Rosemary Wessel, Founder
nofrackegasinmass@gmail.com • 90 Trow Road, Cummington, MA 01026 • 413-634-5726
December 20, 2014
To the Acting Commissioner, Dept. of Energy Reources, Meg Lusardi
and members of the Low Demand Study Team:
The current Low Demand Study, commissioned by the Department of Energy Resources (DOER) originated
when a group of five of us representing various citizen’s groups met with Governor Patrick on July 30, 2014
about pipeline proposals and energy needs for the New England region.
Citing an earlier study by Black & Veatch for the New England States Council on Energy (NESCOE) that stated
that no new pipeline would be necessary if the region were to continue to lower its energy demand with policies
that were already producing notable results, we were told by the Governor and the Secretary of Energy and Environmental Affairs that the study was flawed. When the Governor agreed to our suggestion of a new study, the
DOER invited a large group of stakeholders to be involved in the process, including many conservation groups,
environmental justice groups, and clean energy advocates, as well as energy industry and regulatory representatives. This inclusive approach was very much in line with our request for an open and transparent process - something that had been missing from the decision making process that led to NESCOE, ISO New England and the six
New England Governors’ request for more pipeline capacity.1
The original request for proposals drafted by the DOER to hire a consulting firm included these study goals:
— To determine, given updated supply and demand assumptions, whether or not
new gas infrastructure is required
— If so, how to optimize for environmental, reliability, and cost considerations.
— 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.
— In combination, how far can these alternative resources go in replacing retiring generation capacity
The meetings hosted by DOER for stakeholders to hear the progress of the study and offer feedback have been
inclusive, open to the public by way of attendance or conference calling. Each meeting was followed by a brief
comment period, during which stakeholders were encouraged to provide further specific feedback into the study.
Although it was stated at the outset that this was not a consensus-building process, the initial proposal for the
study and some of the issues addressed by stakeholders seemed to be taken into account as the process moved
forward.
Then the third and final stakeholder meeting was postponed — not once but twice — pushing the final meeting
back until just four days before the deadline for the study’s release. What was ultimately presented at the December 18 meeting did not take the shape of the study that stakeholders had seen taking form during the development
of the request for proposals and the previous stakeholder sessions. As one of the five who originally met with the
Governor to request this study, the differences were stark and disappointing.
The final models used for the study, which were refined during the period of time when public participation was
postponed, have many assumptions that are simply not rooted in the real world. Collectively, they render the study
useless to anyone looking to this report for energy policy development and useless to the people of Massachusetts.
The following are just some of the most outstanding deficiencies in the Low Demand Study’s modeling assumptions:
— None of the models are GWSA (Global Warming Solutions Act) compliant. This not only ignores state law, it
ignores one of the key pieces of the RFP - how to meet our energy needs WHILE lowering ghg emissions.
— Building more pipeline would pull us further out of compliance with the GWSA, shifting the burden to meet
GWSA compliance out of the electric generation sector to more expensive sectors of the economy.
— Offshore wind is discounted as not feasible, yet there are currently multiple projects moving ahead. This will
be part of our energy system in the near future, yet it is not considered.
— Solar is dismissed as not being available during peak hours (the only times considered in the model). At the
same time, peak storage systems using pumped or battery storage are also discounted as not feasible. Including
both can provide peak demand relief.
— The study does not take into account the drastic drop in oil and LNG prices, making the study’s results already obsolete.
— It does not appear to take into consideration emissions of methane released through normal operations of
transmission pipelines (at compressor, pigging and valve stations).2 Methane is currently rated by the IPCC to
have 34 times the climate change impact of CO2 over their first 100 years in the atmosphere; 86 times more over
their first 20 years.3
— It does not include expansions of current energy efficiency programs or further incentives for distributed
generation development, both of which are currently keeping electric demand flat in the state.
— The study uses ISO-New England’s energy forecasts as base model numbers. These forecasts have recently
been criticized by NESCOE for not including current distributed generation (rooftop solar, etc), and utility scale
wind and solar that are slated to come on line in the next few years, as well as energy efficiency incentives that
are holding electric demand flat.4
— The study assumes optimal pipeline use (80% full and serving only domestic uses) which would not be the case
if all or even most of the currently proposed pipelines are built. If they are built, and the market is flooded with
excess capacity during the 325-350 days a year when demand is below peak, this would create a glut of gas capacity with nowhere to go but export to foreign markets. The significantly higher prices that natural gas captures
overseas would raise prices here in New England.
— The study only marginally considers increasing the storage and/or importation of liquified natural gas (LNG)
to meet the infrequent peak demands for natural gas in the current system. There are currently under-utilized
facilities for storage in New England that could be used to store natural gas during the vast majority of the year
when peak demand is not an issue. Also, our main importer in the region, Distrigas, has estimated that the peak
constraints can be addressed by their company with no more impact than 2-1/2 to 3 extra tankers per year arriving
at their facility. This is a solution that could bridge the current constraints while renewable capacity is boosted to
address electric generation needs over the next few years. Unlike a pipeline, both of these solutions are immediately available and don’t require ANY new infrastructure to be built.
By recalibrating the study to such tight and unrealistic parameters, the study has been bent into a shape in which
the only question to be answered was not “is more pipeline necessary”, but “how much pipeline is necessary”.
The spirit of the study requested during our meeting with Governor Patrick was to determine if, and by what mea-
sures, peak demands could be met by means other than new pipelines. Given the unrealistic nature of so many of
the assumptions in this study, its usefulness seems limited to showing how much distortion of study parameters it
takes to show that more pipeline is indeed needed.
It’s my hope that the deficiencies in this study can help the incoming Administration understand how to achieve
the original goals put forth by our citizen’s groups to determine what our actual energy needs are, and how far
we can go toward meeting them using non-fossil-fuel means, before even considering resorting to adding to our
already considerable over-reliance on natural gas. A study keeping in line with the original RFP seems crucial to
moving forward in accurately re-defining our state’s energy policies in a way that will keep both our economy and
our climate impact reduction goals on track.
It’s also my hope that in the brief time before he leaves office, Governor Patrick will require regulations to be put
in place as mandated by the GWSA5, “establishing a desired level of declining annual aggregate emission limits
for sources or categories of sources that emit greenhouse gases.” These regulations were due in 2012 and have
still not been put in place. They would go a long way to helping the state achieve its goals, and are essential in
establishing any future energy policy, since these regulations are mandated to be the law of the Commonwealth.
Sincerely,
Rosemary Wessel
Cc: Governor Deval Patrick
EEA Secretary Maeve Vallely-Bartlett
Undersecretary for Energy, Mark Silvia
Governor-Elect Charlie Baker
EEA Secretary-Elect Matthew Beaton
Attorney General Elect Maura Healey
Senator Elizabeth Warren
Senator Edward Markey
MA Senator Stanley Rosenberg
1- http://www.ct.gov/deep/lib/deep/press_releases/2013/New_England_Governors_Statement-Energy_12-5-13_final.pdf
2- http://www.epa.gov/gasstar/documents/redesignblowdownsystems.pdf
3- http://www.climatechange2013.org/report/full-report/
4- http://www.nescoe.com/uploads/ICR_Statement_October_2014.pdf
5- http://www.clf.org/blog/clean-energy-climate-change/global-warming-solutions-act/