Today we sent our Public Affairs Director to Boston to testify at the Massachusetts Public Utiities Commission on hundreds of megawatts of proposed mandated contracts for wind power projects in Maine. These include Highland Plantaion, Fletcher Mountain, Oakfield, Bingham, and two in Washington County. Over 15 New England advocates spoke elequently AGAINST the projects that would carpet bomb Maine with useless and unnecessary wind projects. Nobody spoke in favor. The lobbyists for the utilitis and wind developers sat uncomfortably throughout the afternoon.

Following is the FMM testimony.  If you want to submit citizen comment, you must do it today... by 5:00 pm Thursday, October 24.

Send to:

------------------------------------

Friends of Maine's Mountains Comment on Wind Power Contracts

October 23, 2013

Comments by Christopher O’Neil, Public Affairs Director, Friends of Maine’s Mountains

Docket Number:  DPU 13-147

Thank you for taking public comment on Docket # DPU 13-147, which would mandate hundreds of megawatts of wind power contracts – most to be located in Maine – upon the ratepayers of Massachusetts, and upon all ratepayers in the ISO - New England.

First, a bit about Friends of Maine’s Mountains (FMM).  You might be puzzled about an environmental group testifying against clean energy.  We are not against clean energy.  As I will explain later, FMM and Maine are staunch proponents and practitioners of clean energy. But it has to be viable. Real. Necessary. Useful. Sustainable. If its impacts are bad for Maine’s environment and economy, its benefits have to be better.  If the proposal before you would result in cleaner air or lower rates for Maine, we would likely be supportive.

Here is a quick example of our thinking:  About a year ago I received a call on my cell phone from a woman in Eustis, a rural town north of Sugarloaf and not far from the Canadian border. Just up the road is one of the first and the biggest grid scale wind “farm”in New England.  She was almost frantic:

“Hello… Chris O’Neil?  I saw you on the web.  You’re the people fighting against the windmills, right?”

“Yes.”

“We need your help. They want to put a great big cell tower up on the ridge behind my house.  What can we do”

“I’m sorry ma’am. We actually love cell towers.  They’re necessary and useful.  They keep us in business. We’re talking right now thanks to cell towers.  Get rid of every cell tower in America today and the world economy will screech to a halt.  Get rid of every windmill and you won’t see a lightbulb blink.”

“Oh. Well thanks for taking my call.  Nice chatting with you.”

FMM opposes today’s proposed rates, not so much for their “list price” -- to use car dealer terminology -- but more because of their likely take home price. And take home cost must be the focus of this proceeding.

About the list price vs. the take home price. The so-called wind “industry” lives in the world of the theoretical, where the industry’s lobbying/public relations sales pitch has led the public to believe much which is often untrue.

Their model is not unlike the relationship between a car dealer and the buyer who walks into a dealership with an ad in his hand, looking for his $17,000 car, but ultimately spends an hour with the man behind the curtain and leaves with a $27,000 loan, because he wanted tires and bumpers and the other features that make his purchase roadworthy.

Whether it is theoretical projections of fossil fuel displacement/replacement, X million pounds of theoretial emissions reductions, or Y number of theoretical homes a wind “farm” can power, the wind power sales pitch is seldom realized in practice.

Accordingly, we ask you to look beyond the sales pitch, with ratepayer protection in mind, and to please ascertain the true cost. Upon weighing the true benefits and impacts (including cost) there is simply no way you can do this to your ratepayers – or to us in Maine.

This summer we sat up in Maine and read the news about several southern New England utilities that announced they would seek approval from you and your counterparts in Rhode Island and Connecticut. Predictably, the well-orchestrated wind PR machine ballyhoo’d the eight cent rate:

“…wind is suddenly competitive… surprisingly viable… finally arrived…”

Our conversations up there were peppered with terms like “Trojan Horse” and “fool’s gold.”

