Christopher Warfel 0

Opposition to DeepWater_Block Island Transmission Cable

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The use of this web-based process should be seen by USACE and CRMC as a valid foundation for accepting and reviewing public input in opposition to this project.

We are utilizing a web-based petition in order to provide the USACE and CRMC a consolidated document for review given the short time between the Town of New Shoreham (Block Island) Town Council Meeting on December 18, 2012 which finally asked for input on this process, and the February 10, 2013 submittal deadline.

We ask that USACE and CRMC consider any document submitted by the Town of New Shoreham to the USACE or CRMC supporting the DeepWater Block Island Transmission Cable project as representing only those opinions of the three of the five members of the Town Council who voted to approve the document, and in no manner be construed as necessarily representing public support.

The reasons for our opposition are many, and are as varied as the people who live on Block Island. The signators believe that the following information provides fundamental reasons for the USACE and CRMC to withhold approval from this project in its current format. Signators with additional reasons for opposing this project have added their own reasons by their name.

Fundamental Reasons for Withholding Approval Based Upon Town of New Shoreham Conduct:

1. Unknown to many residents of Block Island, the Town of New Shoreham appears to have been supporting this project for at least 2 ½ years, maneuvering Block Island through various regulatory processes required for approval of the DeepWater wind farm and Block Island electric transmission cable. During this time the Town did not schedule any public meetings to discuss the merits of this project as a whole. Instead, the Town broke the project up into small pieces, consisting of public meetings of regularly scheduled committees and commissions for prescriptive administration issues such as easement approvals, and zoning and permitting approvals. We contend that this was done so in a deliberately unobvious manner in order to avoid public meetings to discuss fundamental questions this project and its many faceted and complex components. This entanglement is inappropriate and did not provide residents the opportunity to discuss this project except in small pieces.

2. The Town’s “expert” witness testimony before the RI Public Utilities Commission should not be considered expert in this matter. The Town of New Shoreham deliberately used the same person who they use in many types of RI PUC hearings despite this individual’s lack of knowledge in the subject matter. The testimony was submitted with very little analysis to justify the support of this project. The conclusions drawn are speculative and should not be considered representative of expert analysis. The testimony supporting this project was submitted well before several important Federal and Rhode Island state agencies had released their finding regarding this project. It is unconscionable that the Town of New Shoreham allocate so few resources for professional expertise for this project.

3. Several of the Town of New Shoreham’s committees or commissions have been tasked to support the project without the Town providing any means of qualified assistance in analysis. This means that volunteers are being required to deliver opinion on matters they are not necessarily qualified to render decision upon, and the Town has used these decisions as further justification to support this project.

4. We believe the Town of New Shoreham has deliberately avoided adopting common energy conservation and renewable energy measures in an effort to keep the energy consumption on Block Island artificially high. We suspect that the Town has failed to support the adoption of any electric utility energy conservation programs through actions at the Rhode Island Public Utility Commission for the same reason. Block Island is the ONLY town in RI that does not have these programs. The First Warden is on record saying that solar-based renewable energy is problematic, showing a severe misunderstanding of this technology and its utilization.

5. The Town has referenced surveys as a basis for contending community support; surveys which are not qualified surveys, and which are seriously flawed in approach. The Town has made no effort to place this project on a ballet for any type of referendum, nor has the Town retained a professional survey company to create or conduct a statistically valid survey.

6. The Town stands to gain financially from easements it has granted, and appears to be a conflicted party in representing the interest of Block Island residents. DeepWater has apparently paid the Town for its "expert", LaCapra who as noted supported the project without undertaking or presenting any independent and comprehensive analysis, and for the BIPCo regulatory attorney.

Fundamental Reasons for Withholding Approval Based on Erroneous Economic and Environmental Impact Analysis by the Town of New Shoreham, the State of Rhode Island, and/or DeepWater

