Memo from the Massachusetts Department of Public Utilities Chairman, Paul Hibbard, to the ISO New England. Chairman Hibbard expresses his concerns over the push to regionalize costs for building expensive transmission lines to service renewable projects (wind) built far from load centers. Current FERC rules are unclear on how to justify distribution of the costs across all ratepayers within the region unless it can be shown such transmission is needed to ensure the reliability and integrity of the grid.

This document includes studies in Maine, Maryland, Minnesota, New Hampshire, New York, Pennsylvania, Vermont, Virginia and West Virginia.

Below are two Phase I Avian Risk Assessments reports, prepared by Paul Kerlinger, for Vermont's East Haven Wind Farm (July 2003) and New Hampshire's Lempster Mountain Wind Power Project (June 2005). Phase I assessments have proven inadequate in assessing mortality at several sites in the U.S. including Mountaineer in West Virginia and Meyersdale in Pennsylvania. The US Fish and Wildlife Interim Wind/Wildlife Guidelines calls for multi-year evaluation of avian and bat activity using remote sensing.

Renewable energy sources have disadvantages as well as advantages, however. Although their costs have decreased in recent years, many renewables are still more costly than traditional sources. Some are also available only intermittently; for example, wind can be variable and hydroelectric is seasonal. And while many people are in favor of renewables in principle, many are also unhappy when faced with the prospect of a windmill or a trash-burning power plant in their neighborhood. These facilities face the same siting and investment difficulties that any electrical facility would, as the developers of a proposed wind farm off the coast of Cape Cod have discovered in recent years.

...the MEA Report can be used to estimate the value (avoided emissions) of Renewable Energy Certificates (REC) by providing both REC suppliers and stakeholders with information that can be used to communicate the environmental benefits of RECs and works to enhance the overall REC marketplace.

Editor's Note: As noted below under Methodology [emphasis added], this report appears to substantiate the point that wind energy would not backdown "baseload" generation.

This presentation indicates that for New England the increasing demand for summer-time electricity is greater and increasing faster than winter-time demand. The fast-rising need for power in summer will likely result in construction of new power plants to keep ahead of demand - although inland industrial wind plants will not be able to contribute much to this demand period due to their very low capacity factor during summer months.

Comments to FERC by the New England Conference of Public Utility Commissions and the Vermont Department of Public Service