FMM Testifies on Renewable & Climate Legislation


This session many bills have been introduced that seek to combat climate change and expand renewable electricity in Maine. While no single bill specifically promotes onshore wind energy, the Wind Lobby is supporting several initiatives. FMM has been asking policymakers to use math, facts, and science as they consider “solutions” to what they identify as problems, and to carefully quantify impacts and benefits in all proposals. This week the Wind Lobby presented its featured legislation, LD 1494, which seeks to increase Maine’s Renewable Portfolio Standard. Below is FMM’s testimony. (Click on bold links for attachments.)

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May 8, 2019

Senator Lawrence and Representative Berry, and members of the Utilities Committee, I am Chris O’Neil, Public Affairs Director at Friends of Maine’s Mountains. FMM testifies against LD 1494, with a friendly amendment that would make the legislation more effective and more palatable.

FMM educates the public about the high impacts and low benefits of Maine land-based wind energy development.  In that role, FMM has spent the last decade protecting Maine’s iconic Quality of Place from this very destructive form of industrialization. At the same time, FMM has always advocated for sensible clean energy and environmental policy.

First, FMM continues to urge you – as we have all year – to park the legislation presented today, and to collaboratively work with the dozen or so other similar bill sponsors, the governor, and the various interested parties before moving forward with any broad energy/climate policy reforms, including the proposals to revisit renewable portfolio mandates. Coordination of effort is already ongoing, and it is imperative that it continues.

Second, FMM is pleased that Mainers have finally parsed our dialogue such that energy does not mean electricity.  As you know from earlier legislation this session, Maine’s various energy sectors must be considered separately, even as they have at least one predominant common denominator: fossil fuel reliance.

Third, please assess the problem, Maine’s role in the problem, and Maine’s possible contributions to any solutions that have been proposed. As you know, Maine electricity generation is already among the cleanest in the nation, with minimal fossil fuel use. At 40% our RPS is the highest in the nation, and our transportation sector emits at least 6 times more CO2 than our electricity sector does. FMM has been pleased to see so many policymakers this year - especially the governor - fixating not on unnecessary, redundant and unaffordable new electricity generation, but on the real CO2 problem and low hanging fruit: fossil fuel use in heating and transportation, which emit ten times more CO2 than electricity does.

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If Maine could successfully electrify those energy sectors using TODAY’S ELECTRIC FLEET mix, we would achieve exponential CO2 reductions. 

FMM thinks an 80% clean electricity portfolio is achievable in 10-20 years, but if this legislation is to be the vehicle, it needs three modifications: 

1.     The first modification is to eliminate the 100 megawatt limitation on qualifying resources.  Renewables are renewables, and if we are going to electrify our present fossil-fired energy needs, we are going to need a lot of electricity (in a moment I will provide an estimate of how much). 

2.     The second amendment is to eliminate the word “renewable” altogether.  The Connecticut approach that targets “zero carbon” electricity is a far more practical and effective model. An alternative would be for us to define and mandate “low carbon electricity.”  Our continued use of the term “renewable” is tantamount to our persisting at using the term “8-track” to describe “music.”

3.     The third amendment recognizes that this is an opportunity to finally stop the senseless bifurcation Maine created when we wrote two definitions of renewables.  We now have in statute “renewable resources” and “new renewable resources.”  We should consider only the former.  The latter was employed to ramp up new generation, and it worked. Maine has now achieved both of its statutory RPS benchmarks, so this is an opportune time to combine the two. Doing so we can more clearly follow the path to 80% clean electricity…or maybe 100% clean electricity.

I call your attention to an important distinction.  Maine’s RPS governs not Maine’s generation fleet, but the electricity supplied by “competitive electricity providers” from whom utilities deliver our power. Attached is the latest generation mix spread sheet for Maine.  As you can see, Maine is already very close to 80% renewable generation. We “got off” burning oil and coal a long time ago.  

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But also attached is the latest “uniform disclosure label” from Central Maine Power Company

Are you shocked to see that more than 20% of the electricity CMP customers use came from coal & oil?  

CMP Disclosure

CMP Disclosure

Are you surprised to learn that although 19% of Maine generation in 2018 was from natural gas, CMP delivered 53% gas-fired electricity?

Did you know that almost all the wind generation in Maine does not get delivered to CMP customers, even though CMP’s $1.4 billion Maine Power Reliability Project was built to accommodate wind energy? 

Note for what it’s worth that Emera’s disclosure for the same period blows away the RPS, but they still deliver a lot of imported coal power.  

emera maine disclosure

emera maine disclosure

FMM’s purpose in submitting the CMP portfolio is so you are mindful of the difference between generation and consumption. For the period, CMP’s customers got only 15.7 % of their power from renewables, while the Maine generation fleet was almost 80% renewable. Be mindful that cost is a major reason why. Also consider that a hodgepodge of mandates, rules and laws have resulted in this flawed outcome.

