No Coal No Gas submitted over 150 comments to the Federal Energy Regulatory Commission (FERC), opposing ISO New England’s latest forward capacity auction results, which continued funding the coal-fired Merrimack Station.
Then, ISO New England filed a response to our comments, arguing that they were “outside the scope” of the proceeding.
In response, No Coal No Gas filed more motions with FERC to reiterate that considering the scope of the climate crisis is necessary in energy policy. We filed an official motion to intervene in the docket, followed by an official response (called “Motion for Leave to File Answer and Answer”) to ISO New England’s response to our comments. We also filed a comment with FERC’s Office of Public Participation, inquiring just when the climate crisis will be officially considered “inside the scope” of energy policy.
We know that many decision makers in the system have read our latest filings, AND we received a direct email from the Office of Public Participation’s senior policy advisor. We are looking forward to meeting with OPP’s senior policy advisor and will post an update later this month!
Some quotes from our filings:
“Subsidizing a coal plant is a lose-lose situation. If the Merrimack station runs, it produces toxic air and water pollution with long-proven harmful effects on the health of nearby communities and ecosystems. In addition, carbon emissions from coal are among the highest contributors to the worsening climate crisis….Given all that, you might be tempted to argue that the status quo is fine because the plant is only there for backup, and doesn’t run often. It is not fine. It means we’re spending millions of dollars every year to prop up a generating station that hardly even gives us any electricity. Say what? That money could be invested in solar and wind projects, in grid modernization to support more local generation, or in energy-efficiency incentives that reduce our region’s overall consumption. All of those options would put New England in a stronger position going forward.” —Comment by Marisa Keller
“If these proceedings are to be defined in a manner sufficiently narrow that they should fail to account for the fundamental facts upon which they are based, it rapidly becomes impossible to ensure the “reliable, safe, secure, and economically efficient energy services” described in FERC’s mission. For example, if the ISO’s FCA results were determined by valuing the United States dollar at half its current worth, they would be dramatically—perhaps catastrophically— different from results based on reality. Or, for example, if the FCA results were determined based on regional energy demand figures from twenty years ago, they would be dramatically—perhaps catastrophically—different from results based on reality. Both of these would clearly be relevant to whether the ISO had followed its Tariff and conducted a legitimate FCA. That is, in order to follow that Tariff, the factual world must be accounted for. The climate crisis is just as factual and just as connected to grid management as the value of the United States dollar and the current regional energy demand.” —Isaac Petersen, in the NCNG Motion to Answer
“The purpose of subsidies is to contribute to the common good. It is clear we need to shift away from dirty legacy generators toward subsidizing and promoting increased energy reliability, job creation, pollution reduction, the promotion of equity, and a more sustainable climate.” —Comment by Becky Jones
“When will the 3 deaths a year caused by the Merrimack Station be “inside the scope?”...When will the threat of climate change to New England residents, to our regional grid reliability, and to people around the world be relevant to decision making around grid policy? When will the scientific requirements for the existence of life on Earth be related to whether or not we fund coal and other fossil fuels years into the future? We have tried all the proper channels, from stakeholders meetings to lawsuits to meetings with our representatives, and nothing has worked. Yet when the dysfunction and danger of this situation leads us to civil disobedience, we are told that ‘this democracy works.’ Well, if this democracy works, where is your power? Where is the ability of the Federal Energy Regulatory Commission to say that justice and collective survival are within the scope of concern?....When will you realize that the crisis we are facing will not wait to be “ripe for comment,” that….there will be no electric grid or “proper procedural process” if the fossil fuel industry, given free rein by your commitment to bureaucracy, destabilizes and destroys our communities, society, and species?” —Leif Taranta, in NCNG’s Comment to the FERC Office of Public Participation
“It is a moral outrage for us as consumers to be forced to continue to subsidize the pollution of our planet and destruction of our climate. This benefits nobody except the owner of the Station. We should be investing in cheaper renewable energy and in energy efficiency instead. Do not put off this decision. Have courage.” —Comment by Sarah Thorne
“Merrimack Generating Station…would appear to benefit no one economically, except its private investors; it pollutes the beautiful Merrimack River and kills fish. Basically, it’s a disaster for public health and environmental justice.” —Comment by Siobhan Senier
“It's irresponsible and short-sighted to spend hundreds of millions of dollars of ratepayer money to keep a dirty and climate-damaging technology alive.” —Comment by Wharton Sinkler
“As a parent of two young children, ages ten and six, I have tremendous concern over the health and safety of our collective future. What will their futures look like? Will they have access to clean water, breathable air, and healthy soil?” —Comment by Abby Mnookin
“As a small farmer, the impacts of climate change have already reached me and other growers. The state of NH's unwillingness to move to renewable energy and take climate disruption seriously is distressing for all of us who want to contribute to a resilient community and NH's ability to feed itself locally.” —Comment by Amy Antonucci
“We need to immediately cease subsidizing fossil fuels and route those subsidies into renewable energy. If we had begun this process a decade ago, the transition would likely be almost complete. Why do we continue to bolster a dying and destructive industry?” —Comment by Amanda Nash
