Vermont Energy Parks, LLC - New England Clean Energy RFP
March 25, 2015 RE: Comments on the Draft New England Clean Energy Request for Proposals. Dear Evaluation Team: Thank you for reviewing the following comments on the draft RFP. The RFP states that it is pursuant to the clean energy goals of the Procuring States. In the case of Connecticut these goals are, pursuant to Section 6 and 7 of Connecticut Public Act 13‐303, as well as Connecticut General Statutes Section 16a‐14 (together, the “CT Statute”). The draft RFP uses criteria that will exclude proposals from projects that should be eligible based on the CT Statute. Specifically, the CT Statute does not have a minimum project size. Projects with a nameplate capacity of fewer than 20 MW are more likely than larger projects to be distributed throughout the grid providing local grid reliability, timely interconnection to the grid and local economic benefits. Moreover, CT has many more site control options for land supporting projects smaller than 20 MW. Specific proposed changes: Section 2.2.7. Strike “with a minimum nameplate rating of 20 MW” from the first sentence, consistent with the CT Statute. Section 1.2.5. For Tier 1 renewable bids, enable power purchase contract terms of up to 25 years. Other New England states, such as Vermont, have used these longer terms with much execution and rate-reduction success over the last five years. Section 1.3.2. Strike 8 copies from the RFP, replace with electronic and/or CD-Rom copies, as more consistent with paper reduction, environmental best practices, and administration efficiency. 35 Old Dam Road, Fairfield, CT 06824 • 802. 855. 1353 RFP Comment Letter Vermont Energy Parks, LLC Page 2 Section 1.7. Reduce RFP fees by one-half. The proposed fees are at the highest range of clean energy RFP fees. In order to encourage a competitive bid process, more reasonable fees should be used. Section 2.2.8. Evidence of site control should also include items such as a purchase agreement and/or a letter of intent. Section 2.2.3.2. Please explain how bids involving transmission projects get paid for the transmission elements? Sincerely, /s/ Gabriel M. Selig Gabriel M. Selig CEO [email protected]
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