An offshore wind farm off the coast of the Netherlands. Image courtesy of Nuon @ flickr

From California to Craigsville Beach on Cape Cod, nearly twelve hundred people joined together over the past week to voice their support for Cape Wind’s clean, renewable energy and to oppose the ongoing delays depriving our country of its first offshore wind project. Their comments were directed at the Department of Energy (DOE), which was seeking the public’s input as the agency considers a federal loan guarantee for Cape Wind. The immediate issue before DOE is whether to accept the project’s Final Environmental Impact Statement in its consideration of the loan. The rigorous environmental review has been deemed more than adequate by the country’s leading national, regional and local environmental organizations, including Greenpeace, the National Wildlife Federation, the Natural Resources Defense Council, Sierra Club, Mass Audubon, Conservation Law Foundation and more.

In a letter sent to DOE on Monday, more than two dozen environmental, clean energy, public health, business and labor stakeholders urged the agency to proceed without delay to consider and grant a loan guarantee for Cape Wind. The letter stated, “Cape Wind will concretely advance the nation’s objectives in addressing the challenge of climate change while promoting energy security and economic development. Following an extremely lengthy and rigorous environmental review, the Cape Wind project should proceed for consideration and grant of a loan guarantee without further delay. Such action will help lay the strongest possible foundation for offshore renewable energy development in the United States.”

Cape Wind Now’s petition to DOE activated Cape Wind supporters across the country who invoked everything from protecting their children’s future to much-needed jobs to national pride in calling on DOE to approve a federal loan guarantee for the project and unleash the potential of offshore wind, one of the country’s most promising, but as yet untapped, sources of clean, renewable energy. Supporters railed against the decade of delay perpetuated by fossil fuel billionaire Bill Koch and his Cape Wind opposition group, the Alliance to Protect Nantucket Sound. In yet another delay tactic, the Alliance and a couple of House Republicans recently sought to distract DOE and wrap up the loan guarantee process in red tape by questioning the completed, thoroughly researched and vetted environmental review. “No more delays!” was the common refrain from petitioners, including many Cape residents, who pleaded with DOE to do everything in its power to get the wind turbines built now.

DOE announced in November 2012 that it was considering a federal loan guarantee for the project. The DOE loan guarantee is a key component of Cape Wind’s financing, lowering the cost of the project’s debt and ultimately the cost of Cape Wind to Massachusetts ratepayers. DOE will issue its decision in the coming months.

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Cambridge, MA, in snow. From this photo, I ask: Who ranks? Cars or walkers?

This is a scene in Cambridge, MA, last Friday morning during the nor’easter that passed through late last week. From this photo I ask you: Who ranks in Cambridge, drivers or pedestrians?

In fairness to the hardworking snowplow drivers, municipal employees and property owners – this was in the middle of a storm, we’re all just trying to do the best we can, access for emergency vehicles is essential, and budgets are tight so we can’t do everything.  I understand that and have great respect for our public servants. This isn’t about their job performance.

It’s about our priorities. Who ranks? Cars rank. The sidewalks never get plowed by our elected, tax-supported city government. Clearly it’s not our priority to make it easy to walk. Even though walking is better for our bodies and our planet, and in cities when coupled with public transit it’s the easiest, cheapest, healthiest and overall best way to get around.

Ironically, a few blocks from the scene above, a conference on Public Spaces at the Harvard Graduate School of Design was treating topics such as “Public Space, Democracy and Equality:  For the People, By the People, of the People?”  The attendees were a crowd that understands the importance of public space to public health and the environment – and thriving cities – if there ever was one.  However, emerging on the snowy sidewalk a group of them, lamenting the snow and stepping in ankle-deep slush, scoffed at the idea that the city might actually clear the sidewalks of snow so that people can walk on this vital public space.

Which goes to show how deeply engrained our cars-over-walkers priority scheme really is.

This will change. The world is urbanizing. Young people in the US are buying cars at a much lower rate than their parents’ generation, and many are not even getting drivers’ licenses. They are much more willing to use public transit, and share a car if/when they need one. They walk. And they will replace us, as a matter of mathematical inevitability.

