NEW HAMPSHIRE TRANSMISSION SeaLink Position Paper Addressing the Reliability Needs of the Region Addendum April 2014 Greater Boston Stakeholder Letters Index Massachusetts Page number 1. Governor Patrick – January 13, 2014 1 2. Attorney General Coakley - March 18, 2014 3 3. Mayor Walsh (City of Boston) – October 24, 2014 5 4. Former Mayor Menino (City of Boston) - February 8, 2013 7 5. Select State Delegation Reps. & Senators – December 9, 2014 8 6. State Representative Miceli (19th Middlesex) – December 11, 2014 11 7. Mayor Christensen (City of Malden) - January 14, 2014 13 8. Mayor Kennedy (City of Lynn) – March 11, 2014 15 9. Senator DiDomenico (Everett) – April 2, 2014 17 10. Mayor Kirk (City of Gloucester) - April16, 2014 18 11. Mass. Municipal Wholesale Electric Coop – December 15, 2014 20 12. Asst. General Manager Boyle (MBTA) - March 4, 2014 23 13. David Begelfer, CEO (NAIOP) - April 18, 2014 26 14. Bob Rio, SVP (AIM) - June 6, 2014 27 15. President Tozza (Bike to the Sea, Inc.) – March 17, 2014 29 New Hampshire 16. Governor Hassan – January 22, 2014 31 17. U.S. Senator’s Shaheen & Ayotte - June 18, 2014 32 18. Senator Stiles (Seabrook) & select reps - April 2, 2014 33 19. NH DOT – December 4, 2013 36 20. Town Manager Manzi (Seabrook) - March 3, 2014 39 21. President Lalime (Friends of Seabrook Rail Trail) – March 19, 2014 42 Regional 22. NESCOE letter – March 22, 2013 46 Page 1 Page 2 THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF THE ATTORNEY GENERAL ONE ASHBURTON PLACE BOSTON, MASSACHUSETTS 02108 MARTHA COAKLEY (617) 727-2200 ATTORNEY GENERAL www.mass.gov/ago March 18, 2014 Gordon van Welie President and Chief Executive Officer ISO New England One Sullivan Road Holyoke, MA 01040 Dear Mr. JC—^ V-A)^—-— As the Greater Boston area faces significantly elevated energy and capacity costs due to generation retirements and increasing load, as well as transmission reliability needs that must be addressed in the near term, I urge the Board of ISO New England to deliberate carefully as it considers the competing proposed transmission solutions to ensure that necessary transmission investment is planned on a least cost basis. The region has a rare opportunity to choose between two competing solutions that can meet the requirements identified in the Greater Boston Needs Assessment. My understanding is that precise cost estimates have yet to be made generally available to stakeholders in a formal stakeholder process. When that time comes, we expect to participate in a transparent process in which we can evaluate whether the preferred solution has minimized the present value of the costs to consumers. The costs considered should not be limited to the capital expenditure, but should also include all revenue requirements and avoided costs, such as cost of capital, depreciation expense, operation and maintenance expense, administrative and general expense, taxes, congestion costs during construction, and any other costs that are identified by stakeholders. Additional costs that may be imposed as a result of siting requirements should be considered as well. We recognize that the cost estimates fall within a broad range, from minus 25 percent of the project estimate to 50 percent over budget. This range is an improvement over the past project planning practices, but it still poses an unacceptably large risk to consumers. If the developers are willing to cap their recovery for project costs, that cap should be taken into account in choosing between them. Cost overruns should be scrutinized to determine if the causes could lead to findings of imprudence. Finally, while my office maintains that neither competing project should qualify for incentive rate treatment, ISO New England should require the developers to disclose any incentives that they will seek before FERC. O Page 3 I want to thank you and your expert staff for the excellent work that you have done in considering our long term transmission needs. My office looks forward to supporting your efforts to maintain reliability in the Greater Boston area while minimizing long-term costs to consumers. Cordially, Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 April 18, 2014 Secretary Richard K. Sullivan, Jr. Executive Office of Energy and Environmental Affairs 100 Cambridge St., Suite 900 Boston, MA 02114 RE: Greater Boston Reliability Study Dear Secretary Sullivan: As you are aware, our members need reliable electricity seervice at competitive prices. I understand that Massachusetts customers will soon be asked to pay for a new transmission project to solve some reliability problems in the Greater Boston area. The decision by ISO New England on what should be built to solve those problems will have significant implications for our members in terms of reliability and energy costs in the short run and the long run. As our members can tell you, when a real estate investment