It is worth noting at this point that in 2012, the ISO-NE reported that average wholesale cost of electricity for the year was 3.8 cents.  The proposal before you is more than double that price.  If the quality of the product were more than double, maybe we would be here today testifying in support.  However, as you know, the quality of the wind power product is dreadfully low. In any other market, a product’s quality and price will maintain at least a modicum of correlation; low quality = low price.  The proposal before you is high price for low quality.  You cannot justify foisting that perverse value judgment upon your ratepayers.

Better if you dictate the terms: set a threshold price (perhaps one or two cents) above which you will not consider any proposal for wind power.

The first cost that FMM counts outside Massachusetts is the cost to Maine’s signature Quality of Place, which was identified in a 2006 Brookings Institute report as our most invaluable and irreplaceable asset, even for economic development. The woefully low energy density of grid scale wind development relative to its sprawling scope and scale has the potential to destroy Maine’s Quality of Place for very little benefit – economic or environmental. It is the general “high impact-low benefit” nature of this form of development that leads us to oppose it.

As I just foreshadowed, FMM is not merely concerned about the environmental impact.  Like you, we seek to protect ratepayers and the greater economy of our state and region.  Because we are all “connected” in these matters by a common Grid System, FMM is compelled to appear in Massachusetts today.

Before approving the proposed contracts, we implore you to consider several factors that collectively render the “cost” of these projects far higher than the “list price” which has been seized upon by the proponents’ public relations machines as suddenly competitive, viable, and sustainable. In fact, the product provided by the applicant is neither useful nor necessary, and its true costs have not been fully accounted. Do you want to be forever remembered as the gatekeeper who allowed the Trojan Horse through the gates without asking the tough questions?

By “useful,” we refer to wind power’s fatal combination of characteristics: both intermittent and unpredictable.  These characteristics make it essentially useless to a grid scale application; just an occasional and disruptive add-on.  By “necessary,” we note that if the ISO-NE grid anticipates needing new generation, it will be base load, peak load, or load balancing generation. Today’s applicants do nothing to satisfy any of the three needs.  Government mandates notwithstanding, there would be no demand for the product in question.

Maine does not have its head in the sand. The Pine Tree State is proud of its environmental legacy. We have the third lowest state CO2 emissions from electricity generation in the nation.  Depending upon what Vermont does next year, we could be #2. Our RPS is by far the highest in the nation, and 99% of Maine generation comes from clean sources other than coal and oil.  Our capacity exceeds or load by 3:1 or 4:1 on almost any given day.  You’re welcome.  Maine has untapped capacity in our biomass plants, some of which are idle, in part because some states do not recognize biomass as renewable. I realize that you are not the policymakers, but if you can convey the high value of biomass to your legislature, we in Maine will be grateful. To the point, Maine is doing more than our part, and we strenuously object to the notion that we could be forced to pay the “price” for other states’ action or inaction.

We ask you to consider the following:

A contract in-hand is a boon to wind developers.  It helps them gain more favorable financing terms, and it enhances their abilty to win site-location permits. So make no mistake.  Your action here matters to Maine, as we will suffer injury by your action if that action is to approve.

Even after Maine’s 1.5 billion dollar Maine Power Reliability Project – we are transmission constrained.  Curtailment has become common, and resulting efficiency cost-shifts onto necessary generators will inevitably be reflected in rates.  Eight cents is not eight cents. Last year Central Maine Power Company T&D rates increased 19 percent, concurrent with the difficulties we encountered from the widespread addition of wind power generation.  Make sure you add a reasonable T&D increase to your eight cent asking price.

To effectively connect the proposed amount of wind power to the grid, we need - at the least - a system impact study that honestly accounts for both the needed infrastructure and the cost shifts to necessary generators. In 2011 one of Maine’s new combined cycle natural gas plants – Casco Bay Station in Veazie, a 500+ MW plant, had average revenue of $41 per MWh, with zero capacity payments.  But the plant only operated at 40% of capacity.  Imagine how inexpensive the electricity could have been if the plant operated at 50, 60, or 70 percent?  Add your cost shift findings to the eight cent asking price.

