Breaking News: NESCOE Suspends Votes on Tariff Proposals

Aug 1, 2014 by  | Bio |  9 Comment »

The New England States Committee on Electricity (“NESCOE”), an entity created to carry out the policy directives of the New England governors, had been hurtling down the track towards forcing electric customers to pay for a massive, new natural gas pipeline as well as new transmission projects to import large-scale Canadian hydropower. This morning at the monthly meeting of the voting participants in the New England Power Pool (“NEPOOL”), NESCOE signaled that the train is going to slow down.

In a surprising and welcome move, NESCOE announced at the meeting that it is delaying action on both the gas and electric proposals that it has been pursuing–proposals that have the potential to put billions of customer dollars at risk. NESCOE formally requested that all of the votes that had been scheduled for the proposals be taken off the calendar to allow for a delay of  “at least a month.”

For months now, CLF has been calling upon NESCOE and the New England Governors to bring these flawed proposals and the reasoning behind them out into the open. Until now, the formulation of and negotiations around these proposals have been conducted almost completely behind closed doors.  With this delay, NESCOE and the officials who direct its actions have a real opportunity to address procedural and substantive concerns — raised by CLF and other stakeholders —  by embracing a transparent, open process that includes a meaningful assessment of alternatives, including: efficiency, better utilization of existing infrastructure, and more renewable distributed generation. After all, the initial studies for NESCOE indicated that under a “low demand” scenario there would be no need for additional infrastructure at all.

This time around, CLF urges the Governors to require NESCOE to include an evaluation of the cost-effectiveness of all alternatives, as well as an assessment of which solutions are actually consistent with achieving the long-range energy and climate objectives of the New England states.

The NESCOE announcement also followed a compelling argument by CLF at the last Transmission Committee meeting on July 22, regarding the need for these proposals to be properly vetted through ISO-NE’s “Major Initiatives” process. These proposals carry with them the power to shape New England’s energy system for the next 40-50 years, so an open, public process is imperative. CLF will continue to provide the public with up-to-date information as it becomes available.

4 Things You Should Know About CLF’s work on Natural Gas

Jul 29, 2014 by  | Bio |  Leave a Comment

As I write this, CLF President John Kassel and I have just left the White House. We were there as part of a small group of environmental leaders, industry and union heads, regulators, and policy makers invited to participate in a special White House roundtable on reducing methane emissions – a potent greenhouse gas with 34 times the heat-trapping power of carbon pollution. CLF received this special invitation in recognition of our nearly five decades of work to transform New England’s power system. Over the past few years, CLF has been fighting to clean the air and clear the way for more efficient technologies by taking on the owners of obsolete, polluting power plants – and winning. What you may not realize is that, with natural gas now dominating the discussion about our energy future, we’ve also been leading the region to ensure that we “get gas right.”

Here are 4 things you should know about CLF’s advocacy around natural gas:

1. Leading the Way on Leaks: CLF was one of the first organizations to call for more attention to the “fugitive emissions” from natural gas. We partnered with academics from Boston University to map leaks throughout the city of Boston and issued a first-of-its-kind report on the scope of the problem of leaking pipelines as well as policy tools to tackle the problem. Although natural gas burns cleaner than coal at the smokestack, natural gas is over 90% methane, and when it leaks from pipelines or other equipment, methane’s heat-trapping power is potent. Unless leaks are substantially reduced, they can virtually erase any potential climate benefits of switching to natural gas.

2. Taking the Long View: There is a role for gas, but it must be limited. We cannot simply replace every retiring coal and oil plant with natural gas and expect to leave our children with a livable climate. CLF understands that the increased use of existing natural gas electric generation capacity has helped to pave the way for the retirement of dirtier coal plants, but building new, long-lived natural gas infrastructure without any constraints isn’t compatible with meeting our climate goals.