So our priorities have to change. And the sooner the better – because we cannot afford to keep driving everywhere, and maintaining (let alone expanding) a transportation system that prioritizes cars.

This is not a purist view. Cars are a good and necessary thing. We all use them at times, and will continue to need to, so we’re not about to get rid of them altogether. Our collective fleet needs to go electric, in a big way, for similar reasons.  And that’s going to happen too – but that’s another subject.

This is about our priorities. Decreased use of cars in urban areas (large, medium and small), and increased use of walking, biking and transit, is both good for us and the way of the future in any event.

The sooner we align our public spending with that set of priorities the healthier, wealthier and wiser we will be.

In 1998 and 1999 CLF played a key role in a coalition that stopped a proposed development that would have placed a large tower on top of the Massachusetts Turnpike.  That proposal was not coordinated at all with larger plans for building on “air rights” over the MassPike (as it is known) and threatened to inflict major cost on the state transportation agencies due to the cost of building a deck over the highway large and strong enough to support a tower – and concerns about the stress this major new development would place on the transit facilities (the buses and subway) serving the area.

The project inspired significant opposition from residents of the Back Bay and Fenway neighborhoods for a wide variety of reasons.

One result of the controversy around that, and other air rights project and development in those neighborhoods was a massive stakeholder process to develop a “Civic Vision” for development over the MassPike that literally bridged a chasm between neighborhoods in a way that strengthened and improved existing neighborhoods.

CLF was deeply engaged in that stakeholder process, and the closely related environmental review that created that “Civic Vision” and now, years later, that effort seems to be bearing fruit.  A proposal for that same area has been preliminarily accepted by the Massachusetts Department of Transportation as detailed in this short Boston.com blog post and a presentation by the developers.  The proposal would place the actual tower on solid ground away from the Turnpike and put a low-rise commercial building over the MassPike itself.  Still to be dealt with is the crucial question of how the development will enhance the subway and bus infrastructure on and serving the site.  Nearby, the “Fenway Center” air rights proposal that will be built adjacent to Fenway Park is addressing this issue by rebuilding the Yawkey Station commuter rail facility.  Will the Boylston Street entrance to the Hynes station (which is only open for special events as shown in this video) be renovated and opened?  Will the development help pay for signal improvements that improve the Green Line that serves that station? The fact that the designated developers have a good track record of working with the local community suggests that dialogue around such ideas is very possible.  And the fact that the project earns a cautious positive comment from Marty Walz, who led the citizen opposition to the prior project, in the Boston Globe is encouraging.

Building a thriving future with sharply reduced greenhouse gas emissions and strong communities will require investments in real urban development, like the project that has been proposed for this critical Boston crossroads – and we owe it to our future and all the people (even the occasional Yankee fan who finds themselves in enemy territory) who visit, live in and work in Boston to get this one right.

Mount Tom power plant in Holyoke, MA.

A familiar story appears to be unfolding at the Mt. Tom coal plant in Holyoke, Massachusetts. According to recently released documents, the owner submitted what is known as a Dynamic Delist Bid with ISO New England (ISO-NE), the operator of the New England electricity system and markets, and ISO-NE accepted the bid.

This means that during the 2016-2017 capacity commitment period the plant will not be obligated to run and will not receive any capacity payments. The plant could still run and be paid for the electricity it makes, but the act of de-listing means that Mt. Tom’s owner thinks there is a significant chance it will not be economic for the plant to run during that year.

This is not surprising given the sharp decline in how often the plant has been running over the past few years:

This news is particularly significant for two reasons:

• First, submitting a de-list bid to leave the market for one year has been the first step on the path to retirement for two other coal-fired plants in Massachusetts, Somerset Station and Salem Harbor Station;
• and Second, the fact that ISO-NE accepted the de-list bid means that it determined that Mt. Tom can exit the capacity market for that timeframe without any impact on reliability. That’s a good indication that Mt. Tom could permanently retire without impacting the system, although some additional analysis would need to be done.

