“Pick a Day, Commute Another Way.” That’s the theme of this week’s Massachusetts Car-Free Week, when the state joins over 1,000 cities in 40 countries around the world to encourage motorists to leave their cars at home and try bicycling, walking, public transit, carpooling, or vanpooling to work. With transportation as the state’s largest and fastest growing sector with respect to climate-altering greenhouse gas emissions, it’s imperative that we reduce the number of vehicles on the road.

Here at CLF, in addition to our extensive policy work to improve transportation choices in both urban and rural communities across New England, we’ve long advocated for market-based approaches to encourage people to drive less as a means of reducing greenhouse gas emissions, air pollution, and traffic congestion. That’s why, in conjunction with Massachusetts Car-Free Week, we’re proud to announce a new pilot study that our non-profit affiliate, CLF Ventures, will be conducting in 2014.

Funded by a $2.1 million Federal Highway Administration Value Pricing Program grant administered by the Massachusetts Department of Transportation, and with an in-kind contribution from Plymouth Rock Assurance, the three-year study will explore how rewarding people for driving less affects their driving behavior.

Specifically, CLF Ventures will examine how the size and timing of cash rewards, and how those rewards are communicated, can motivate people to adjust how much, when, and where they drive. The study will help us understand the economic and environmental implications of these behavioral changes, and will provide, for the first time, publicly available data about these behavioral impacts so that states, insurers, and motorists can learn more about the effectiveness of various incentives for reducing driving. Using in-vehicle telematics devices, the study will collect data on miles traveled and when a driver enters different geographic zones, such as Metro Boston or Metro North, but it will not track specific locations.

As CLF President John Kassel states:

“CLF strongly believes in market-based approaches to addressing environmental problems. For more than 15 years, we’ve championed innovative methods to reduce driving as a way to achieve real environmental benefits. This study is an important next step in providing the data policymakers and insurance companies need to design effective voluntary programs that encourage reductions in driving on a large scale. We need to pursue every option available to reduce greenhouse gas emissions in order to meet Massachusetts’s – and the region’s – climate goals.”

Financial incentives to drive less can provide a win all-around for Massachusetts consumers, residents, insurers, policymakers, and the environment:

• Consumers can earn rewards for driving less.
• All Massachusetts residents will benefit from improved road safety and reduced traffic congestion that result when people drive less.
• Insurers can provide an incentive to policyholders that reduces driving, thereby reducing the number and cost of auto accident claims.
• Policymakers will benefit by having real data that reflects how consumers change their driving behavior when incentivized to do so.
• The environment will benefit from the reduction in vehicle miles – less driving means reduced fuel usage, better air quality, and lower climate-altering greenhouse gas emissions.

Groups of randomly selected, current Plymouth Rock policyholders will be invited to participate in the pilot study, which will begin in 2014. Potential participants can accept or decline the invitation to participate; they cannot “volunteer” to join the study. The study will enroll approximately 3,000 Plymouth Rock policyholders in Massachusetts from a representative mix of vehicle classes, geographic territories, and coverage characteristics. Participants will pay their normal insurance premiums, regardless of how many miles they drive, and can earn per-mile cash rewards for reducing the miles they drive.

Considerable data security measures will be in place to protect the privacy and confidentiality of the voluntary study participants and protect their personal information. Participants will be told what data will be used and how, and must provide their consent. Data released to the public will be scrubbed of personal/identifying information and only made available in aggregate form.

We know that reducing miles driven can decrease emissions of climate-altering greenhouse gases and health-damaging air pollutants, ease traffic congestion, and improve road safety. What we don’t know is to what extent driver behavior can be influenced through financial rewards and incentives. This pilot study is a great way to find out.