3. Crafting Real-World Solutions: CLF struck the first agreement in the nation to place binding greenhouse gas emissions limits and a date certain for shutdown on a new natural gas fired power plant. When Massachusetts regulators failed to establish meaningful GHG limits for a proposed new gas plant, CLF stepped in and negotiated a settlement that requires the project to limit its useful life to 2050 and reduce its GHG emissions over time consistent with the requirements of the Massachusetts Global Warming Solutions Act.

4. Building Better Markets: CLF understands the intricacies of the electric and gas markets and has been working to develop market refinements that create more transparency and liquidity in the gas markets in order to reduce price spikes through better use of existing supply rather than overbuilding new capacity. CLF’s proposals for a winter reliability solution, had ISO-NE adopted them last winter, would have lowered prices and lowered pollution. CLF continues to fight for better market design that sends the right price signals to maximize efficient use of our resources. New England is ahead of the curve on clean energy and climate change – and that’s why CLF was the only regional environmental organization invited to be part of this discussion, which will ultimately shape national policy around methane emissions as part of President Obama’s Climate Action Plan.

Stopping State Handouts for Sprawl

Jul 21, 2014 by  | Bio |  4 Comment »

Over the past year it has been troubling to see large new development projects planned for areas around Vermont’s highway interchanges. It was not that long ago that Vermont’s then Governor Howard Dean issued an executive order protecting our highway interchanges from sprawl development.

Our public dollars created the interstates and we have a responsibility – to our pocketbooks and to our environment – to take good care of them.

That responsibility includes avoiding traffic snarling commercial sprawl at our highway exits.

Highway sprawl is expensive. A look at the roadway improvements planned around Burlington, Vermont, including two multi-million dollar interchange re-builds, show that many of them are needed now because of the commercial sprawl that sprang up around these exits.  As federal transportation dollars dwindle, we can ill afford to promote sprawl near highway exits that is guaranteed to require new and expensive upgrades in the coming decades. As we drive more to reach commercial developments near highway exits we increase pollution and greenhouse gases as well.

Governor Dean’s executive order from 2001 recognized that development at interstate interchanges can mar not only the scenic character of the state, but also can impair natural and agricultural resources and harm tourism. It directed state agencies to foster conservation of land in and around the highway interchanges.

Moving away from Governor’s Dean’s vision, this past year developers proposed changing Vermont’s Act 250 land use law to make it easier to build on valuable farmland. A poster child for this was a massive new commercial project planned for the Randolph highway exit. The plan would pave nearly all the farmland at the highway exit and replace it with a large commercial development, a portion of which would serve as a state visitors’ center.

Instead of protecting land around the interstate, state agencies would be partners with this sprawl development.

The proposed Act 250 change that would have helped this project never passed the Vermont Legislature, and the project appears to be on hold.

Now there is a proposal for a new truck stop-like huge convenience store along with a “state sanctioned welcome center” on a farm field just twenty miles up the road at the Berlin exit in Vermont. Traveler services are needed, but they come at too high a price if they are married to massive sprawling commercial developments at our highway exits.

This past year the Vermont Legislature did amend Act 250 to provide stronger protections against strip development outside of town. If some of these projects at our highway interchanges move forward it will be a good test of this new protection.

In contrast to these highway developments, the Vermont Judiciary just announced that it will move the State’s Environmental Court to downtown Burlington. This is good news. The Environmental Court, which hears appeals of Act 250 and local land use decisions, will no longer be in a stand-alone office building on a farm field outside of town. Instead it will set a good example for developers by being better integrated with other courts and closer to services in a downtown location.

Our public dollars, natural resources and scenic beauty are too important to squander in exchange for some short-term savings that burden future generations with more pollution and higher costs. Like the Environmental Court, the public investments and development decisions we make today should stand as good examples for generations.

A version of this post first appeared in the Sunday July 19 edition of the Rutland Herald and Barre- Montpelier Times Argus.