Although this is welcome news, because it means the end of a long legacy of pollution, it is not surprising. Even Brayton Point, New England’s largest power plant is facing desperate financial circumstances. Coal-fired power plants have been faltering across the country over the last two years, and CLF, Coal Free Massachusetts and local allies have been warning that Mt. Tom is not only a polluting, outdated relic but that it is also an unprofitable, unstable source of revenue for the City of Holyoke and that now is the time to plan for a cleaner, brighter future.

A task force created to examine the issue of retiring, demolishing, and eventually redeveloping the sites of aging coal-fired power plants in the Commonwealth will be visiting Holyoke on March 6 for a meeting with ISO-NE and a tour of the Mt. Tom plant.  CLF and its local allies are urging the task force to open this meeting to the public and to solicit more public input on the process.  Thus far, although meetings have been open to the public, there has been little effort to engage local community members.  Engaging the public is critical to an open, fair, transparent process that will create results that the entire community can get behind.

Since Governor Patrick proposed his plan to raise revenue for transportation and education, a lot of time has been spent on discussing the merits of the revenue sources he has chosen. In comparison, relatively little time has been devoted to how such money should be spent. The great American humorist Evan Esar once wisely said, “The mint makes it first, it is up to you to make it last.”

Transportation for Massachusetts has worked closely with Representatives Tricia Farley-Bouvier of Pittsfield, Representative Carl Sciortino of Medford, Senator Katherine Clark of Melrose, and others to draft legislation that addresses this side of the coin. In addition, Transportation for Massachusetts helped develop a bill that could prepare Massachusetts for better ways to raise revenue for transportation in the future. In total there are currently three great bills pending that Transportation for Massachusetts helped develop.

Here they are:

An Act relative to transportation investment, regional fairness, and accountability to state policies (HD 3119 introduced by Rep. Farley-Bouvier, Rep. Sciortino, and S. 1670 by Senator Clark) will guide any transportation investments the legislature and the governor agree on to build a financially stable, safer and more modern transportation system in every corner of the Commonwealth of Massachusetts. This bill would:

• Eliminate the unsustainable practice of paying for day-to-day operational costs of our highway system by borrowing through state bonds (currently, MassDOT is spending roughly $1.75 for every $1.00 borrowed because of the interest on the bonds);
• Require that an equitable portion of transportation revenue benefit all regions throughout the Commonwealth;
• Set aside funding for Gateway Cities and environmental justice neighborhoods to plan and design projects that are eligible for federal transportation money. This would allow these communities to invest in projects that residents care most about—such as fixing roads and bridges, improving Regional Transit Authorities, and investing in sidewalks, bike lanes, and other projects that promote transit oriented development and affordable housing;
• Require that transportation projects comply with existing policy goals and objectives that reduce pollution, improve public health, improve land-use coordination and meet our mode shift goals;
• Require that transportation investments over $15 million be analyzed for their impact on our economy, environment, public health, low-income communities and communities of color, pedestrian and bike access, and cost of operations;
• Ensure that sufficient money is available for critical maintenance and safety investments; and
• Support the state’s existing mode shift goal to triple trips made on public transportation, biking and walking across the Commonwealth.

An Act relative to contract assistance for Central Artery debt of the Massachusetts Bay Transportation Authority (H. 3141 introduced by Rep. Sciortino) proposes a way to address the crippling debt load at the MBTA by paying down the debt related to the Central Artery Project. The legislation would require that the Commonwealth provide contract assistance from the Commonwealth Transportation Fund for the Big Dig debt held by the MBTA. This money couldn’t come out of funds that are already set to support investments at the MBTA or RTAs.