Today, CLF, the Appalachian Mountain Club, and the Society for the Protection of New Hampshire Forests filed joint comments with the U.S. Department of Energy (DOE) bearing a simple message: the Northern Pass project’s new “amended” application for a federal Presidential Permit once again doesn’t cut it. The application, filed in July, fails to provide the comprehensive and required information that DOE and the public need to evaluate the project. This time, project developer Northern Pass Transmission LLC (NPT) should not get another bite at the apple.

After more than two years of self-imposed delay and thousands of good-faith comments from the public expressing concerns about the project’s impacts and offering a wide range of potential alternatives, project developer Northern Pass Transmission LLC (NPT) has had ample opportunity to right the wrongs in its original, incomplete permit application by fully describing the practical alternatives to the project and its important environmental impacts, including at the project’s power sources in Canada. Instead, as we say in our comments, NPT’s 80-page amended application amounts to a poorly cited legal brief. It fails to include much of the detailed technical and environmental information in NPT’s possession and seeks to avoid thorough and rigorous review of the project and alternatives by dismissively branding each and every alternative to the current proposal unreasonable and impractical.

Enough is enough: no more bites at the apple for Northern Pass (photo credit: flickr/shane o mac)

Why is what’s in NPT’s application so important? For one, the content of the application provides the crucial starting point for DOE’s review of the project and its alternatives. And the application also should provide a set of sound technical and environmental information about the project and its alternatives that the public can reference, evaluate, and hold NPT accountable for. This is especially important in the wake of a saturation public relations campaign that superficially touts the project’s supposed benefits, including a series of “open houses” where project officials control the agenda and won’t answer key questions.

CLF and its partners agree: NPT had its chance to present a revised project, an amended permit application, and a new approach that respected host communities, acknowledged the feasible alternatives to overhead transmission technology outside the original corridor, and made a credible environmental and economic case for increasing imports in the context of the region’s overall energy future and in the face of its affiliate PSNH’s stubborn insistence on continuing to operate uneconomic, dirty coal plants. With its barely changed ”new route” and unwavering adversarial stance, NPT blew it.

As CLF’s President John Kassel made clear this summer, the region should pursue a robust regional discussion of the right approach to importing more power from eastern Canada. But without even the solid ground of a complete federal permit application, NPT’s proposal should stop here.

Don’t forget: next week, Show Up and Speak Out at the Final Round of Public Scoping Meetings for Northern Pass, and tomorrow is the deadline for intervening or filing specific comments on NPT’s amended Presidential Permit application.

Conservation Law Foundation warmly welcomed the news that Vermont Yankee will soon close. The closure is long overdue for this tired old plant, following a history of leaks, false testimony, broken promises and poor management.

For over ten years, CLF has been actively showing that Vermont Yankee is not a good deal for Vermont. The state has been saddled with this poorly managed, uneconomic dinosaur for far too long, enduring environmental damage and the persistent threats to public health and safety that come with operating a nuclear power plant well beyond its planned life.

Image Credit: Tim Newcomb

With no place to put the waste that will remain dangerous for thousands of years, no power contract that would provide reliable and low cost power to Vermonters, and rapidly escalating costs to shut down and clean up the site—and little money available to make that happen—the numbers just never added up. The plant has been a pig in a poke for some time. The schemes from the plant’s wily owners to eke out a profit and keep the plant running, finally failed.

Vermont Yankee’s closure is good news for Vermont and the region’s economy and energy future. It heralds a transition away from older and polluting power supplies. Old technology, whether nuclear or coal-fired, cannot compete with newer, more efficient resources, renewable energy and energy efficiency. As New England undergoes a massive technology transition that hastens the demise of old polluting power plants throughout the region, we can begin investing in cleaner supplies that will meet our energy needs and create good, green jobs, instead of propping up polluting old plants and paying too much for their power.

Throughout the past decade, CLF added a strong oar pulling to move away from Vermont Yankee. We explained to state regulators, courts, legislatures, federal agencies and blue ribbon commissions the problems with water pollution, management and poor economics of the plant operation. Our advocacy built on a history of holding states and power plant owners responsible for acting in the best interest of ratepayers.