The Elephant Not in the Room at the New England Governors – Eastern Canadian Premiers Conference: Tar Sands Fuels and Climate Impacts

Jul 10, 2014 by  | Bio |  Leave a Comment

This Sunday marks the start of the annual New England Governors–Eastern Canadian Premiers (NEG-ECP) Conference. Each year, these regional leaders join forces to discuss pressing policy issues of mutual importance to their states and provinces. While energy issues have been a regular feature of recent NEG-ECP conferences, we understand that a certain energy elephant will be conspicuously absent from the conference room this year: tar sands fuels.

01212014 tarsands pic 1

Dirty tar sands fuels could soon make up 18% of our fuel mix – jeopardizing New England’s hard-won efforts to curb carbon emissions.

Tar sands fuels are slated to hit the region soon, and in a big way. While our current fuel mix is virtually tar sands free, the expansion of tar sands pipelines in the region and nationally means that this dirty fuel could soon make up as much as 18% of our fuel mix by 2020. This rapid shift has huge climate consequences, given that tar sands fuels emit significantly more greenhouse gases than conventional fuels. While New England has been a national leader in pursuing policies to reduce carbon pollution, tar sands could wipe out all those hard-won efforts. A rapid 18% increase in tar sands fuels penetration would not only offset the progress the region has already made in reducing emissions under the Regional Greenhouse Gas Initiative, but impede future efforts as well.

The environmental community has called on leaders attending the NEG-ECP conference to make tar sands fuels a central issue. Twenty-five leading environmental organizations sent the letter below to the organizers of this year’s NEG-ECP conference. There have been some encouraging signs that individual states and cities are starting to look at the issue – South Portland, Maine, for example, is considering an ordinance aimed at preventing shipping of tar sands fuels, and the New Hampshire legislature passed several bills to ensure pipeline safety in 2014, one of which Governor Hassan herself will sign at a ceremony directly after the conference. But the issue has still not been added to the agenda for the NEG-ECP conference. CLF and our partners will continue to urge the New England states to make tar sands-derived fuels a priority issue, even after the delegates to this year’s conference go home.

Update: Shortly after publishing this post, CLF received this response letter from Governor Hassan in New Hampshire. Governor Hassan notably commits to raise the issue of tar sands with delegates of the NEG-ECP conference in the coming year and notes that states in the region are working together to develop the tools necessary to track the carbon intensity of petroleum fuels entering the region. We commend Governor Hassan for these important steps.


Twenty-five national, regional, and state environmental groups signed the following letter, which was provided to each of the New England Governors and Eastern Canadian Premiers. Read the full letter with all signatories.

June 13, 2014

The Honorable Maggie Hassan
Governor of New Hampshire
2014 Chair of New England Governors-Eastern Canadian Premiers Conference
State House
107 North Main Street
Concord, NH 03301

Dear Governor Hassan,

We write with respect to the upcoming New England Governors and Eastern Canadian Premiers (NEG-ECP) Conference scheduled for July 13-15 this year in New Hampshire. We ask the Conference to confront growing public concern about the encroachment of tar sands into Eastern Canada and New England by pipeline, rail, barge, and as a refined fuel, and convene working committees to evaluate the threats posed by tar sands spills and evaluate standards for fuel carbon intensity in the region.

As you are likely aware, pipeline proposals in both the U.S. and Canada have focused significant public attention on the risks of transporting tar sands diluted bitumen through pipelines. Simultaneously, new research suggests that the annual influx of tar sands-derived fuels into the U.S. Northeast and Mid-Atlantic region could have a substantial climate impact that would negate the carbon pollution reductions the U.S. Northeast region has sought under its landmark Regional Greenhouse Gas Initiative. Climate policies in Canada such as Quebec’s greenhouse gas cap and trade system could be undermined.

Together, the transport of tar sands diluted bitumen via pipeline and the consumption of tar sands as a refined fuel is a grave risk to the region. We believe the NGA-ECP Conference should provide state and provincial decision-makers with an opportunity to understand these risks and identify policy solutions to address these pressing issues.