An Act relative to the establishment of a vehicle mileage user fee pilot program by the Massachusetts Department of Transportation (H. 3142 introduced by Rep. Farley-Bouvier and Rep. Sciortino) proposes a voluntary vehicle miles traveled pilot program to identify alternatives and supplements to the gas tax. The pilot seeks 1000 volunteers from the entire Commonwealth to evaluate ways to protect data collected, ensure privacy, and vary pricing based on time of driving, type of road, proximity to transit and vehicle fuel in order to help Massachusetts prepare for the future of transportation revenue.

We are grateful to the legislative sponsors of these bills who share our commitment to creating and sustaining a 21st-century transportation system that serves all people in communities across thes state.

You can also find this post on the Transportation for Massachusetts (T4MA) blog.

The National Mall was quiet when I stepped off the 350 Massachusetts bus last Sunday. As the sun rose over the Washington Monument and I was tasked with finding breakfast for eleven of my very hungry peers from Stonehill College, I could not help but feel excited and energized for the day ahead. This was a historic moment. So much is at stake in our fight against climate change.

A few weeks earlier I attended the Keystone XL rally in Portland, ME and I could not believe the crowds- over 1,000 people showed up! I wondered: How many people would show up in DC? You can imagine my excitement as the morning went on and thousands upon thousands of Americans from all across the country gathered on the National Mall. They gathered to hear from environmental leaders like Bill McKibben of 350.org, Michael Brune of the Sierra Club, and Senator Sheldon Whitehouse (D-RI). They gathered to stand together, sharing a simple concern. And they gathered to share a simple message with the country: We need to act now, together, on climate change.

As these and several other speakers shared their stories with the 45,000 Americans gathered in front of them, the urgency with which we must address this complex climate change problem was evident. It’s going to take a great deal of effort, time, and some significant behavior change, but the Americans who gathered together on this frigid day are just a few of the millions of us who are ready for some serious legislative action on climate change.

Stonehill students at the Forward on Climate Rally

At times, the crowd roared. They cheered in agreement when it was noted that, “We will never be able to eat money and we will never be able to drink oil.” The emphasis was certainly on the Keystone XL pipeline and President Obama’s ability to stop this project in its tracks. While the cheering was frequent, the signs were funny, and people smiled at the young children running around, the mood was somber as the march began toward the White House.  As the Rev. Yearwood, President of the Hip Hop Caucus noted, “We’re fighting for existence.” That day, on the National Mall surrounded by thousands, the fight was alive.

As Conservation Law Foundation (CLF) President John Kassel noted in his blog post on the topic, this type of movement certainly needs strategists, lawyers, and scientists to succeed, but also the “people in the streets, in villages and barrios, on college campuses and in cornfields and in automobile assembly plants.” Due to the excellent organizing of 350 Massachusetts, the Commonwealth sent a sizable and diverse delegation of 7 full buses including 11 of my fellow students and friends from Stonehill College in Easton, Massachusetts.

Active in a variety of different ways with sustainability and environmental issues at the College, our group of students were able to secure a grant to cover the costs of trip from our school’s “Green Fund” which awards small grants to groups of students looking to engage in environmental events and make campus a greener place! Needless to say, this was an incredible opportunity and it has energized and inspired all of us to take further action at our school to make a positive environmental difference. Whether this be our ongoing divestment campaign, our work to reduce plastic consumption of water bottles and “to-go” meal containers, or education regarding our composting options in the cafeteria, the Forward on Climate rally proved to all of us that we all share a joint responsibility to work together to fight and seriously address the threat of climate change.

Please join us in this critical fight to preserve and protect our previous environment. Join Conservation Law Foundation. If there’s one lesson learned from the rally, it’s that we must work together. Looking around the mall, you couldn’t help but agree that we’re stronger when we do.

Just how much financial trouble is Dominion facing at its 50-year old coal and oil-fired power plant? The prospects are bleak and looking worse. For years, people have assumed that the largest coal-fired power plant in New England could weather any storm, but the numbers show that Brayton Point is facing dark days, and the clouds are not likely to lift.