In the 1980s, we led a successful campaign to prevent a second reactor from being built at the Seabrook Station nuclear power plant in New Hampshire because the economics didn’t make sense. In 2000, we helped avert a fire sale of Vermont Yankee that was a bad deal for Vermont ratepayers. And in 2006, CLF showed how cleaner energy efficiency could help meet our power needs and reduce the need for massive transmission that would prop up older plants.

Throughout New England, whether it’s these old nukes, or old coal-fired power plants, we and our allies—the people who have paid and continue to pay with their health, their wallets and their children’s futures to keep them running—are shaking the region from simply accepting business as usual. The demise of Vermont Yankee—and the Salem Harbor and Somerset Station coal plants—was the result a changing energy landscape brought about by  advocates like CLF, who held  plant owners to account year after year, and  built legal, political and popular support for a better deal for New Englanders. Who knows how much more life their owners may have tried to wring out of these old plants at our expense if CLF and others had not been there to keep the pressure on for them to move aside?

Economics and advocacy are closely intertwined. Regardless of which straw finally broke Yankee’s back, the end of these old, polluting power plants is clearing the way to a cleaner energy future in our region. Thanks to the persistence and dedication of many, that is now within our reach.

During the week of September 23, the United States Department of Energy (DOE) has scheduled four additional public scoping meetings in different communities in New Hampshire as part of the scoping process for DOE’s Environmental Impact Statement (EIS) for the Northern Pass transmission project.

As with the well-attended meetings more than two years ago, these new meetings are a vital opportunity to explain your concerns about the project to DOE officials. These meetings are the last in-person moments to influence DOE’s decisions on the scope and content of the draft EIS, including the environmental and social impacts of the project to be considered and the alternatives to be seriously studied. Those decisions will have lasting ramifications as the federal and state permitting processes continue. Here is the schedule:

• Monday, September 23, 2013, 6–9 p.m., Grappone Conference Center, Concord, NH (map)
• Tuesday, September 24, 2013, 5–8 p.m, Plymouth State University, Silver Center for the Arts, Hanaway Theater, Plymouth, NH (map)
• Wednesday, September 25, 2013, 5–8 p.m., Mountain View Grand Resort & Spa, Presidential Room, Whitefield, NH (map)
• Thursday, September 26, 2013, 5–8 p.m., Colebrook Elementary School, Colebrook, NH (map) (this meeting was moved from a smaller location in W. Stewartstown)

Each meeting will include both an “informal workshop” and a more formal session where the public will have the opportunity to make brief statements. In the 2011 meetings, speakers were limited to 3 minutes. If you want to speak, we advise that you reserve a slot in advance by emailing DOE’s Brian Mills at Brian.Mills@hq.doe.gov. The formal portion of the meeting will be transcribed by a stenographer, and all public testimony will be included in the official administrative record of DOE’s review of the project.

Even if you aren’t interested in making any remarks in the formal session, please attend and bring your neighbors, friends, and family. The turnout at these meetings is important to the course of the permitting process, and many will be watching to gauge the public’s reaction to Northern Pass’s revised route. Showing up matters!

(photo credit: flickr/Christchurch City Libraries)

You can also weigh in with written scoping comments on DOE’s EIS website. The deadline for these comments is November 5, 2013. (The deadline to file comments with DOE on the amended application and to ”intervene” remains September 18.)

