing in place, and it is now obvious that RHW misrepresented that fact to the DEP on several occasions. Your report should show that RHW is suspended due to absence of financial capacity. It should also show that the project is, identical to Oakfield, under appeal to the Law Court.

I have testified to LURC at Carabassett in March of this year about the need for a much more skeptical approach to the permanent alteration of hundreds of miles of mountain ridges and side slopes for the road construction needed for 2700 MW of wind power. Additionally there will be hundreds of miles of clear cuts through currently unbroken wildlife habitat for transmission corridors such as occurred at Kibby. The cumulative impact of this massive assault on Maine's landscape is nearly incomprehensible, and yet we continue on this absurd march like lemmings to the sea, or like frogs sitting in a slowly boiling pot of water, unwilling to recognize the folly of our current course.

Thanks for the opportunity to provide feedback to your worthwhile endeavor to analyze the impacts of Maine's wind goal, something the Task Force and legislature clearly ignored. Please share this with your fellow board members.

Steve Thurston

Roxbury