Brayton Point Capacity Factors from 2007-2012

Today, Conservation Law Foundation released an independent analysis of the financial performance of Dominion Resources’ Brayton Point power plant in Somerset, Massachusetts. The report, authored by the Institute for Energy Economics and Financial Analysis, projects a bleak future for the 50-year-old coal-fired facility. Entitled Dark Days Ahead: Financial Factors Cloud Future Profitability at Dominion’s Brayton Point, the report found that the once profitable power plant’s earnings before interest, taxes, depreciation and amortization (EBITDA) are plummeting due to a perfect storm of market conditions that are projected to continue at least through the end of the decade.

The report shows that those conditions make it unlikely that Brayton Point will ever recoup its recent $1 billion investment in upgrades to the facility, or return to profitability.

“Brayton Point is looking at losing money for the foreseeable future,” said David Schlissel, who co-authored the report with financial expert Tom Sanzillo. “The market conditions have changed and are continuing to change for old coal plants. There is nothing on the horizon that shows that this power plant will be able to return to financial health; in fact, even the most optimistic scenario shows that Brayton Point cannot produce earnings that would cover its costs and produce a return for equity investors at any time through 2020.”

Sanzillo added, “The forecast for Brayton Point is indicative of what’s happening all over the country. We are seeing the owners of these 50-year-old coal-burning facilities facing do or die decisions about their futures, with hundreds having already announced their plans to retire in the next few years and more going that route every month. Brayton Point’s current experience – bleeding money and owner Dominion Resources having already written off $700 million of its $1 billion investment in upgrading the plant – and its bleak outlook clearly show that continuing to operate this plant doesn’t make economic sense.”

A Perfect Storm of Changing Conditions Sends Earnings Plummeting

The report points to a set of changed conditions that together are putting severe downward pressure on Brayton Point’s earnings, which dropped from $345 million in 2009 to an anemic $24 million in 2012, a decrease of some 93 percent:

• Natural gas prices have declined significantly since 2008 and are expected to remain low for at least the remainder of this decade.
• Wholesale energy market prices have decreased In response to the declining natural gas prices, , meaning reduced revenue for coal plant owners and reduced generation at coal plants like Brayton Point.
• Meanwhile, prices for capacity have been also been declining with a 35% decrease in the price obtained in the Forward Capacity Auction in 2012 as compared to the price for 2010.
• Additionally, energy usage in ISO-NE decreased by 2-3 percent between 2008 and 2012 as a result of the economic downturn and increasing energy efficiency efforts.

Future Profitability is Unlikely

The report provides two extremely conservative scenarios of future performance: an “optimistic scenario,” in which generation from Brayton Point coal Units 1-3 is projected to rise to a 60% capacity factor through the years 2013-2020, and a “less optimistic” scenario, which assumes that the units’ generation will not exceed 40% for any year in the period. In 2012, Brayton Points Units 1-3 operated at an average 16% capacity factor. Thus, the report says, earnings from those units could be much lower than projected in the two scenarios modeled. “In no way have we looked at a ‘worst case’ scenario,” noted Mr. Sanzillo.

In both scenarios, based on forward-looking conditions, the report shows that it is unlikely that future energy market prices, ISO-NE capacity market prices, plant generation and coal prices will lead to earnings high enough to provide its owner with adequate recovery of capital or return on investment. The report’s conclusions are based on projections that show that it is reasonable to expect that for the remainder of this decade, at least:

• Energy market prices in New England will remain low, reflecting continuing low natural gas prices.
• Energy consumption in New England will remain flat while consumption in Massachusetts may decline.
• Bituminous coal prices will increase over time.
• As a result, the generation at Brayton Point Units 1-3 is not likely to reach the high levels of performance achieved by the units through 2009.
• Future New England capacity prices are not likely to increase significantly.

On the longer horizon, from 2020 on, the report points to increasing pressure to place a significant price on carbon emissions from fossil fuel-fired power plants, and the plant’s age, as additional factors that will likely weigh on the plant’s earnings.