What should you say or write? Any reasonable concern or question about the proposed Northern Pass project and alternatives is relevant to the scoping process and will help inform DOE’s decision-making. As a starting point, it may be helpful to review the maps of the project route prepared by Northern Pass Transmission LLC in its amended permit application; both the maps and the application are available at DOE’s EIS website. CLF’s Northern Pass site, our detailed 2011 scoping comments, and three years of our Northern Pass blog posts are also at your disposal. Consider submitting comments on the potential impacts of the project on communities, the White Mountain National Forest, the climate, wildlife, forest resources, wetlands, recreation areas, the renewable energy sector, the local economy, and natural resources in Canada.  And don’t hesitate to tell DOE, once again, that its review of the project needs to be more fair, transparent, and objective than it is now. Note also that Northern Pass’s many rejections of potential alternatives to the project, including in its permit application, aren’t the final word, and DOE must conduct a rigorous review of all reasonable alternatives, including not building the project, and alternative routes and project designs that may have fewer impacts. It’s well settled that an objective and comprehensive analysis of alternatives is an ironclad legal requirement and, indeed, the heart of the federal environmental review of the project.

Show up and speak out!

The Vermont Public Service Board will be holding a public hearing on the proposed expansion of Vermont Gas facilities.

Vermont Gas Systems Expansion

Tuesday evening, September 10, 2013

7:00 p.m 

Middlebury Union Middle School, 48 Deerfield Lane, Middlebury, Vermont 

At a time when climate change is upon us we must think carefully about putting in place new fossil fuel systems that will be around for a very long time. Keeping us hooked on fossil fuels for many years is a bad idea.

The Board is considering a proposal to expand the Vermont Gas Systems pipeline to Middlebury and then beyond. The proposed project would run through valuable wetlands and farmland, and expands Vermont’s reliance on fossil fuels at a time we need to be moving away from these polluting sources. This is the beginning of a bigger project to supply gas across Lake Champlain to New York. It also moves Vermont closer to being able to access gas supplies from fracking in the United States.

Come let the Board know what concerns you have. Tell the Board you want to make sure energy is used wisely and that Vermont takes steps now to reduce our addiction to fossil fuels. It is important for the Public Service Board to hear from you.

Anyone who follows CLF’s work knows about plans being pushed to move oil derived from tar sands in Canada through pipelines that would cut across Vermont, New Hampshire and Maine.  The purpose of the these pipelines is simple and clear: to allow this oil to reach the sea and foreign markets that can only be reached by oil tanker.

It is easy to understand why the Canadian oil industry, and the multi-national petroleum companies with big Canadian investments, want to move the oil extracted from the Tar Sands of Western Canada out to the larger world markets: doing so will mean they make A LOT of money.  The Canadian petroleum industry has explained this for us all very helpfully in an ad found on page 2 of the June-July 2013 issue of the Canadian Public Policy and Politics magazine with the zippy name of “Policy” that we reprint here.

The ad confirms the purpose of the wave of pipeline building being pushed by the Canadian petroleum industry (and ExxonMobil and Koch Industries, the owners of leading Canadian companies like Imperial Oil/Esso and Flint Hills Resources): to raise the price of Canadian oil up to the levels found on many global markets.  As the ad shows, using little prices tags, the price of oil in the North American market hovers around $85 a barrel at times when the same barrel of oil sells for $110 elsewhere in the world. If the producers, refiners and sellers of that oil have access to world markets they can demand that North American customers pay them the higher price if they want to buy this oil.  This reality is especially stark when you look at the fact that oil refining companies with operations in the United States just don’t care if these pipelines get built – they are fully occupied with oil extracted right here at home.  It is just Canadian companies (and the multi-national companies like ExxonMobil and Koch who own Canadian operations) who profit from the push for these pipelines.

So we know who wins if new pipelines carry Canadian oil to reach global markets: the petroleum companies who reap the higher prices found beyond the United States and Canada. But who loses?

The answer to that requires us to think both about the short-term in which we all live our day-to-day lives and the longer-term world in which future generations will have to live.

When we think about immediate and short-term concerns for our families and businesses it doesn’t get any more real than gasoline prices.

Supporters of building pipelines to move Canadian oil to market generally and the highest profile project, the Keystone XL pipeline that would move oil through the middle of the United States from Canada to the Gulf Coast, invoke gas prices as a reason for taking that step, at least implying that the new pipelines will drive down gas prices.

