November 12, 2014
Questions for Applicant - Number Nine Wind Project
1. Maine DEP Rule Chapter 2, Section 13 dictates the requirements for tonight’s Public Information Meeting: At the meeting, the applicant or its designee shall present a
summary of the project; provide clear and concise written information that details
the expected environmental impacts of the project and lists the state, local and
federal licenses necessary for the project; and provide adequate opportunity for
public questions and responses from the applicant.
I thank you for the opportunity to ask a few questions, and in the interest of time, I would
be pleased to allow you to defer responses to any question that might not be readily
answered this evening. Will EDP provide written replies for the record if any question
tonight remains unanswered?
2. Maine DEP Rule Chapter 2, Section 13 further dictates:The applicant must submit a
signed certification attesting that a public informational meeting was noticed and held in accordance with this section. The submission must include an estimate of the number of attendees and a narrative responsive to any significant issues relevant to the
licensing criteria that are raised at the meeting. The certification must be submitted
with any application that requires a pre-application meeting pursuant to section 10(B) of
this rule.
To the extent that you must submit sworn certification to DEP with your application, and
to the extent one or more of my questions might be technical or misinterpreted, I
request that you share your draft certification and narrative prior to your
submission, so that we can be on the same page before it goes into the record. Will EDP
agree to such collaboration?
3. According to the NREL wind resource map, the proposed project area has poor to
marginal wind quality. The Stetson and Stetson II wind projects 50 miles south are
on similarly low hills with weak wind resources. The Stetsons in 2012 achieved capacity
factors of 21.4% and 18.4% respectively, but they were the beneficiaries of considerable government grant funding. Maine people want assurance that your LLC has a sustainable
business plan, including full decommissioning of a potential massive blight, in the event of failure, abandonment, or insolvency. DEP now requires full pre-funding of decommissioning,
but the applicant is allowed to estimate the cost, which is always ridiculously low. Are you willing to bond and guaranty full decommissioning at the actual eventual cost?
4. You have secured leases for +50,000 acres. So that the public will benefit from
disclosure as the public participation process moves forward, can you please tell us now
who are the lessors and what are their various subsidiaries and affiliated entities?
5. An aggrieved party in Connecticut has a pending law suit against the Connecticut
department that ordered your controversial Power Purchase Agreement (PPA). The State
has filed a motion to dismiss. If the motion is denied, the court could take considerable
time before we know the outcome of the litigation. Given the tenuous status of the
Production Tax Credit, and given the increased viability of large-scale hydro and New York
wind to satisfy state mandates, thereby diminishing the likelihood of a lucrative PPA, and
given the probability that regional natural gas deficiencies will soon be fixed, what
assurances will you give Maine that this project is a viable business concern, discussing
each of the above factors.
6. Transmission and generator lead lines for wind projects are expensive. The proposed
project is separated from the ISO-New England by a considerable transmission gap,
which is exacerbated by the Orrington bottleneck. Emera Maine and other utilities have
devoted considerable resources to maintaining regional reliability at minimal cost to
ratepayers. According to an EmeraMaine report dated 12-18-13, EmeraMaine might be required to purchase that portion of the lead line necessary to connect to ISO-NE, with socialization implications. Please explainall the implications for ratepayers in the various systems, based on all the possible T&Dconfigurations that might occur relating to this wind project.
7. Last year a representative of your company named Jeff Bishop testified before the
Maine legislature on LD 1750, a bill brought by the wind lobby. Mr. Bishop explained
EDP’s support for the bill because it “clarifies that wind developers do not have to prove
the energy and emissions benefits of their project…” He further said “this seems
appropriate.” As Mainers have become increasingly educated on wind energy’s true
impacts & benefits, we have come to know that wind energy’s “energy and emissions”
benefitsare theoretical at best, and in many cases are fictional. Given that we are being
askedto absorb massive environmental and economic impacts from this sprawling and
costly project, including encroachment on “forever wild” Baxter State Park, will you
please be a good neighbor and delineate said benefits for us, subject to expert review
and cross examination during the permitting process?
8. The Connecticut Legislature has repeatedly upheld their law essentially forbidding
industrial wind energy in the Nutmeg State. Congratulations to you in winning the
still disputed (see #5) competition for Connecticut Renewable PPAs, topping a field of 47
bidders, many of which were in Connecticut. DEEP Commissioner Dan Esty awarded EDP
for 250 megawatts of capacity, and a CT solar firm for 20 Megawatts of capacity. Given
that Connecticut lawmakers refuse to site wind complexes in their own state, and given
the sacrifices Mainers will be asked to make, would EDP support a Friends of Maine’s
Mountains initiative that seeks Connecticut land for the relocation of Maine’s nuclear
waste to Connecticut?
9. If you took that question as somewhat facetious, this one is not. We have had too many bad experiences with wind developers and we do not trust them. How many EDP employees were ever employees of Enron or its affiliates and subsidiaries? Please list all, and their
current positions at EDP.
10. For about a year EDP has stationed a pair of young public relations staffersin
downtown Presque Isle. For several years EDP and the former Horizon have conducted PR activities in the area. Surely your activity is more than buying coffee and donuts for the snowmobile club. Please save Maine taxpayers the expense of Freedom of Information
Access compliance, and provide for the record all correspondence with public officials
regarding the project.
11. Roughly 10,000 square miles of Northern Maine have been designated as lynx critical habitat by the U.S. Fish and Wildlife Service. What has been done to determine that a
sprawling project involving extensive blasting and clear-cutting will not disturb this
endangered species and comply with the federal Endangered Species Act?
12. Stakeholders in Aroostook are now grappling with several serious issues in the MEPCO-
Emera-NB Power-Van Buren-Houlton-NMISA region. The system here has serious issues,
from reliability to potential base load shortages. We have two biomass plants with 70
megawatts of base load capacity. Those ostensibly could provide load following to
balance the zero capacity generation that you propose, which is unlikely to perform more
than 15 minutes per hour on average. Those dispatchable biomass generators with firm capacity will certainly be harmed by grid disruption as a direct result of your project, and
they will need to find higher revenues through rates and capacity payments, or they may
very well go under, putting hundreds of local people out of work, including forest products professionals who provide some $40 million worth of fuel annually. Then Aroostook will
need to get its base load and load following power elsewhere, perhaps from oil plants in
New Brunswick. In short, irrespective of whether it is useful or necessary, your project
could cause calamity.
12A. When you submit your tangible benefits/community benefit package in your
application next month, will you provide a true “net” benefits assessment, deducting the negative impacts, including those named above, or will you merely report half the equation, which is to count the money that you sprinkle around the County?
12B. Given the pending negative impacts on system reliability and ratepayers, will you
agree to an additional criterion in your permit process: a PUC Certificate of Public
Convenience and Necessity?
Thank you for your apparent willingness to be a good neighbor. Your proposal has
lots of people concerned, so your ability to adequately answer our questions here will go
a long way in determining that EDP and the project will be good for us. We look forward to your replies.
Friends of Maine’s Mountains PO Box 60 Weld, ME 04285