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New England Clean Energy RFP - public comments
From:
To:
Lori Lerner
CleanEnergyRFP
03/27/2015 01:22 PM
Cc: "Linowes, Lisa"
The attached document is being submitted in response to the request for public
comment on the New England Clean Energy RFP, on behalf of New Hampshire Wind
Watch and the Wind Action Group.
Please feel free to contact us for any further information or explanation.
Respectfully,
Lori Lerner
New Hampshire Wind Watch
215 Lake Street
Bristol, NH 03222
603-744-2300
Lisa Linowes
The Windaction Group
286 Parker Hill Road
Lyman, NH 03585
603-838-6588
MA-CT-RI Clean Energy RFP - Public Comment Responses (1).pdf
MA/CT/RI RFP Comments
Submitted by NHWW and Windaction Group
March 27, 2015
Page 1 of 2
Public Comment on New England Clean Energy RFP
RFP Language
2.2.8 GENERATION SITE/ROUTE CONTROL (Page 17)
The Eligible Bidder of a generation project must demonstrate that it has control, or an
unconditional right to acquire control, over the generation site included in the bid.
In all cases, site control and property rights include all necessary easements or
development rights necessary to operate or develop the generation project. In order to be
considered to have site control for generation projects, the Eligible Bidder must provide
documentation showing one of the following: that they own the site or have a lease with
respect to the site on which the proposed project will be located for a term at least as long as
the PPA or Qualified Clean Energy Delivery Commitment term; or have an unconditional
option agreement to purchase or lease the site for such term. This requirement applies to
both new and existing facilities.
ENVIRONMENTAL ASSESSMENT, PERMIT ACQUISITION PLAN AND TIER (Page 43)
7.4 Provide documentation identifying the level of public support for the project including
letters from public officials, newspaper articles, etc. Provide a plan for community outreach
activities, and discuss the status of that plan.
Alternative Language (Public Comment)
Amend statement: The Eligible Bidder of a generation
project must demonstrate that it has control, or an
unconditional right to acquire control, over the
generation site and transmission route and
substation included in the bid. Also, if this will be sited
on any publicly owned land or conservation land, this
needs to be identified.
EXPLANATION: For a wind energy facility, the wind
turbine site is one of multiple sites impacted. The facility
will require a transmission route and a substation for
which full control also needs to be demonstrated.
Add statement: For new facilities, provide energy
related local ordinances and Town Master Plans for
communities that will ‘host’ the energy facility, in
addition to results of any municipal votes taken to
gauge support in communities in the vicinity of the
energy facility.
EXPLANATION: It is very important to demonstrate local
support through the voice of the people. There is no
better way to gauge that support than by providing the
municipal documents which have been voted on by the
people of the impacted community.
MA/CT/RI RFP Comments
Submitted by NHWW and Windaction Group
March 27, 2015
Page 2 of 2
RFP Language
13. CONTRIBUTION TO EMPLOYMENT AND ECONOMIC DEVELOPMENT (Page 48)
13.1 Please provide an estimate of the number of jobs in to be created directly during project
development and construction (for a project that includes new facilities or capital
investment), and during operations, and a general description of the types of jobs created,
estimated annual compensation, the employer(s) for such jobs, and the location. Please
treat the development, construction, and operation periods separately in your response.
13.2 Please provide the same information as provided in response to question
13.1 above but with respect to jobs that would be indirectly created in as a result of the
proposed project.
13.3 Please describe any other economic development benefits that could be achieved in by
the proposed project, such as creating property tax revenues or purchasing capital equipment,
materials or services for New England businesses. Please provide the location(s) where
these economic development benefits are expected to occur.
2.3.2.1 FACTORS TO BE ASSESSED IN QUALITATIVE EVALUATION: (Page 23)
Eligible Project feasibility, including:
 Experience and capability of the Eligible Bidder and Eligible Project team including,
where applicable, any associated transmission development team, in project
development, operations and maintenance, and experience in the ISO‐NE market
 Status of permits and credibility of plan to obtain approvals
 Demonstrated progress in the interconnection process
 Identification of required permits and approvals
 Extent to which site or route control has been achieved, including acquisition of
necessary easements or rights‐of‐way
 Community relations plan
 Conformance with FERC’s applicable regulatory requirements
Alternative Language (Public Comment)
Add Statement: 13.4 Identify any changes (positive or
negative) that will occur in the area around the
proposed site, such changes may include impact on
tourism locations, recreational activities, residential
neighborhoods. Will the facility be ‘in harmony’ with
the proposed area? Are there any existing businesses
that may be negatively impacted within the vicinity of
the proposed energy facility area?
EXPLANATION: Identifying only the benefits of the
proposed facility would be very misleading. All impacts,
positive and negative, must be considered.
Add Bullet: Demonstrated ability that this facility will
have sufficient transmission capacity to deliver all of
the energy without curtailment by the ISO-NE of this
facility or resulting in the possible curtailment of any
other electric generating facility on the system.
EXPLANATION: If a feasibility study or system impact
study has been completed for the project and has
identified possible curtailment this facility will likely
require or potential curtailment impact to any other
facilities, that information must be provided and
considered during the evaluation process.