However,  it is well documented in a number of reports and studies that Midwestern drivers would see gasoline prices rise on the order of 42 cents a gallon if that pipeline is built. And this is not surprising – if the oil used to make gasoline is being sold (and bought) at higher prices then gasoline prices will rise.

So in the short term – the losers in this equation? Anyone who buys gasoline or relies upon goods or services that rely on gasoline or diesel fuel that are transported by car, truck, ship or airplane – in short all of us.

And that doesn’t even get into the critical longer term issue: that tapping into the tar sands oil, bringing them to market and burning them would be a large step towards the devastating climate disaster that is unfolding around us and that we need to stop.

There are those who disagree with this assessment. Some politicians argue that tar sands oil from Canada is needed to free ourselves from dependence on oil imported from volatile (and often hostile) nations overseas.  They suggest that these pipelines will simply bring it that oil to markets we, here in the U.S., draw upon, oddly ignoring the stated purpose of the pipelines to bring the oil to higher-priced offshore markets.

And there are thoughtful and detailed analyses that disagree with the climate argument about this oil.  This analysis argues that if the tar sands oil is not brought to market that it will simply be replaced by slightly-easier-to-access Venezuelan oil with a very similar carbon footprint.

That climate impact analysis, and the political argument for building pipelines to tap into tar sands oil, however ignore one important, essential and difficult option: use less oil instead. The advent of electric vehicles, smarter urban development and increases in transit use all converge to show us a way forward and off of oil. The increase in fuel economy standards, a process that is well underway, is a step on that path.

Getting off oil will not be easy.  As the social critic, songwriter and bicycle enthusiast David Byrne has noted, “From the age of the Dinosaurs, cars have run on gasoline.”  Changing something so fundamental will be hard but it is what we need to do; that is what in all of our interests, not laying new pipelines to bring ancient oil derived from the cracking and boiling of tar sands to foreign markets where it will be burned and released into the atmosphere.

On the cusp of the Northern Pass transmission project’s fourth year, it is no closer to community acceptance, government approvals, or construction. But, for the first time since 2011, the permitting process is moving forward once again, as are the developer’s efforts to sell the project to a skeptical Granite State. That means new opportunities to register your concerns with the federal agency reviewing the project and to provide feedback directly to the people on the developer’s team. Here is a Northern Pass update.

Recent Developments

The project came back from a long lull this summer, with the developer, Northern Pass Transmission LLC (NPT), announcing a slightly revised “new” route, initiating a new statewide marketing campaign (complete with long-discredited talking points), holding “open houses” for some towns that would be affected by the project, and unveiling a plan to create a fund to support North Country jobs if the project is approved. Meanwhile, op-ed and letter writers took to the state’s and region’s newspapers to renew the public debate about the project.* A key obstacle to Northern Pass’s revised proposal immediately emerged: it is unclear that the project has the legal ability to use several miles of North Country roads.

In July, the developer filed an amended application for a Presidential Permit to U.S. Department of Energy (DOE). Earlier this month, DOE published a notice in the Federal Register that it had received the amended application and that it would accept public comments on the filing.

NPT rendering of Northern Pass project from the Rocks Estate in Bethlehem, NH

The federal permitting process for Northern Pass will include a full environmental review of the entire project, evaluation of alternatives to the current proposal, and special consideration of the proposed sections that cross the White Mountain National Forest. It is now clear that the federal government’s review of the project will be a critical part of the state’s consideration of the project’s application for state approval as well. As CLF has said from the beginning, by law and as a matter of good government, New Hampshire deserves a federal permitting process for Northern Pass that is comprehensive, rigorous, open, and fair.

