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. 220.127.116.11 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.
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