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]