While the defects in DOE’s passive and troubling approach thus far have not been addressed, what is encouraging is that, earlier this month, New Hampshire’s Congressional delegation, in an extraordinary moment of bicameral, bipartisan unity, requested improvements in DOE’s handling of the permitting process to ensure a “thorough, transparent, and effective” environmental review, including the public release of information about the project’s impacts and the alternatives to be studied. Their full letter to DOE Secretary Moniz is here. (In a separate letter, the delegation also jointly asked the Secretary of Agriculture to reaffirm that the terms of the Connecticut Lakes Headwaters Easement would not allow the Northern Pass project to use the conservation land it protects, the only project alternative that NPT included in its amended application.)

Get Involved

If you are concerned about Northern Pass, you have three immediate opportunities to weigh in on the project and its amended permit application:

• Submit comments to DOE on Northern Pass’s amended application.

The application is a lengthy document with additional information on the project and a number of exhibits, but much of the proposal is exactly the same as the proposal that has been on the table for almost three years. This is an opportunity to tell DOE, for example: what your concerns are with the project, what you think of the changes to NPT’s proposal, what you think is missing from the application, whether NPT’s discussion of alternatives is adequate, and whether DOE should require NPT to submit more information for public review before the permitting process continues. You may file comments by sending them to Christopher.Lawrence@hq.doe.gov and then sending a hard copy of the comments to Christopher Lawrence, Office of Electricity Delivery and Energy Reliability (OE-20), U.S. Department of Energy, 1000 Independence Avenue SW., Washington, DC 20585.  The deadline for submitting comments is September 18.

Regardless of this deadline, you can continue to file “scoping comments” on DOE’s environmental review of Northern Pass at http://www.northernpasseis.us/. DOE has not announced a deadline for those comments.

• Request intervener status in the DOE permitting process.

You should consider filing for intervener status if you want to play an ongoing role in the process. Landowners, residents of affected communities, and interested organizations, as well as local communities and municipal boards should consider filing for this status, if they didn’t do so in 2010 (a list of those that did is here). To give you an idea of what an intervention filing looks like, take a look at CLF’s filing from 2010 (20 MB PDF). Another simpler example is the 2010 filing of the North Country Council.  The requirements are spelled out in federal regulations (18 C.F.R. 385.214) and DOE’s Federal Register notice. The deadline for filing for intervener status is September 18.

• Attend a developer-sponsored open house.

This is your chance to speak your mind and ask hard questions. Let us know what you hear! The next open house is in Concord on September 4, and more are scheduled. Here are some suggestions:

• These open houses seem to be targeted at residents and landowners; project representatives have maps and computer programs to show where the project would be located. Find out how the project would affect your town or places that are special to you, and tell the representatives what you think about the impacts.
• Ask project representatives to explain if and by how much the project will reduce your energy bill, especially if you are a PSNH customer.
• Ask why they continue to use an estimate of the project’s climate benefits that is completely untrue.
• Ask why the project is not proposing to use the new imports to phase out PSNH’s dirty, costly coal plants.
• Ask why siting a non-reliability transmission project in roadbeds owned by unwilling landowners is different from using eminent domain.
• Ask why underground transmission technology is not an option for more of the project.
• Ask why the proposed jobs fund contributions are less than 1% of the project’s annual profits.
• Insist that project representatives follow up and provide information and proof in response to your questions in writing.
• Keep in mind that these open houses are not part of the public review process for the project. They are a public relations gesture and a showcase for NPT to get its message out. Whether or not they reflect any form of honest engagement with the public remains to be seen.

There will be many future opportunities to participate in the federal and state permitting processes for Northern Pass, including at additional scoping meetings for the federal environmental review, which have not yet been scheduled but will likely be later this fall. We’ll keep you posted. UPDATE: DOE has announced the final round of public scoping meetings for the project’s environmental review for the week of September 23. More on those meetings here.

