StopNED - Stop the Northeast Energy Direct StopNED.org #PIPELINE stopneaors December 21, 2014 To the Acting Commissioner, Dept, of Energy Resources, Meg Lusardi and members of the Low Demand Study Team: We at StopNED are participating as stakeholders in this study as members of communities threatened by massive fossil fuel infrastructure construction, We are conservation commissioners, land trust members, affected landowners, and concerned citizens worried about our communities, the Commonwealth and the effects of continued fossil fuel use globally. We had great hope reading the RER for the study since members of our coalition were among the group who met with Governor Patrick to inspire this Low Demand Study. Clearly we are gravely disappointed in the direction the study headed while meetings were postponed. Initially we understood the study as defined by stakeholders and the Administration: The goal of DOER's study is to determine, given updated supply and demand assumptions, whether or not new infrastructure is required, and if so, how to optimize for environmental, reliability, and cost considerations. Key questions for consideration include: 1) When considering all energy resources, which resources offer the greatest net benefits when assessing for reliability needs, cost savings and reducing environmental effects including lower GHG emissions. 2) In combination, how far can these alternative resources go in replacing retiring generation capacity?" At Thursday's stakeholder meeting we were stunned to see the outcome did not address the original intent of what was agreed to be the charge of the study. How do you execute a study of energy capacity and generation with no regard for compliance with the Global Warming Solutions Act (GWSA)? Especially when you are dealing with a fossil fuel, methane, known to be 34X more harmful to the environment without even considering all of the effects from fugitive emissions that occur during extraction, blowing off, and leaking. How do you use study results that leave the Commonwealth further out of compliance with its own law? "OER Agency Document Number: RFR-ENE-2015-012Synapse recently submitted testimony” regarding the avoided costs of GWSA compliance for a study commissioned by the Massachusetts Departments of Energy Resources and Environmental Protection, why didn't you take this knowledge into account in this Low Demand study? Why in this study are there no financial considerations for non-compliance? The City of Boston, ranked &th most at risk coastal city in the world, is fully aware of the economic impact of impending climate change having just released their updated 2014 Climate Action Plan. As one commenter said last Thursday, how do you complete an energy study as if climate change is not one of the most pressing issues facing mankind today? We understand that environmental destruction, loss of ecosystem capital, decreased property values, risk to our drinking water supplies, disruption of our way of life, all have no part in your study as they do not have a tangible price tag you can "model." These are high costs for all of us, especially those directly affected. We are labeled "low collateral” because our homes, our businesses, our low population rural lives would be a small price to pay should something go awry while natural gas capacity and presumably consumption are increased. We are likely to be paying these high intangible costs for the obvious profit from natural gas exportation, not for simply fuffling a New England need, when you consider that 4.Sbctid are currently proposed where your study finds a shortage of only 0.6 - 1.1befid We are questioning the justification for removing winter reliability, demand response, and storage options for no annual savings as stated by your “Key Changes to Feasibility Study and Supply Curves” slide #12, The reason given to bring in more gas is not annual but to meet peak demand requirements of a couple of hours on a few days? We question the measure used to determine “feasible and practical” when discounting renewable energy options for the study. Given the growth of home and small business solar in Massachusetts in recent years, and despite the ending of SREC | and I this growth is likely to continue. This growth also likely will include storage that would certainly be “feasible and practical’ if providing electricity during the hours of early evening. In addition to our own comments, we would like to reassert the points that were made during Thursday's breakout session among the “enviro groups” 1. Report limited to MA. The analysis is limited to Massachusetts, while the challenge and solutions are regional. Additional analysis is now needed at the regional level to determine the optimal resource mix. For example, we know that NH and ME have a lot more efficiency potential, yet this potential is not captured in the MA-focused study. 2. Report's obsolescence based on unforeseen/unanticipated market developments. Recent developments in energy markets — particularly the drop in oil and LNG prices ~ makes many of the assumptions outdated already. For example, it may be much more attractive to rely more on LING and new gas storage on the system. 3. Misleading assumptions about economics of pipeline capacity. Assuming optimal economics for additional pipeline capacity (i.e. 80% annual utilization rate) skews the results to portray new capacity in a favorable light, whereas in reality pipelines are often oversized, which could lead to lower utilization and worse economics.4, NO GWSA Compliance. All scenarios are out of compliance with the GWSA, and additional Pipeline pulls us further out of compliance, potentially requiring more expensive emissions reductions outside of the electric sector. 5. Limited consideration of alternatives, The study is limited in its consideration of alternatives, specifically: Importing cheaper LNG through existing infrastructure and storing more LNG in the. system Doing more on energy efficiency Incorporating offshore wind, which politically is a likelihood Including transmission from Maine to carry wind backed by hydro from Labrador, which would have a higher annual capacity factor and greater benefits than Quebec system power. 6. ALL caveats should be clearly stated/summarized up front, This is in addition to being restated at the beginning of each section which is what Acting Commissioner Lusardi indicated DOER plans to do. Hopetully, the new Baker administration can use the identified shortcomings of this study to commission a new one whose results will move the Commonwealth forward to a scenario of energy efficiency, sustainable energy generation and compliance with a fully regulated GWSA. The Patrick administration has let the non-industry stakeholders down with the derailment of this study, Respectfully, ‘The members of the StopNED coalition Represented at the Low Demand Study by Paula Terrasi, Rob Rand, and Cathy Kristofferson Contact info: info@stopned org CC: Governor Deval Patrick Governor-Elect Charlie Baker EOEEA Secretary Maeve Vallely-Bartlett EOEEA Secretary-Elect Matthew Beaton Attorney General-Elect Maura Healey US Senator Elizabeth Warren US Senator Edward Markey US Representative Niki Tsongas MA State Senator Eileen Donoghue MA State Senator Jennifer Flanagan MA State Senator-Elect Anne Gobi MA State Representative Sheila Harrington