Pipeline proposals to carry tar sands diluted bitumen
Public concern over the transport of diluted bitumen has grown considerably in the past several years. Many of the concerns have focused on the potential impact of a spill to waterways given that diluted bitumen has different chemical properties than conventional oil.   Now that Enbridge’s Canadian Line 9 is approved to bring tar sands to Montreal, many in the U.S. believe that the Portland Pipe Line Corporation will request permission from the U.S. State Department to reverse the flow on the Portland-Montreal Pipe Line (PMPL) in order to transport tar sands. In response, dozens of communities in Vermont, Maine, New Hampshire, and Quebec have passed resolutions in opposition to a reversal. A spill of diluted bitumen from the PMPL pipeline could threaten drinking water supplies, wildlife, fishing and other water dependent industries, and public health across New England.

At the same time, TransCanada is moving ahead with its Energy East pipeline proposal which, if approved, would carry tar sands diluted bitumen and potentially impact hundreds of communities across all of Eastern Canada. Once diluted bitumen is loaded onto tankers there is also the possibility of a marine oil spill into both the Gulf of Saint Lawrence and the Bay of Fundy. The pipeline would also have the climate pollution impact equivalent to adding seven million new cars to Canada’s roads.

An influx of tar sands into the region’s refined fuel mix
A new analysis indicates that by 2020, as much as 18 percent of the U.S. northeast region’s fuel supply could be derived from carbon-intensive tar sands ­- up from less than 1 percent in 2012. If that occurs, it would increase greenhouse gas emissions by approximately 10 million metric tons per year. This would offset the carbon pollution reductions that the region is seeking under its landmark Regional Greenhouse Gas Initiative over the next five years. Unless states take immediate action to hold the line against growing carbon emissions, and boost efforts to support the clean fuels sector, the influx of tar sands fuel would undo years of progressive climate policy.

We ask the NEG-ECP adopt a resolution to convene a committee of environmental agencies to develop standards and recommendations around fuel carbon intensity across the region.  Last year, the NEG-ECP passed Resolution 37-3, concerning transportation.  This resolution built on priorities raised at the 2012 conference to facilitate a more sustainable transportation future and identified the need to reduce greenhouse gas emissions while exploring opportunities to advance the green economy through investments in clean, efficient, and sustainable transportation. A resolution at the 2014 conference addressing the encroachment of high carbon intensity fuels like tar sands in our transportation fuel mix is correlated to, and logically evolves from, the transportation resolutions adopted at the 2012 and 2013 conferences.

We also ask the conference adopt a resolution to more fully investigate the threats associated with the transport and spills of diluted bitumen both by pipeline, rail, and barge.   Rapidly growing evidence shows that spills of diluted bitumen pose greater threats to water resources than conventional oils, with serious implications for emergency response and clean up. Major tar sands spills in Marshall, Michigan in 2010 and Mayflower, Arkansas in 2013 provide direct evidence of these unique challenges. Now is the time for state and provincial decision-makers to better understand the inherent risks of transporting diluted bitumen and options to confront and eliminate these risks.

We would also be pleased to have an opportunity to present our views and research on these issues and thank you for considering these recommendations.




Vermont Gas — Faulty Analysis, Faulty Results

Jun 16, 2014 by  | Bio |  Leave a Comment

Taking climate change seriously means taking a hard look at proposals to expand fossil fuels in the region. Science tells us we need to move quickly – run, don’t walk – away from fossil fuels to cleaner, renewable sources of energy.

The massive new pipeline proposed by Vermont Gas will run (not walk) through Vermont and across Lake Champlain to serve an industrial customer in New York. It will be a pipeline in place for 50 to 100 years – long past the time we need to move away from fossil fuels.

Common sense says a new fossil fuel project will increase greenhouse gas emissions. The analysis from Vermont Gas defies common sense. It is based on unreasonable and unrealistic assumptions about future uses, methane leaks and the global warming features of methane.

Following current science, CLF filed testimony at the Public Service Board showing the troubling and faulty analysis by Vermont Gas.