* A sampling of the many thought-provoking pieces authored by concerned citizens this summer:

• Lee Sullivan, Northern Pass Project Power Is Not Needed (Foster’s Daily Democrat)
• Nancy Martland, Unneeded Power Line Would Scar New Hampshire (Hartford Courant)
• Dolly McPhaul, How Dare They? PSNH Exploiting NH (Nashua Telegraph)
• Kathy Sullivan, Northern Pass Numbers Do Not Add Up (Manchester Union Leader)
• Fergus Cullen, Northern Bailout – PSNH, Public Assets and Private Profits (Manchester Union Leader)
• Terry Cronin, Psst, PSNH, Why Not Join the 21st Century? (Concord Monitor)

There are few more important, and more obscure, agencies in Washington D.C. than the Federal Energy Regulatory Commission the regulator of the wholesale electricity transmission systems and “bulk” (imagine big quantities, like giant tubs from Costco) U.S. electricity markets.

FERC oversees an incredibly complex electricity system.  Our grid meshes together rural systems, where power lines stretch hundreds of miles without interruption, with dense and sophisticated urban networks where millions of people are packed together and drawing power to charge cell phones, watch television, use computers, and make  hospitals, factories, homes and offices all hum.

The age of the elements of these incredibly diverse systems range from “physically touched by Thomas Edison” to “installed hours ago” with all that suggests in terms of technological sophistication.

On top of that physical complexity from a legal and regulatory perspective the American system is a bewildering mix of business and regulatory models with some places served by utilities that own generators and others, like nearly all of New England, served by utilities who are actually generally forbidden from owning power plants. And in contrast to many other parts of the world we mix together privately and publicly owned electricity systems, with many customers served by private “Investor Owned Utilities” but many others served by public entities like “municipal light companies” – and just to make life even more complicated our large generation is mostly owned by private companies with some giant exceptions in the form of hydroelectric dams and other generators owned by States like New York or Federal entities like the Tennessee Valley Authority.

This last bit of complexity is rooted deep in history, notably the declaration by Franklin Roosevelt, when running for President, that he generally favored private ownership of electricity generation and systems but “that where a community — a city or county or a district is not satisfied with the service rendered or the rates charged by the private utility, it has the undeniable basic right, as one of its functions of Government, one of its functions of home rule, to set up, after a fair referendum to its voters has been had, its own governmentally owned and operated service.”  This idea played out in his long run as President when the cornerstones were laid for both gigantic federally owned systems and for the FERC model of regulated private systems.

It is no wonder, given this complex mix of elements that some think the American electricity system is ungovernable.  But a few leaders have succeeded in using the tools available to them to reshape this unwieldy system and steer it in a good direction.  One of those leaders is the current, and soon to be former, FERC Chairman Jon Wellinghoff.

During Chairman Wellinghoff’s tenure FERC has instituted important reforms – pushing time and again for changes that remove the barriers to the new clean resources, like energy efficiency and renewable energy (like wind and solar) that are the rising stars of our energy system.   Under his leadership FERC has pushed aggressively against entrenched policies that gave a leg up to existing generators and utilities simply because they were already in place.  The idea of “pay for performance” that meant that new technologies could earn revenue from providing services to the electricity might sound simple and obvious but FERC has had to fight to make that idea a central tenet in its decision making, beginning with the critical idea (incubated in New England) that efforts to reduce electricity demand should be compensated in markets just like resources that generate power.  Application of the pay-for-performance principle has meant that new technologies that flourished in a small pilot market here in New England can spread across the nation – opening doors for electricity storage systems that will revolutionize the way we generate and use energy.

The biggest single effort that FERC has undertaken during the Wellinghoff era is almost certainly the Order 1000 initiative. Order 1000 mandated thoughtful regional planning of the electricity system across the nation and consideration of public policies, like state renewable energy standards and greenhouse gas reduction mandates, in electricity system planning and infrastructure decisions, among other systemic reforms.  This mammoth effort to reshape the current national electricity system is still in progress but should pave the way for significant progress in managing the energy system transformation and transition beginning to unfold around us.