If you thought that was odd, consider how much we pay power plants to burn fuel and maintain steam. The attached “Capacity Payment” spread sheet is a stark illustration of the mess we’ve created. As you can see, Maine’s fleet of modern natural gas generators is sitting idle almost all the time. Yet ratepayers are still forking over hundreds of millions in capacity payments to keep those generators in business. More revenue for sitting there than for generating electricity! If CMP and Emera replaced all their imported coal- and oil-generated delivery with gas generation procured from these local plants, both Maine’s emissions and costs would plummet. Hence FMM’s distinction between “renewable” and “low carbon” generation. In a perfect world, “zero carbon” (not always renewable, and could mean nuclear) would be the ideal. But because our policy favors renewable and particularly “new” renewable, we are stuck with imported expensive oil and coal rather than gas when the grid needs dispatchability. Remember that the grid operator continues to warn us about energy security (keeping the lights on when the switch is flipped).

capacity payments exceed energy sales

capacity payments exceed energy sales


Current RPS and other policies incentivize the construction of new generation, irrespective of need, and the redundancy is paid for by ratepayers (and to a degree, federal taxpayers). Maine’s existing generation fleet could at full output provide enough electricity for four Maines. Yet for several years running Maine has been a net importer of electricity. A transmission line must prove necessity before obtaining a license. Hospitals must earn a “certificate of need” before purchasing costly equipment. But Maine policy senselessly invites and pays all comers when it comes to electricity generation. 

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Last, as always, FMM urges that you consider the impacts and benefits in any policy proposal.  Opponents of this legislation will remind you of potential costs, which will be highly speculative. For perspective about the benefits, we have actually calculated how much potential good can come of this and other climate legislation:  

If Maine’s entire electricity sector converted to zero-carbon, it would reduce 1.4 MMT of CO2 annually.  Subtracted from the 36,000 MMT of global CO2, that would result in 4/1000ths of one percent decarbonization.

If Maine could decarbonize its entire 16 MMT of CO2 from all energy sectors, it would result in 3/100ths of one percent global CO2 reduction. 

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If complete decarbonization of Maine electricity were akin to prescribing upon me a diet, and if pounds were equated to CO2, the diet would promise me a weight loss of 1/10th of one ounce.  If that diet could be equated to complete decarbonization of all Maine energy sectors, my weight loss would be one ounce. I’d have to ask myself if the discomfort of eating tofu and drinking Tab all day were worth such a tiny outcome.

So before we delude ourselves into thinking Maine can make some significant climate difference in a world where developing nations are building coal plants and increasingly burning fossil fuels at breakneck pace as their economies develop, we need to keep this perspective on how little good we can actually achieve even in a best-case scenario. 

This is not to assert that Maine should not do its part; more that Maine is doing its part, however tiny, and our expectations of maximum global benefit should be factored directly against the amount of impact we are willing to tolerate in exchange for that benefit. Right now, the Seabrook Power plant could theoretically supply all of Maine’s electricity customers. But electricity is a small piece of the energy pie. As we have said, to reduce CO2 in Maine, you have to look at sectors like heating and transport. There is lots of talk about electrifying Maine: switching to heat pumps and electric vehicles. To electrify every BTU (nearly 400 trillion) of consumed energy in Maine would require the equivalent of 34 Seabrook power plants, or 3500 Mars Hill Wind projects. Not to mention unfathomable amounts of transmission. Simply ludicrous notions even if the result were meaningful. But are we willing/able to go there, for 3/100ths of one percent global CO2 reduction?

BDN Photo

BDN Photo

Maine now hosts 400 massive wind turbines, almost all built to satisfy arbitrary procurements from southern New England. Maine has exceeded our maximum capacity for these sprawling projects. Mainers are increasingly resisting the industrialization of our Maine Brand, our signature Quality of Place. Recently Maine has become engulfed in furor about a power line for Massachusetts that proposes 800 utility poles, 10 stories tall, nestled into the woods. Imagine the uproar over the 2500 Mars Hill wind turbines at 40 stories tall, (plus transmission) that would be required for an equivalent delivery of energy, albeit unpredictably. 

Record hill & ellis pond, with mt. blue in the distance, from east baldpate, appalachian trail

Record hill & ellis pond, with mt. blue in the distance, from east baldpate, appalachian trail

If Maine could somehow find the mountains for just ten more Record Hill Wind projects, enabled by new mandates, some of the proponents of today’s bill would get some work, and work counts for something.  But you are legislators, not job creators, and ten Record Hills would add less than 1% new electricity to the grid, while decimating rural Maine. When the Wind Act was written a decade ago, nobody contemplated the environmental or economic impact of the wind proliferation that was enshrined in statute, and now Maine regrets it. Please think ahead so that you can compare the impacts and benefits of these ideas. 

comparing impacts vs benefits is crucial

comparing impacts vs benefits is crucial

For example, another bill in your possession proposes solar panels on schools. Neat idea. But what would it actually achieve, and at what cost? Assuming Maine’s 620 public schools each installed 100 solar panels, they would together add 15.5 megawatts to the 4000+ megawatts of overall generation capacity in Maine, and to the 35,000 megawatts of overall capacity in New England. Assuming a generous 15% capacity factor, this new school-solar generation would be about 20,400 megawatthours, which would be 16/1000ths of one percent of New England’s 125,000,000 megawatthours. The CO2 ROI from this $62 million “investment “would obviously be too small to measure. Again, a noble pursuit, but essentially inconsequential.

As you amalgamate the many proposals before you – and before other committees – please quantify impacts & benefits.  There are lots of ideas on the table, but we need to avoid blindly following the unsustainable “all of the above energy pathway.” 

FMM’s recommendations if you choose to move forward with this legislation:

- Eliminate any reference to “new” renewable or capacity resource in Sec. 3210.

- Eliminate the size limit for renewable generation.

- Define “zero-carbon” or “low carbon” resource and substitute it for “renewable.”