N. Jonathan Peress, VP and director of Conservation Law Foundation’s Clean Energy and Climate Change program, commented, “Brayton Point, like many other old coal plants in New England and around the country, is at a tipping point. Dominion has already made a losing investment in trying to make this plant viable beyond its useful life. Now, Dominion and its shareholders need to decide whether to keep pumping money into Brayton Point with little chance of a return, as this analysis clearly shows, or to let it go. This report provides compelling evidence for the Town of Somerset, which has been seeing its tax revenue from the plant decline in recent years, to begin planning for Brayton Point’s retirement, and a healthier future for that community in all respects.”

(photo credit: Jack Zalium/flickr)

Get ready: long-simmering chatter among lobbyists and officials in state houses and administrative agencies is about to become a loud, insistent chorus proclaiming that New England needs to give Canadian hydropower financial incentives so that our region can meet renewable energy and climate goals. This policy change would be a wrong turn for a region that is trying to build a truly clean energy future.

As we’ve been discussing for several years now, Québec and other eastern Canadian provinces are eager to increase power exports to New England, including through proposed transmission projects like Northern Pass. Our neighbors to the north have developed and are building more power than they need, and, until New England power prices began their historic decline, the economic motivation for increasing exports was clear: Canadian utilities like Hydro-Québec could sell power to customers in New England and the northeastern U.S. at much higher prices than their own domestic customers are paying. Profits from existing exports to the United States were and remain a major contributor to those utilities’ bottom lines, and they saw and planned to take advantage of a major opportunity to increase profits with new transmission capacity and newly developed hydropower facilities.

The economics behind this long-term Canadian strategy are increasingly in question. Following on the heels of recent technical analysis questioning the strategy’s underpinnings, the most recent projections from the U.S. Energy Information Administration show that total U.S. imports of all energy and electricity in particular are slated to decline over the next fifteen years, with electricity imports never again to achieve the peak level of imports seen in 2012. Given the availability of U.S.-based energy supplies at lower long-term prices, especially natural gas but also wind and other renewable sources, there will be less market demand in the U.S. for Canadian power. These projections reflect a very different reality from the prevailing expectations in 2008, when Hydro-Québec’s strategic plan and the Northern Pass proposal were taking shape. In a research note published last week, Stéphane Marione of Canada’s National Bank Financial warned that “none of the Canadian energy-producing provinces can ignore the profound changes that are taking place in the U.S.”

Montréal, we have a problem. In this new world, the potential market profits from Hydro-Québec’s export strategy are far less compelling. Hydro-Québec may not be able to sell power in New England at the prices it needs to recover the costs of building new transmission like the Northern Pass project and new hydropower projects like the Romaine complex and also return substantial export-driven dividends to the provincial budget.

One possible way that Hydro-Quebec could restore some of these profits is by convincing New England states to increase the price New England customers will pay for Canadian hydropower above the market price. While this may directly contradict the widely held assumption (and marketing claim) that Canadian hydropower is a low-cost power source that is economic without any special incentives, the cognitive dissonance has not prevented Hydro-Québec and Northern Pass developer Northeast Utilities from lobbying New England states to achieve just this goal, an effort CLF has opposed around the region, including in New Hampshire. (Hydro-Québec succeeded several years ago in convincing Vermont to allow its power to count towards a portion of the state’s renewable targets.)

Although the utilities’ lobbying is mostly outside the public view, it is increasingly occurring out in the open, with a direct and urgent new tone. Case in point: Hydro-Québec and Northeast Utilities recently filed comments on Connecticut’s draft energy strategy, which contained some language favoring expansion of Connecticut’s renewable portfolio standard program to include Canadian hydropower, the very policy change that the utilities are seeking. (Incidentally, the final strategy, released last week, made a few changes to the language, and Connecticut is now considering whether and how it might incentivize new imports in a separate study, which is due out soon.) So what did they say?

