Honorable Paul LePage

1 State House Station

Augusta, ME 04333-0001 September 19, 2018

Dear Governor LePage:

In May of this year you appointed me to the Maine Wind Energy Advisory Commission. Thank you for that vote of confidence and for seeking my knowledge and experience, which I have gained by professionally representing parties in the fight against industrial wind energy. Since 2009 I have represented Friends of Maine’s Mountains, the statewide wind opposition group which has been involved at the legislative, regulatory and public affairs levels of the matter, so I assume you sought to tap that experience and knowledge for the Commission’s benefit. It is an honor to be asked.

And thank you for heeding the pleas of Maine people who have already done what the Commission was formed to do: learn the facts about wind energy’s high impacts and low benefits.

In my 22 year public policy career I have sat on and participated in dozens of study panels, commissions and task forces. Many of them produced reports spawning real and lasting policy that improved Maine. When it was announced by your executive order, I was eager to help this Commission raise awareness and hopefully change bad policy, but I now have little faith that it will achieve much, if anything.

Four months have passed since my appointment and the Commission has not convened a meeting. Election season is upon us. The departures from the Administration of DECD Commissioner George Gervais and Energy Director Steve McGrath have denuded the Commission of its designed leadership. Fully expecting additional late-term turnover as in any outgoing administration, I do not think we have the ability to produce a quality product.

Today I respectfully resign from the Commission. But my rationale is not merely that the Commission appears to have run out of time.

The Executive clearly has the ability to form and accept counsel from an advisory group, but I would have preferred an open public process and discourse. Despite my lingering reticence about transparency, I accepted the appointment thinking that I could help the Commission produce a credible and actionable report. As documented by Pine Tree Watch[1], the original task force that devised and rammed through the Wind Act was itself cloaked in secrecy. So I decided that I would give your Commission a chance at revealing the folly of the most devasting land use policy in Maine history, a policy that bestowed unprecedented preferential treatment and special rights upon a single industry that could ruin the Maine Brand.

My more fundamental concern however, is that the Commission’s aim is poised to miss its mark in two ways. Your Order creating the Commission issued a charge that – despite being well intended – dooms it to failure.

First, the Commission’s limited focus is on the western mountains. Once a prudent person learns the facts, it becomes clear that industrial scale wind energy is simply wrong for Maine, all of Maine. Whether in Hancock, Aroostook, Washington, Somerset, Franklin or any other county, wind is unnecessary, unsustainable, unaffordable, and essentially useless to the grid. See Chart 1, which shows that even if Maine stopped electricity generation altogether, such an action would have no measurable impact on nationwide or global emissions.



In theory, wind energy could slightly reduce Maine CO2 emissions.
But even if Maine could close allof its electricity generation sites, the theoretical and actual amount of CO2 reduction would be imperceptible

· Maine has #1 highest Renewable Portfolio Standard in the USA

· Maine is #3 cleanest state behind ID & VT in CO2 emissions from Electric Power sector

· Maine’s Transportation sector is responsible for 6 times more CO2 than its Electric Power sector

· Maine's Electric Power sector is responsible for 1.3% of total New England CO2 emissions

· Maine's Electric Power sector is responsible for 3/10,000ths of 1% of total USA CO2 emissions (.0003%)

· Maine's Electric Power sector is responsible for 4/100,000ths of 1% of total Worldwide CO2 emissions (.00004%)

http://www.eia.gov/environment/emissions/state/analysis/ Maine Electric Power CO2 emissions = 1.44 MMT http://www.eia.gov/environment/emissions/state/analysis/USA CO2 emissions = 5300 MMT http://edgar.jrc.ec.europa.eu/overview.php?v=CO2ts1990-2015World CO2 emissions = 36,000 MMT

Maine’s electricity sector is exemplary when measuring emissions. In fact, Maine’s transportation sector is responsible for six times more CO2 than our electricity sector, yet the only legislative action over the last decade that impacted transportation emissions was unanimous passage of a bill allowing increased speed limits on Interstate 95. Such lack of critical thinking begets bad policy. Year after year Maine burns oil to generate only about one percent of its electricity, yet proponents continue to assert that we need wind energy to “get us off foreign oil.” Maine uses its oil in the transportation and heating sectors, yet misguided policies continue to target our electric sector for reducing emissions and oil. Thank you for trying to break this farcical trend.

Having met with you several times, I know you realize that under the guise of good green intentions, wind energy is actually harming both our environment and economy, and not just in the western mountains. The preposterous impacts so drastically outweigh the minimal benefits, wind development needs to cease statewide, even more urgently than billboards did decades ago.

Second, the Commission was asked to study Big Wind’s impacts on tourism. At first glance, this makes sense because tourism is so huge. But more specifically, outdoortourism and the Maine Brand are what really count.

According to the Maine Office of Tourism’s 2017 figures, 41% of overnight visitors come primarily to the lakes & mountains/highlands/Downeast. That is more than the visitors who flock to red hot Greater Portland and Maine’s spectacular beaches combined. 88% of overnight visitors came to Maine for touring/sightseeing/active outdoor activities. This is 28% higher than people who come for the food scene. Tragically, these special areas and the outdoor activities within them are directly threatened by industrial scale wind development for Massachusetts utilities. More of our visitors come from Massachusetts (ironically) than from any other state or province, but Massachusetts refuses to site energy infrastructure even as they flock as tourists to experience “The Way Life Should Be.”

It stands to reason that industrial wind development runs counter to those favorable tourism trends.

But while tourism per se is unequivocally important, quantifying it (or the loss of it) is a nebulous and ephemeral endeavor at best. Any attempt to ascribe cause and effect, no matter how impassioned or eloquent, will be roundly discredited and panned by the Wind Lobby, a powerful political force that has had vast success invoking emotion instead of logic to fool most of the people most of the time.

