Mr. Michael Henderson
Director, Regional Planning and Coordination
ISO New England
1 Sullivan Rd.
Holyoke, MA 01040

Re: Scenario Analysis Stakeholder Working Group -- Final Scenario Analysis Modeling Assumptions

Dear Mr. Henderson:

First, I wish to express our thanks to the ISO-NE for its initiative and hard work that brought us through the Scenario Planning Analysis. Moving forward, regional policymakers, stakeholders, and the public will need to work together to understand the trade-offs necessary in planning for our future electricity needs. Your efforts will provide the essential tools necessary for making informed decisions.

I represent Industrial Wind Action Group, a national organization focused on raising awareness of the negative impacts of utility-scale wind if sited improperly. In this capacity, our organization closely monitors wind energy proposals, development, and post-construction performance and attendant impacts. As you know, we've raised a number of concerns throughout this scenario planning process regarding the reliability and effective capacity of wind energy, particularly for onshore installations.

We are writing to express our concerns regarding some of the assumptions and results presented in the Final Scenario Analysis Modeling Assumptions. While we understand that, to some extent, this process is as much an academic one as it is a practical effort, there are a number of assertions and assumptions detailed in your draft report which grossly overstate the opportunity for wind development and performance in the region. If the results of this effort are intended to aid our region's policymakers, it is essential that the information provided be as realistic and as accurate as possible. Our areas of concern are outlined below. We recognize that time may be of the essence and regret the lateness of our comments. But given the magnitude of the concerns we raise, we respectfully ask that you take the time to reconsider several of the assumptions pertaining to on-shore wind.

Editor's note: The remainder of this document and associated appendices can be downloaded below.