PORT submits comments to the Maine Public Utility Commission

PORT is a community organization formed by citizens of the Town of St. George, Maine (“St. George”). Maine Aqua Ventus (“MAV”) has approached St. George regarding the possibility of landing the cables for its floating wind turbine pilot project (“Project”) in St. George. PORT was founded to represent the interests of the St. George coastal community with respect to the impacts of the Project on its landscape, character and quality of life, as well as on the fishing community that is vital to the regional economy. In reviewing comments already filed in response to the January 24 Order, PORT sees that many comments supporting the Project have been filed by persons located in other states, and from as far away as Australia. PORT believes that it is important that the Commission hear the views of Maine coastal communities, and particularly those (such as St. George) that may be directly affected, regarding the impacts of the Project.

The Commission’s January 24 Order requests comments on whether the Commission should reconsider orders issued in 2014 in which it approved a term sheet for a long-term power purchase agreement for the Project (“Term Sheet”) pursuant to the Ocean Energy Act (“Act”). The January 24 Order notes that there have been developments since 2014 that may warrant reconsideration of the Commission’s approval of the Term Sheet. The Commission has identified a series of specific issues upon which it seeks public comment. In this context, PORT recognizes that under the Act, the Commission lacks authority over environmental impact and siting issues associated with the Project. However, in determining whether to reconsider its approval of the Term Sheet, the Commission should be cognizant of the impacts the Project would inevitably have upon the existing industries, environment, and culture and history of Maine’s unique coastal communities, and should weigh those impacts in the balance when considering whether the Term Sheet as originally approval is truly beneficial to all affected interests, including consumers and the communities that would experience the direct adverse impacts of large floating offshore wind turbines with the associated landing infrastructure.

PORT’s comments below address specific matters under the headings stated by the Commission.

C. Renewable Energy Goals

As the Commission notes (January 24 Order at 4), one of the purposes of the Act was to harness the potential for offshore wind energy resources to meet Maine’s renewable energy goals. PORT agrees with the Commission that Maine has been very successful in developing renewable energy resources, to the point where Maine’s existing renewable resources exceed the state’s renewable energy goals. Indeed, Maine has become a leader in this area.

As a result, PORT does not believe that Maine electricity consumers, who already experience relatively high energy costs, should be called upon to subsidize an experimental project that is not necessary to meet the state’s renewable energy goals. Nor should Maine’s coastal communities be subjected to the adverse impacts that inevitably would flow from the presence of floating wind turbines and the associated infrastructure necessary to bring electricity onshore. To the extent that Maine seeks to pioneer in the development of alternative energy technologies, it should look to new and innovative technologies that will not cause harm to existing communities and industries.

D. Tangible Economic Benefits and Commitment to Manufacturing Facility

In considering whether the Project and the associated Term Sheet will present the opportunity for Maine to achieve tangible economic benefits, PORT urges the Commission to bear in mind that if the Project comes to pass, it will inevitably produce adverse impacts on the individual coastal communities near the ultimate project site. These impacts will include damage to the landscape, environment, character, and quality of life of these communities. More specifically, long-standing fishing communities that have been a vital part of the state’s economy will be devastated due to loss of fishing grounds. In addition, there will be a significant loss of tourism dollars: the landscape will be less attractive and there will be diminished birding opportunities due to the effect of the Project infrastructure on migratory birds. Any benefits calculation should be a net benefits calculation that factors in the tangible detriments resulting from the Project.

In addition, as the Commission notes (January 24 Order at 5), other states on the East Coast have established offshore wind programs and are seeking to locate manufacturing facilities in their states. See “‘Made in the U.S.A.’ Turbines Complicate U.S. Offshore Wind Plan,”

Bloomberg News (Feb. 14, 2018) (https://www.bloomberg.com/news/articles/2018-02-14/-made- in-the-u-s-a-turbines-complicate-u-s-offshore-wind-plan, last accessed Feb. 21, 2018). This makes it increasingly unlikely that Maine will become a regional center for wind energy manufacturing, one of the goals of the Act. At a minimum, the Commission should take this into consideration when determining the economic benefits that can be expected to flow from the Project. The Commission should also consider that increasing the overall cost of electricity to Maine consumers by subsidizing the Project as contemplated by the Term Sheet may very well discourage other manufacturing from locating or expanding in the state.

E. Project Specific Circumstances 2. Interconnection Location

As the Commission notes (January 24 Order at 6), at the time the Term Sheet was approved it was anticipated that the Project would be interconnected with the electric grid at the Town of Bristol. MAV subsequently abandoned that proposed interconnection site. MAV has since approached St. George about the possibility of interconnecting there, but PORT is opposing any such proposed landing, and as the Commission notes, the interconnection location is still unsettled.

PORT believes that it is vitally important that “persons with an interest in the ultimate interconnection location have an opportunity to comment on the project[.]” (Id.) As explained above, if the Project ultimately is constructed, it will inevitably produce at least some adverse impacts on the affected coastal communities. The Commission cannot and should not blind itself to these impacts, and if the Commission is to take these impacts into account in its determination of tangible economic benefits – as PORT believes it must – this can only be done if MAV has identified an interconnection/landing site. Until an interconnection site has been selected and affected persons have had the opportunity to comment, the Commission should not grant its blessing to the Term Sheet.

PORT appreciates the opportunity to provide comments and to participate in this process.