Wind energy was broadly accepted ten years ago when the Maine Wind Act was enacted without a single dissenting vote[2]in the Legislature. But after a decade of disappointing and shocking experience, that popularity is waning, and it isn’t merely about the view. The Wind Act not only prioritized and incentivized wind development in state policy, it rendered a new and unprecedentedly catastrophic land use almost impossible to stop, especially in the Unorganized Territory.

In those ten years, about 900 megawatts of installed wind generating capacity has been built, severely harming Maine’s storied “Quality of Place” almost exclusively to satisfy policy goals/mandates in southern New England states like Massachusetts. In addition to the $1.4 billion transmission upgrade which was prerequisite for Maine’s wind development, the 400 skyscrapers at Maine wind projects have cost ratepayers/taxpayers approximately $2 billion, while last year supplying a mere 3% of New England’s electricity load, often at times when the electricity was not needed. Still, public perception persists that wind energy is useful, necessary and beneficial.

The most compelling reason to stop wind development is its irreversible harm to Maine’s fabled Quality of Place. Quality of Place is the Maine Brand, our calling card and ticket to prosperity, according to the authoritative report on the subject,Charting Maine’s Future[3]by the Brookings Institution. And industrial wind energy is absolutely antithetical to that Maine Brand, an outdoor environment and ethos unlike anything east of the Mississippi.

Tourism is certainly interwoven with the Maine Brand, but the Maine Brand is bigger, more vulnerable and more valuable. The Maine Brand is the very underpinning of Maine tourism and the greater economy.

The graphic below shows the logos of several Maine-based companies that are not necessarily in the tourism industry, yet they all “sell” the Maine Brand, something many of us natives take for granted.


It isn’t just tourism, but the greatest outdoor experience east of the Mississippi


On its recruiting page, even a big Portland insurance company depicts a serene kayaker rather than a bustling call-center, which would be more accurate. The Maine Brand, so integral to our economy, cannot withstand more industrial blight.



By selling Maine’s Quality of Place



As evidenced by the current public backlash to a single transmission line proposal between Quebec and Lewiston, Maine people are fed up with serving as the power plantation for Massachusetts. I applaud you for asserting, much like Governors Fernald and Baxter did a century ago in “water wars” with CMP’s Walter Wyman, that Maine will not be chopped up and sold to the Bay State for no benefit.

I note that the Quebec transmission proposal would deliver (more reliably) the equivalent electricity of 100 Mars Hill wind projects, or 30 Kibby wind projects, or 20 Bingham wind projects. There is no comparison and simply no room for thousands more 50 story flashing thumping bird chopping turbines. I also note that over about a decade, the 34,000 megawatt New England grid is losing at least 5000 megawatts of reliable (often dirty) base load and peak load power generation, which despite our wishes cannot be replaced or even displaced by wind energy. It should further be noted that Maine’s electricity generation (see below Spread Sheet 1) is about one third what it was 15 years ago.


Maine used to be a net exporter of electricity. Now generation AND consumption are down.

Maine used to be a net exporter of electricity. Now generation AND consumption are down.

It should finally be noted that Massachusetts’ resistance to natural gas pipeline expansion has forced us to continue and sometimes increase our procurement of peak electricity[4]from dirty sources like oil and coal. Via exorbitant peak pricing (see Spread Sheet 2) and ballooning “capacity payments” that keep peak generation plants (often dirty and old) afloat, this backwards policy extracts billions of wasted dollars annually from the New England economy while polluting our air. It is a grossly negligent misallocation of resources to spend billions on superfluous wind infrastructure, billions on capacity payments, billions on dirty peak energy, and billions more on accompanying transmission, all while neglecting to maintain critical infrastructure that would truly help our economy and environment.


Gas shortage at peak demand costs ratepayers billions

Gas shortage at peak demand costs ratepayers billions

Tourism and the western mountains are both invaluable, but an honest examination of wind development in Maine needs to grapple with issues like the foregoing, always mindful of Maine’s delicate Brand.

Speaking of studies, in 2012 the Governor’s Energy Office conducted a comprehensive review of the Wind Act. The so-called “OEIS Report[5],” which should be required reading for this Commission and all policymakers, was the result of overwhelming anti-wind backlash in the Legislature. Unfortunately, that OEIS Report, thanks to intense and insidious lobbying, was relegated to the dusty shelf where studies go to quietly die. Its multiple recommendations went largely ignored in subsequent legislatures, but the insights and research contained therein are still timely and prescient -- and can save this Commission months of work, if it ever begins the work.

The aforementioned 2006 Brookings report should also be required reading, as it repeatedly makes the case for protecting the Maine Brand, our Quality of Place.

“Studying” Big Wind’s impacts on tourism will be arduous and futile. Maine needs to think more soberly about all the cataclysmic impacts of industrial wind, both short and long term. Your Commission is a welcome step in that direction, but it lacks urgency, credibility and focus. Whether this critical policy discussion happens in the Commission or in the next legislature, or both, it needs to happen. My simplest and most direct recommendation is repeal of the Wind Act. No study needed. We know enough. Return Maine to a rational and fair development review scheme wherein citizens and markets have a say in state land use and energy policy.

Again, thank you for listening over the last eight years to the voice of reason. Your legacy will never depict you as a tree hugging environmentalist, but you have been right about this issue that is such an environmental and economic disaster.

I have attached the earlier comments submitted by my client to the Commission.

Best wishes to you and Mrs. LePage in the future.


Christopher P. O'Neil

O'Neil Policy Consulting, Inc.
Government Relations
PO Box 631
Portland, ME 04104
(207) 590-3842