The departure of Jon Wellinghoff from FERC does not have to mean the end of progress on all of these fronts.  FERC has maintained a collegial and effective decision making process that cuts across party lines (which is a pretty stunning thing to say in 2013 about any institution with a mix of Commissioners from the two main political parties).  Very often its decisions are unanimous or feature a very focused and specific dissent from one or two Commissioners disagreeing with some specific aspect of the decision but accepting much of what the majority are doing and saying.

This uniquely effective institution will maintain its balance and continue to make progress if Ron Binz, the nominee proposed by President Obama to take over as Commissioner and Chairman of FERC, is confirmed by the Senate.  Mr. Binz is accustomed to working across party lines as he comes from the quintessentially “purple” state of Colorado where he had a solid record as a consumer advocate, chair of the state utility commission and energy expert and innovator.

We are in a time of change and challenge: coal plants are retiring and the United States shows signs of finally getting serious about using energy efficiently while reaping the power of the wind and the sun.  Such times call for steady leadership at the essential Federal energy regulatory body.  That is what Jon Wellinghoff has shown – and it is what Ron Binz can provide going forward.

photo courtesy of lydia_shiningbrightly@flickr.com

If your doctor puts you on a diet to prevent major health problems, it is a bad idea to fill your pantry with potato chips. Simply hoping you don’t eat the chips staring you in the face is a bad way to try losing weight.

Likewise, if you want to reduce fossil fuels and combat climate change, it is a bad idea to blindly expand pipelines that deliver these fuels to your doorstep and beyond. These are pipes that will be in place for the next 50 to 100 years. In that timeframe we need to move away from dirty fossil fuels, including fracked gas.

In Vermont, the proponents of a proposed gas pipeline expansion are sadly ignoring the long term impacts.

Instead of proposing a project that actually meets our climate change diet needs, the proposed gas expansion in Vermont is doing the equivalent of filling our energy pantry with potato chips. Chips that we will stare at every day and try not to eat in order to stay on our diet.

This is a bad idea.

The gas cheerleaders, including the Shumlin Administration, are hoping folks will only eat the chips as a small snack. But sadly they are not proposing any limits on the use of the gas, or sizing the project to meet our very limited dietary needs. They are not even considering the use of the full pipeline capacity in their analysis.

Testimony from Conservation Law Foundation provided by Dr. Elizabeth Stanton, explains the considerable uncertainty underlying the claims of Vermont Gas and states:

“As long as there is significant uncertainty in the emissions from natural gas, Vermont risks adopting long-lived natural gas infrastructure that is not compatible with meeting Vermont’s 2050 greenhouse gas reduction goals. Approving Vermont Gas’ request represents a gamble, on the part of the PSB, that Vermont’s current and future sources of gas will be at the low end of the current range of possible emission rates in the literature and not at the higher end, and that the uses of the gas will only replace oil or propane. Both assumptions are unlikely and as a result the project proposed will most likely increase greenhouse gas emissions over the life of the project.” (Stanton Testimony at 9-10).

The testimony from the Public Service Department, which is responsible for the State’s energy plan, and helping us meet our climate goals, provides various manipulations of others’ testimony but still simply assumes all the gas in the pipeline will replace oil use. (Poor testimony at pg 8). That is an analysis that is far too limited.

The testimony from the Agency of Natural Resources recognizes that if any gas supply sources have emissions as high as some of those documented, then the claimed emissions benefits of the project “could be reduced or even result in a scenario of increased GHG emissions relative to oil.” (Merrell Testimony at pg. 3). Instead of recommending ways to reduce that impact, however, the Agency calls for annual reporting. While more information is always good, the Agency’s suggestion will be about as effective as closing the stable door after the horse has already run away.

It is past time for Vermont to begin taking its climate change goals seriously. Expanding our addiction to fossil fuels by expanding gas pipelines in Vermont is irresponsible.