Professor Jon Erickson, a leading ecological economist at the University of Vermont explained the imperative to reduce emissions based on the recent IPCC assessment and how expansion of natural gas “would likely result in considerable, long-term lock-in to natural gas use resulting in total GHG increases and nonrenewable energy dependence that is incompatible with long-term state policy.” (p.8). You can read the testimony here.

Shanna Cleveland who authored a report of gas leaks and has been active in a number of regional gas proceedings explained several shortcomings in the Vermont Gas analysis including:

1) leak rates that underestimate emissions (pp.  8-10); 2) emission estimates that do not correspond to the system that supplies gas to VGS (p. 10); 3) unreasonable assumptions by VGS that all gas will replace oil (p. 10-13); 4) failure to use the most recent figures for the global warming potential of methane (pp. 14-16); and 5) failure to account for excess capacity (p. 16). These shortcomings show that VGS significantly underestimates the emissions that will result from the project. Ms. Cleveland then identifies steps that can be taken to reduce emissions and make sure we use our limited supply of gas wisely. (p.20-25). You can read the testimony here.

James Moore, a developer of solar projects for consumers explained how cleaner, low cost solar is available now to meet heating needs and how expanding natural gas undermines Vermont’s ability to meet its clean energy goals. (pp.5-6). You can read the testimony here.

As President Obama said in a recent interview with Thomas Friedman of the New York Times: “Science is science …. And there is no doubt that if we burned all the fossil fuel that’s in the ground right now that the planet’s going to get too hot and the consequences could be dire.”  Concerning natural gas, where methane leaks can wipe out any climate benefits of natural gas, it is important for states to get it right. That means saying “NO” to carte blanche approval of massive new pipelines. It also means industry and regulators building in conditions to pipeline use that support the needed transition to cleaner and lower cost energy supplies.

Public Hearing: Vermont Gas Pipeline Expansion

Jun 11, 2014 by  | Bio |  Leave a Comment

The Vermont Public Service Board will be holding a public hearing on the proposed Phase 2 expansion of Vermont Gas facilities.

Vermont Gas Systems Expansion
Thursday evening, June 12, 2014 
7:00 p.m 
Middlebury Union High School Auditorium
73 Charles Ave., Middlebury, VT

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 through Addison County and across to New York to serve the Ticonderoga Mill. 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 prior post explains some of the problems of expanding natural gas use.

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

Maine is Ground Zero for Determining the Role of Natural Gas in New England’s Energy Future

Jun 10, 2014 by  | Bio |  Leave a Comment

One of the greatest energy and climate challenges facing Maine and the nation is making sure we get right the role of natural gas in our energy – and climate – future.

Right now, Maine is ground zero for this challenge. The Maine Public Utilities Commission (PUC) has opened a proceeding that could result in Maine electric customers paying up to $1.5 billion and three to four times their fair share of an interstate natural gas pipeline. Advocates for the plan say that those costs to Maine customers would ultimately be recovered through future savings on energy bills. Such a financing scheme for new infrastructure would mark an unprecedented and risky entry into the private energy markets by Maine and the other New England states. At the same time, even though natural gas is considered cleaner than coal and oil, it still releases significant greenhouse gas emissions, making the PUC’s proposal one that will have long-term impacts on our efforts to address climate change and to reform the energy markets.

CLF has taken the lead in this case to ensure a transparent, fair, and thorough assessment of this speculative gambit to manipulate private gas markets, as it represents a significant financial risk to electric customers. What’s more, we believe that a new interstate natural gas pipeline will overbuild our capacity and will result in an over-commitment to and over-reliance on natural gas, a fossil fuel with a history of price volatility that presents a reliability risk to our electrical system.

Most significantly, state and regional goals of reducing our emissions of greenhouse gasses by 80% by 2050 will be thrown out the window if this strategy is approved by the PUC, along with any hope of mitigating the harmful effects of climate change. CLF will argue that before any new pipeline capacity is added, we must maximize efficient use of our existing pipeline system, make market changes that allow for more efficient and flexible use of existing gas supplies, fully utilize existing LNG and gas storage capabilities, and expand pipelines incrementally and only if and when market-driven need calls for it.

