The following letter was submitted to the Department of Energy regarding the Presidential Permit application of the Northern Pass Transmission project.
September 18th, 2013
Mr. Brian Mills
United States Department of Energy
Office of Electricity Delivery and Energy Reliability
1000 Independence Avenue
Washington, DC 20585
Re: Northern Pass Transmission Project, Presidential Permit Application, Docket PP-371
The New England Ratepayers Association (NERA) wishes to submit the following comments for consideration regarding the Northern Pass Transmission Project:
The New England Ratepayers Association is a non-profit,
As a group dedicated to protecting ratepayers from public policies that result in higher electricity rates in the region, it is incumbent upon us to take a broad view of generation and transmission projects as part of the calculus of the region’s energy policies. While the region has enjoyed relatively low natural gas price over the past few years, there is no guarantee that prices will remain at or near the historical lows we have recently experienced. Currently, New England is exceedingly reliant on natural gas for electricity generation—with over 50% of generation derived from natural gas. Unfortunately, New England suffers from constricted natural gas pipeline capacity, which is magnified by the fact that most of the firm supply for natural gas capacity is allocated to local districution companies (LDCs) for home heating fuel. This results in New England electricity ratepayers being held hostage to the volatility of the natural gas markets—as well as limiting the potential for more baseload natural gas-fired generation plants to be constructed.
Public policy in the region (and nationally) has made it highly unlikely that New England will build new coal or nuclear plants and even the proposed 670 MW footprint natural gas plant in Salem, Ma. is facing objections from environmental groups, who choose to ignore the fact that the the New England Independent System Operator (ISO-NE) has clearly stated that the project is needed to ensure reliability of the grid. Buoyed by the pending decommissioning of Vermont Yankee, environmental groups are pushing to close the Massachusetts Pilgrim nuclear plant and it is only a matter of time before Seabrook Station is also targeted.
With nuclear power plants re-emerging as a red herring for environmentalists, and with 8,000 MW of baseload power (mostly coal and oil) scheduled to retire by the end of the decade, new, reliable baseload power will be needed to provide stability to the New England power grid. Additionally, the U.S. Department of Energy’s Energy Information Association (EIA) projects that electricicty demand will increase approximately 28% over the next thirty years. These numbers include energy efficiency measures, which won’t do enough to offset growing electricity demand. Which energy sources are going to provide us with the reliable and inexpensive power we will desperately need? Wind and solar are costly, intermittent energy sources that cannot provide baseload power and require natural gas-fired generation on spinning reserve as back-up, further complicating concerns about natural gas pipeline capacity in the region, and rely heavily on taxpayer and ratepayer subsidies that cannot be assured to last indefinitely. The answer likely lies in large-scale hydropower, which has the potential to provide New England ratepayers with the affordable, reliable baseload power that will be needed to replace the 8,000 MW of retiring generation.
The Northern Pass project will provide 1200 MW of affordable, reliable, baseload hydropower to a region with a growing dependence on natural gas generation for electricity as well as a rapidly dwindling portfolio of baseload supply options. The project is opposed by individuals and groups who are concerned about the impacts of transmission structures along the route corridor. Many argue that unless the entire project is buried, it shouldn’t be built at all. However, this is not financially feasible, despite speculative arguments about hoped-for technological advances and apples-to-oranges comparisons to dissimilar projects. These opinions are all subjective and open to debate. What isn’t debatable is the rapidly declining options for baseload power in New England. Nuclear and coal plants have been pushed off the table and until natural gas pipeline expands throughout New England—and that will raise its own set of environmental hurdles—the region will need to turn to additional baseload power options. Denying a Presidential Permit to the Northern Pass Transmission Project will deny New England an opportunity to add 1200 MW of cost-effective and reliable baseload power to an electricity grid that will soon be starving.
New England Ratepayers Association