The ISO-NE has recently begun allowing negative pricing.  The net effect of this dangerous practice will necessarily increase all rates, even as wind developers will tout their “list price” as competitive and reasonable.  Add the increase to the eight cent price.

Wind power’s true price should include the cost shifts to the necessary generators, T&D, capacity payments to a generation source that has zero capacity, Renewable Energy Credits, and other taxpayer contributions.  Moreover, high voltage direct current transmission projects are on the way from Canada to here.  Such projects supplying versatile high quality base load, peak load, and load balancing renewable energy have the potential to render New England wind “farms” irrelevant, undesirable, and burdensome. Where will that leave our “investment” in wind power? How much will that cost the ratepayers left holding the bag?

Last July on our hottest days, when load exceeded 26,000 MW and peaking plants were commanding hundreds of dollars per megawattHour, invariably our one billion dollar-plus expenditure on wind projects was able to contribute less than one percent of load.  Where is the value to ratepayers?

These true/net costs should be overlaid by the actual benefits. Please do a full and fair accounting of costs when evaluating these rates, and recognize that Maine people are increasingly unwilling to serve as the wind plantation for southern New England.  For your own sake – and for Maine’s – please look beneath and beyond he marketing of the proponents, who are essentially just rent-seeking.

Please know that FMM and others will vigorously oppose and delay the proposed projects at the site-location process, thereby denying Massachusetts ratepayers any benefit – perceived or real.

Please know also that over three dozen Maine municipalities have, through land use zoning, effectively shut out grid-sclae wind power.  They all took time and did their homework.  Once they knew the facts they concluded that it just isn’t worth it.  Unfortunately, most of remote Maine is in what we call the “Unorganized Territory,” where citizens have no municipal government, therefore no local control/zoning.  They are vulnerable, and while you do not represent them, think about their plight as you consider mandating outrageously expensive contracts that do no good.

Maine does not want these contracts.  Neither Maine nor Massachusetts needs these contracts. The utilities certainly do not need these ridiculous contracts.  Only the wind developers need them.

In 1820 my state had the fortitude to shove off from Massachusetts.  I enjoy your fair commonwealth for its museums, ballparks, and the like. I was educated here (and some of my best friends are from Massachusetts).  But the wisdom of our 1820 decision becomes more apparent as we contemplate what is at stake today.

Maine has an “Expedited Wind Law” that might make you think we want this development.  In 2007 when the law was passed and oil was $149 per barrel, we thought we wanted it. And wethought there was some connection between oil and electricity. But we have done our homework and now we know it is a Trojan Horse…fool’s gold. The law is under scrutiny and under fire, with many legislators expressing regret about voting for it in 2008.  New legislators are increasingly seeing the law as a bad deal for Maine.  We will not tolerate it being the wind power plantation for southern New England.  Please don’t tread on us.

About a hundred years ago Maine Governor Fernald teamed up with then-Senator / future Governor Baxter -- for whom our “forever wild” State Park is named, and against whose wishes these people (point at First Wind’s Kurt Adams) are willing to defile Katahdin – to pass the Fernald Law.  They were facing an industrious and aggressive entrepreneur named Walter Wyman, the founder of Central Maine Power Company.  I note that Wyman is one of my favorite historical Maine figures. He was building dams and flooding forests and farms to harness energy that would power the Industrial Revolution.  But Mainers saw that there was more in it for Lowell, Lawrence, and Boston than for Portland, Bangor, and Lewiston.  So Baxter and Fernald waged war with Wyman for decades to ensure high impact electric generation would have high benefit for Maine.

Everybody won because Wyman’s dams were useful, necessary, and sustainable.  The projects driving the contracts before you are none of the above.  Per the Fernald Law, Maine has fought this sort of extraction development before, and we will do it again.

For the good of Massachusetts ratepayers and the good of the region, please deny.

Christopher P. O’Neil

(207) 590-3842

http://www.friendsofmainesmountains.org/blog/53/18/FMM-to-Boston-do...