While Maine is ground zero on this issue today, similar proposals to expand natural gas infrastructure are cropping up across New England. CLF will be vigilant in ensuring that New England does not rely on natural gas as the sole answer to our energy supply issues, but rather as a bridge to a cleaner-energy future for the entire region.

New England Out Front in New Action Plan for Zero-Emission Vehicles

May 30, 2014 by  | Bio |  Leave a Comment

Yesterday the New England states of Connecticut, Massachusetts, Rhode Island, and Vermont, together with California, Maryland, New York, and Oregon, released a new Action Plan announcing the roadmap to achieving their collective goal of putting 3.3 million zero-emission vehicles (ZEVs) on the road by 2025.  The Action Plan puts meat on the bones of a pledge first introduced by the eight states in a Memorandum of Understanding (MOU) on October 24, 2013.

By increasing the sale of ZEVs—which include battery electric vehicles, plug-in hybrid vehicles, and hydrogen fuel cell vehicles—the eight MOU states are taking an important step in combating the air pollution and climate change challenges we face. The Action Plan takes critical steps to make the 3.3 million goal a reality, including these priority multi-state actions:

  • Increase collaboration among the states and private entities to promote the availability of ZEVs to consumers;
  • Evaluate opportunities to incentivize increased consumer adoption of ZEVs;
  • Increase use of ZEVs in public and private fleets;
  • Remove barriers to retail sale of clean transportation fuels;
  • Increase access to ZEV refueling stations at workplaces; and
  • Coordinate advances in ZEV refueling infrastructure.

Will we soon be seeing more zero emission vehicles in 4 New England states?

The Action Plan also identifies further action that can be taken on a state-by-state basis, including: devising incentives for ZEV purchasers through “point-of-purchase” rebates or state and federal tax credits, access to high occupancy vehicle (HOV) lanes, preferential parking, reduced tolls, and reciprocity across MOU states.

In order for the MOU states to achieve their goal of 3.3 million ZEVS on the road by 2025, it will be critical for individual states to pursue these more ambitious actions, above and beyond the collective activities identified in the Action Plan. For instance, the consumer rebate program just announced in Massachusetts is a model other states can adopt to increase ZEV purchases.

The eight states participating in the MOU account for approximately one quarter of new car sales in the nation.  California’s ZEV program, developed by the state’s Air Resources Board, was the first model for promoting and supporting ZEVs state-wide.  The eight states have also been working toward lowered greenhouse gas (GHG) emissions and increased ZEV use at the local level, with examples like the all-electric transit bus fleet launched in March in Worcester, Massachusetts.

Unlike internal combustion vehicles, ZEVs do not emit GHGs through their tailpipes. While the generation of electricity and hydrogen required to operate ZEVs results in GHG emissions, the net lifecycle emissions for ZEV fuels is still less than conventional vehicles overall, with varying GHG profiles depending on the region and energy source.  With current innovations and increasing support for renewable fuel sources, such as solar, wind, and geothermal, electricity production for electric vehicles will increasingly be sourced by low or zero emission sources.  In addition to decreased GHGs, implementation of the ZEV Action Plan will lead to decreased smog and therefore better health, increased national security, economic growth, and savings for consumers. Electricity is one-third the cost of gasoline or diesel per mile, and ZEV maintenance costs are far below those for conventional internal combustion vehicles!

CLF applauds the leadership and commitment of the eight ZEV MOU states, and urges additional states to hop on board.

Public Hearing: Vermont Gas Pipeline Expansion

May 5, 2014 by  | Bio |  2 Comment »

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

Vermont Gas Systems Expansion

Wednesday evening, May 7, 2014

7:00 p.m 

Shoreham Elementary School,  130 School Road, Shoreham, 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 through Addison County and across to New York to serve the Ticonderoga Mill. 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 prior post explains some of the problems of expanding gas use.

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.


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