Hydro-Québec, through its U.S. trading subsidiary HQUS, commented that hydropower should be counted towards meeting Connecticut’s renewable objectives and that its hydropower is less costly than other renewables, but not all power in the marketplace:

HQUS urges Connecticut to recognize Hydro-Québec hydropower as a renewable resource and consider how it might contribute to achieving renewable objectives, as well as other important energy and economic goals. HQUS recognizes that Connecticut has multiple objectives for its renewable programs including to support the development of in-state and in-region resources and emerging technologies. However, if Connecticut’s priority is to maintain its commitment to renewable supply in a cost-effective matter, consideration should be given to the participation of Canadian hydropower. Allowing these resources to contribute to renewable objectives offers a pragmatic way for the state to lower program costs in the near term and, if desired, to extend and increase renewable goals into the future. An approach that values the multiple benefits of Canadian hydropower could also create a market signal necessary in today’s market to promote the infrastructure needed for incremental deliveries into the region for the benefit of all consumers….

Some stakeholders suggest that Hydro-Québec hydropower facilities are “cheap” or low cost to construct. This is incorrect. In fact the cost of building hydropower facilities is significant and generally also requires the construction of new transmission facilities to deliver generator output to load centers, which is also very costly. (Hydro-Québec has also proven successful in the development and construction of transmission facilities to deliver large quantities of electricity over long distances.) However, even with the added cost of transmission to deliver hydropower from Quebec into New England, HQUS estimates its costs to be significantly less than the cost of the delivering equivalent quantities of renewable power from other potential renewable resources in and near New England.

Northeast Utilities, through its Connecticut subsidiary Connecticut Light & Power, commented that hydropower delivered through new transmission projects should get incentives, which would count against the state’s current renewable requirements:

Connecticut has an opportunity to tap into Canadian hydroelectric facilities that are available now or under development, through the development of new transmission infrastructure. A Connecticut RPS market design, which acknowledges that RPS can not only enable new generation, but also support new, clean energy transmission infrastructure could, in this instance, provide for significant Connecticut customer savings….

CL&P believes Connecticut could create a new class of RECs for incremental hydro-electric supply that is delivered over a new transmission interconnection that has been built as an economic project (as opposed to a reliability-based one) which would supplant the need for meeting some portion of Class I RPS requirements….

CL&P believes that embracing large scale hydro power delivered on new transmission as a qualified renewable would meet all three of the State’s energy goals:

• It would be cheaper than other clean energy resources,
• It is clean with very low lifecycle CO₂ emissions, established by independent scientific reviews, and
• It is reliable, and would lessen the region’s dependence on natural gas for power generation needs.

It’s clear from these comments – and the utilities’ growing campaign to secure changes to New England’s renewable energy policies – that they are looking for subsidies from electric ratepayers to support new hydropower imports into the region. In fact, the Northeast Utilities comments constitute a direct effort to secure ratepayer subsidies for Canadian hydropower transmitted over Northern Pass, something Northeast Utilities repeatedly claimed it would not seek and does not need (e.g., here, here,  and here).* (For the record, they are mischaracterizing the emissions benefits to support their argument for subsidies. But that’s another story, well chronicled in prior posts.) Certainly, Hydro-Québec’s own comments reveal that its power can no longer beat the market on its own.

It’s also clear that, depending on how it is pursued, this kind of policy change threatens to put New England’s renewable energy industry at a deep and unfair disadvantage and to undermine its growth. Even Northeast Utilities, in the comments linked above, acknowledges this risk.

CLF has been clear that more Canadian hydropower could be a good thing for the region under the right conditions. But why should New England customers be forced to pay an above-market price? State renewable portfolio laws are intended to get new renewable projects built here, not to force ratepayers to pay extra to improve the economics of Québec’s new hydropower facilities and specific transmission development plans. That’s why CLF strongly objected to the draft Connecticut strategy’s mention of potential inclusion of Canadian hydropower in Connecticut’s renewable portfolio standard law. You can read our full comments, which address other major Connecticut energy issues as well, here.

It’s not too late for the New England states to get smart about new imports and make sure that new imports only happen, if at all, in cost-effective ways that allow alternative power sources and companies to compete on a level playing field, respect local communities, and provide meaningful economic and environmental benefits, accounted for in fair and open processes. Committing New England residents and businesses to pay above-market prices for Canadian hydropower isn’t one of them.