is being contemplated, they have to consider all costs. When the ISO makes its decision, it too should look at all costs to ratepayers when comparing alternative transmission projects. Whether it is the initial investment costs or the ongoing transmission costs or the source cost of the energy, they should all be considered and balanced against the long term reliability of the energy. At this time, NAIOP has no recommendation regarding whicch of the proposed transmission projects should be selected. However, we ask you to communicatee to the ISO that its evaluation process needs to be comprehensive and should fully consider all of the costs and all of the benefits each alternative has to offer. I would be happy to discuss this further with you at your connvenience. Sincerely yours, NAIOP MASSACHUSETTS David Begelfer Chief Executive Officer cc: Barbara Kates-Garnick, Undersecretary for Energy, EOEEA Ann Berwick, Chair, Department of Public Utilities 144 Gould Street Suite 140 Needham, MA 02494 ph: 781-453-6900 www.naiopma.org Page 26 June 6, 2014 Maeve Vallely-Bartlett Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge St., Suite 900 Boston, MA 02114 Re: Greater Boston Reliability Study Dear Secretary Vallely-Bartlett: AIM would like to submit these comments relating to energy infrastructure investments in Massachusetts. AIM is the state's largest nonprofit, nonpartisan association of Massachusetts employers. AIM's mission is to promote the well-being of its thousands of members and their employees and the prosperity of the Commonwealth of Massachusetts by improving the economic climate, proactively advocating fair and equitable public policy, and providing relevant, reliable information and excellent services. As you know, AIM has been actively involved in the energy debate for many years. Throughout that time, we have consistently supported competitive energy markets and have long advocated for a transparent and competitive selection process for all types of power, including renewable power. This is a critical time for New England. We face a host of issues, from reliability concerns to retiring generation. Energy prices have reached historic highs during the winter, straining the ability of some companies to profitably operate in Massachusetts. In almost every survey our members consistently rank the cost and reliability of electricity and energy as one of their primary concerns going forward. We have been following the Greater Boston Reliability Study closely over the past year, as it will have significant implications in terms of reliability and energy and capacity costs for the Boston area. This is the first time two reliability projects have competed to serve Greater Boston. AIM understands that the competitive process has already demonstrated value through significant reductions in cost estimates and technical innovation. Page 27 AIM believes that ISO-New England should use a broad set of criteria in comparing these projects. In particular, this evaluation should include: 1) all costs that ultimately impact ratepayers’ bills, including congestion costs during construction; 2) the resiliency of the network, and the repair and economic costs of disruptions; and 3) the speed with which a project can be implemented to improve capacity and reliability in the region. At this time, AIM has no recommendation regarding which of the projects should be selected. However, we ask that you continue to work with ISO-New England so that its evaluation process is comprehensive and fully considers all of the costs and all of the benefits each project has to offer to Massachusetts ratepayers. Thank you for your leadership on this issue. Sincerely yours, Robert A. Rio, Esq. Senior Vice President and Counsel Government Affairs cc: Barbara Kates-Garnick, Undersecretary for Energy, EOEEA David Cash, Commissioner, Department of Environmental Protection Mark Sylvia, Commissioner, Department of Energy Resources, EOEEA - 2 - Page 28 Bike to the Sea, Inc. c/o James Tozza, President 12 Saugus Avenue Saugus, MA 01906 781-558-3535 March 17, 2014 Secretary Richard K. Sullivan Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston MA 02114 Re: SeaLink Project Dear Secretary Sullivan: For over 20 years, Bike to the Sea Inc. (B2C) has advocated for the creation of the Northern Strand Community Trail (NSCT). The NSCT, already partly completed with the assistance of EEA’s Recreational Trail program, is a regional recreational trail that when fully built out will extend about 10 miles from the Mystic River Reservation in Everett through the communities of Malden, Revere and Saugus, ending at the Nahant Beach Reservation in Lynn. The SeaLink project proposes to use nearly the entire length of the NSCT corridor en route from Lynn to the power grid in Everett. Our focus is to complete and improve the surface of the corridor as a recreational trail.