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.

Why did you petition to become an intervenor in this matter before the NH SEC?

With New Hampshire’s recent reinstatement of PILOT agreements and legislative efforts to a Renewable Portfolio Standard, the regulatory groundwork is being laid for more wind facilities to enter the state. Yet, New Hampshire, like many states, has no consistent regulatory process in place for reviewing these projects to ensure our environmental, societal, and economic interests are protected. The work the NH SEC has agreed to undertake in reviewing this application is precedent setting. How the committee approaches its review and the weight it places on arguments presented by all sides will impact other developments in the State as pertains to renewable energy projects.

There are a multitude of conflicting issues at play when considering any wind project. My commitment to this process is to help provide, to the best of my ability, valuable and timely information that will assist the Committee in making an informed decision on this application.

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