* from Northern Pass’s website, accessed today:

Providing economic clean energy—without a government subsidy

This will be one of the few—if not the only—renewable energy projects in the region that does not need a government subsidy to move forward. Hydro-Québec can generate and sell the power to us at prices that will compete with the average market prices that are being set today by fossil fuel power plants.

The Boston Harbor Association has a powerful message about the very real threat of sea level rise driven by global warming.  Their report, “Preparing for the Rising Tide”, is a dramatic wake-up call about the fundamental threat to the historic and economic heart of Boston.

The report starts with very solid science that shows how the homes, businesses and cultural institutions (like the New England Aquarium) that sit on the waterfront are now on the edge of entering, and have in some cases already entered, a very real danger zone.  A zone where the flooding and catastrophic damage that Hurricane Sandy brought to the New York region would tear across our coastline – with the prospect of worse to come.  Indeed, had Sandy hit only 5 ½ hours earlier than it did, when tides were high, the floodwaters would have reached Boston City Hall, nearly ½ mile inland from the City’s waterfront. In other words, Boston got lucky compared to New York City and other communities that were brutally whacked by the storm.  And this near miss begs the question:  do we really want to leave the vitality of our coastal communities to chance?

The report provides a few key lessons:

• Many vulnerable places, like the entrance to the UMass Boston campus, key MBTA stations like the one at the New England Aquarium and sections of waterfront buildings like the Long Wharf Marriott are in very real danger, today, from the severe storms that are becoming an unfortunate, and all too frequent, visitors to the Northeast.
• Indeed, some of these vulnerable places would have suffered very real and painful damage if Sandy had slightly changed course and struck Boston instead of New York, or if Sandy had arrived just a few hours earlier.
• As climate change continues to worsen due to the build-up of greenhouse gas emissions in the atmosphere, a build-up that grows a little bit every day, the likelihood of a severe flooding event increases. In a very real way the march of time is our enemy here – with each passing year, as we continue to pump enormous quantities of greenhouse gases into the atmosphere, the chance of a catastrophic flooding event grows.
• Addressing this fundamental problem will require an integrated approach that reaches across all aspects of society, the economy and government – fundamentally transforming the way we plan, use our land and water resources, build, travel, manage our buildings and use energy – in order to make our communities more resilient and able to handle inundation and other impacts from the changing climate but also to reduce the emissions that are causing the problem in the first place.

In other words, while it remains critically important to tackle the root causes of climate change by reducing energy waste and cleaning up our energy supply, that’s not enough any longer. The emissions we produce today from driving our cars and heating and lighting our buildings will produce effects that are beginning to materialize now – as with Superstorm Sandy – and that will present ever more daunting challenges for future generations. We therefore need to brace for impacts that already have been set in motion. And we must adapt a broad range of infrastructure and institutions to make our communities more resilient to those impacts.

Conservation Law Foundation, as a group with roots in Boston and nearly 50 years of work here, applauds the work of the Boston Harbor Association in preparing and releasing this Report.  As a regional organization that works across New England, we recognize that the Report reflects an absolutely vital case study that provides guidance for planning and preparations in Massachusetts’ largest city, while also providing an example of the kind of sober analysis and planning that needs to unfold from Connecticut’s Long Island Sound coastline to the frigid waters of Downeast Maine.

This Report is a reminder that we must act now to protect our communities from the harm that has already been done – and we need to act on emissions reductions to prevent even worse and more catastrophic harm beyond the massive flooding outlined in TBHA’s chilling maps.   This is the mandate of the Massachusetts Global Warming Solutions Act that has been on the Commonwealth’s books since 2008. Having had the foresight to enact this law the question becomes whether we here in Massachusetts will have the courage to truly implement it.  TBHA’s Report, which looks at both the impacts that are unavoidable and the even worse impacts if massive greenhouse gas emissions continue, provides a compelling reminder of the  consequences of inaction.