No one representing the Town has verified RIDEM PUC submitted testimony dated July 20, 2010 regarding the benefits of the project. The testimony gives unqualified support of the project. This appears to be a less than objective analysis. RIDEM’s submittal provided no caveats, cited no negative issues or impacts. Attempts to verify the calculations give credence to the possibility that the analysis may be wrong. The RIDEM analysis has been cited by the Town, and DeepWater as reason to support the project. RIDEM has not been forthcoming in answering concerns about the analysis. RIDEM and Deepwater have incorrectly represented several benefits of the project, including attributing the annual generation and environmental benefits to BIPCo, which is mathematically incorrect and contractually impossible.The Town has assumed that BIPCo will pay the equivalent of Natural Grid’s standard offer, when in fact BIPCo will be paying a homogenized rate offered by ISO New England’s generators. These rates may be very different. This directly impacts the savings to Block Island ratepayers and is a critical error. The analysis should have been conducted by professionals over 2 ½ years ago, before any support was given by the Town. No provision has been made for consideration of how to allocate the economic burden of replacing or repairing the cable when the wind turbines are dismantled. This could be economic disaster for the residents of Block Island. Once the turbines are dismantled, only Block Island will have an incentive to maintain the cable. It has been repeatedly demonstrated that the number of kWhs utilized on Block Island is far from what is necessary to amortize the cost of the cable without a very large rate increase. What is being represented as an umbilical cord for Block Island could very well become a noose around the neck of the residents and businesses.The Town undertook no action to assess other options for Block Island’s energy requirements. Technology exists today to deliver renewable energy at a fraction of DeepWater’s cost, keeping more money in Block Island’s and Rhode Island’s economy. Approximately 38 times the current BIPCo capacity could be built for the capital cost of Deepwater. Additionally, the cost of electricity from Block Island based renewable energy sources would approach 2 cents per kWh in ten years. At that time Deepwater’s electricity will cost over 30 cents/kWh and continue to increase for another ten years.The State of Rhode Island and DeepWater initially represented this project as a job creation opportunity. The latest analysis by DeepWater and the State indicates that Block Island Power Company alone may lose more jobs than the DeepWater project creates. The loss of jobs throughout Rhode Island due to the high cost of energy that would come with this project has not been assessed, but certainly would further harm Rhode Island’s economy.This project has been forced upon the taxpayers and residents of Rhode Island by Legislature fiat. The RI PUC rejected the original power contract between National Grid and DeepWater citing the extraordinarily above market cost of the project and its deleterious effect upon Rhode Island’s electricity rates. The Legislature effectively undertook an end run around the authority and passed legislation requiring the RIPUC to approve the project. This is analogous to spot zoning, and obviously is a usurpation of the RIPUC’s authority, and which had no provision for meaningful public opposition to be voiced.

Fundamental Reasons for Withholding Approval Based Upon Risk Assessment of DeepWater Wind

DeepWater Wind is owned by hedge funds D.B. Shaw & Co and Ospraie Management. Neither company has demonstrated experience with building and operating offshore wind turbines in the area and/or conditions proposed. Both have suffered substantial monetary losses in the past two years for differing reasons. DeepWater has provided over $4 million dollars to Rhode Island Economic Development to fund the Special Area Management Plan (SAMP), which resulted in the designation of the area off of Block Island as appropriate for development. The use of the developer’s money for this purpose is not consistent with the separation necessary to maximize independent analysis and conclusions.DeepWater steadfastly maintains that the purpose of this project is to establish the risk premium required by the larger off shore wind project planned 14 miles to the southeast of this one. This makes no sense. The risk premium should be established at the location of the project. Spending $260 million dollars is far beyond what is necessary to establish the risk premium of offshore wind turbines. Mooring several turbines or heavily instrumented models of turbines will accomplish the same task at less than $10 million dollars. The most recent study of offshore wind projects indicates the turbines capacity factor is reduced by one-third after ten years, and have a life between twelve and fifteen years, not the twenty years represented by the State of Rhode Island and DeepWater.

So what could be actually going on?

Once CRMC provides approval for the SAMP and the application, the site may be developed to the full permitted capacity of the site. Modifications may be made by the applicant (DeepWater) to install many more turbines than the six now under consideration. Transmitting this power can be accomplished by installing a larger cable, or raising the transmission voltage of a smaller diameter cable. Since no equipment has been ordered, the modifications required with either of these options are of minimal incremental cost. This is analogous to a bait-and-switch tactic, except the consumer cannot walk away from the “deal”. To illustrate how possible this is, DeepWater has presented maps showing a future transmission cable just south of the SAMP zone, from the 900mW DeepWater Wind Energy Center to Orient Point, Long Island.An offshore wind transmission cable from North Carolina to New Jersey is currently undergoing permitting. Expanding this cable along the coast of Long Island is certainly possible.

In summary, the residents of Block Island, the citizens and businesses of Rhode Island as a whole are put at economic risk by this project. The conduct of the former Governor of Rhode Island, Donald Carcieri, and the Rhode Island Legislature, which effectively forced this project to be viable for DeepWater, is an abrogation of their fiduciary and constitutional responsibility to the citizens of Rhode Island. The economic benefits of this cable accrue almost completely to the hedge funds that own DeepWater. Much better economic and environmental benefits could be realized at 15 to 20 percent of the project’s cost. Therefore this project fails all four of the tests normally required by such a project: Utility (National Grid), Participant (National Grid Customers), Non Participant (None, all are captive), and Society (Society must pay an extraordinary amount for this energy, energy which could be developed by proven renewable energy technology at a far lower cost). We ask that the United States Army Corp of Engineers reject this project as serves only the very limited interests of the owners, and places great risk upon those who are held captive and who will be required to pay the egregious price, both economically and socially if this project were to go forward.

Submitted Electronically, by Web-based Petition Process


Common Sense


2008 document that shows the beginning of the Town's involvement and manipulation of information

Latest study on offshore wind turbine reliability

RI PUC Hearing Rejecting the Power Contract
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