Public Comment for the State Ten-Year Energy Strategy Update
Thank you for the opportunity to comment on the state’s ten-year energy strategy. The signatures on this comment represent 350 New Hampshire, a local environmental advocacy organization. 350 NH is a multigenerational movement working to advance a just transition to a renewable energy economy and an end to our society’s dependence on fossil fuels, with over 15,000 supporters in New Hampshire. We hope our comment may help the Department of Energy modify the state energy strategy so the department can fulfill its mission of securing an affordable, innovative, reliable, and sustainable energy economy for our state.
New Hampshire has no concrete greenhouse gas emission reduction goals or legislative-mandated climate action plans. That said, it’s in the best interest of the Department of Energy and the general public to ensure our energy policy meets the needs of Granite Staters in an affordable, safe, healthy way that also addresses the problems facing our current energy system. The numbered statements below are pulled from the 2022 10-year strategy document, followed by our comment on how 350NH Action sees that the Department of Energy can meet its goals.
1.Prioritizing cost-effective energy policies.
Solar and wind energy are becoming cheaper in relation to oil and natural gas (methane). The solar and wind industries have taken off in the last decade, and more manufacturing is happening on a larger scale. Local wind and solar resources are significantly cheaper to keep on our grid because, unlike oil and methane, they don’t require operational costs to get shipped into our region. Geothermal energy also has potential in this region to support better home heating options. Projects like the pilot in Framingham, Massachusetts are proving geothermal home heating to be an affordable and clean alternative to oil and gas.
Investing in battery storage, energy efficiency, and demand response will also prove to be cost-effective and will be included in this comment under a different section.
2. Ensuring a secure, reliable, and resilient energy system.
In order to ensure a secure, reliable, and resilient energy system, that energy system must be designed to operate under current conditions and uncertain future conditions. New Hampshire has had increasingly worse storms over the past few years: extreme flooding, ice storms, and even thunderstorms with tornadoes and high winds. This Connecticut case study predicts power outage increases of 42%-64% by the end of the century due to increased heavy wind and precipitation. All of these conditions make it more difficult to ensure a reliable energy system. The state must take this into account when talking about energy sources and strategy for the next 10 years. Burning oil and methane for energy actively makes this problem worse, so maintaining a technology-neutral stance in the current environment is not safe for our energy grid. Instead, policies must follow common sense to minimize the damages the grid gets from climate crisis-fueled disasters.
We also need to invest more in our transmission system to improve reliability. Upgrades to poles and wires need to consider the added solar and wind power from small, local sources and community-built projects. The current backup of renewable energy projects waiting to connect to the grid is influenced by our transmission system, which needs major upgrades.
A resilient energy grid is also one where we can be self-reliant. New Hampshire imports uranium, oil, and gas in order to power the nuclear facility, home heating, oil-fired plants, and gas-powered plants. Only about 17% of our energy is produced locally, from hydropower, biomass, wind, and solar. Tariffs on Canada are likely to impact the cost of our energy though the exact impact is uncertain at the moment. We should diversify our energy mix to create a more resilient system. More wind, solar, and geothermal energy produced locally will reduce our dependence on imports and secure a more reliable source of energy. With more of a focus on locally produced energy, we can also support microgrids to improve conditions for Granite Staters, which regularly experience electricity outages. These energy sources are more sustainable in the long term and make our system safer.
3. Adopt all-resource energy strategies and minimize government barriers to innovation.
The current NH legislature is making it impossible for the Department of Energy to achieve this goal in their pursuit of disavowing offshore wind and eliminating government positions related to the Gulf of Maine Wind Task Force. Offshore wind is a growing industry, and our neighboring states are already taking advantage of this innovation. Manufacturing and distribution centers are being set up in Massachusetts and Connecticut, while New Hampshire legislators are trying to eliminate wind workforce training resources. We are set to lose millions of dollars if we refuse to be a part of this project. If we are to minimize barriers to innovation, we must not ban innovation like this, and the Department of Energy must advise the Governor that signing these bills is not in the state’s interest.
Any “all-resource energy strategies” need to even the playing field. Right now, New Hampshire makes it easier for oil and gas resources to build than it does for clean, renewable sources. The state should protect the Renewable Portfolio Standard that allows small-scale hydropower resources to exist and enable more net metering opportunities that help people choose to build solar panels on their own properties. Fuel diversity is essential, and right now, we rely too heavily on methane gas resources. To diversify our energy mix, we must reduce methane gas use and increase clean, renewable energy. New technologies are being developed every year that are cleaner and safer for our environment. Showing these industries that NH is open to that kind of work will help us attract business revenue for the state and clean up pollution from oil, gas, and coal that resides in our state.
4. Achieve cost-effective energy savings.
The cheapest energy is the energy we do not use. We should increase resources to NH Saves and support weatherization efforts for government-owned buildings to reduce our energy use. This benefits the state and our residents, and should especially be focused on supporting low-income Granite Staters and residents who live in really old, poorly insulated homes. A single household spends $2,000 on average on electricity costs and greater energy efficiency measures can save hundreds of dollars a year. When we need less energy because we have high efficiency, we need fewer power plants.
5. Achieve environmental protection that is cost-effective and enables economic growth.
Clean and renewable energy is the solution if the goal is economic growth and environmental protection. Expanding wind (onshore and offshore), solar, and geothermal energy production will allow us to get off of energy sources that pollute the environment with oil spills and methane emissions. It is significantly more cost-effective to prevent further pollution than it is to clean up pollution down the line. Unfortunately, we already have soil and water contamination resulting from coal plants in Bow and Portsmouth, but we can prevent further spills by preventing any new pipelines or fossil fuel projects from being built. We must make wise decisions about new energy investments that do not perpetuate pollution or over-reliance on one type of fuel.
6. Government intervention in energy markets should be limited, justifiable, and technology neutral.
If environmental protection, cost savings, and reliability are important to the state energy plan, then being technology-neutral in our approach to the energy market conflicts with those other goals. Technology is not neutral. Nuclear energy comes with its own safety risks and waste disposal challenges. Solar energy comes with energy production patterns that increase capacity in the summer compared to the winter. Solar is also produced here and doesn’t require us to ship in fuel. Burning oil for electricity comes with harmful emissions that impact human health and contribute to the climate crisis, which causes a more unreliable energy grid. Oil also must be shipped here from elsewhere since we don’t produce it here. We must weigh all the costs - direct and indirect - in our energy decisions. We must ensure that the limited and justifiable interventions in the energy market account for the reality of the technologies we use.
7. Support a robust, market-selection of cost-effective energy resources.
Right now, electrification is popular. People are installing heat pumps in their homes more than ever. Rooftop solar, when accessible to people, is more popular now than it was ten years ago. More people drive electric vehicles or wish to see more public transportation options. To ensure the new energy resources being added to the grid are done so in a cost-effective way, the NH energy strategy should include three other passive resources: demand response, energy efficiency, and battery storage.
Demand response resources are a vital way for the state to decrease overall energy use, reducing the amount of on-demand resources we need to keep the electricity running. There are large-scale energy users and large numbers of household ratepayers who would voluntarily participate in demand response to ensure a reliable and affordable energy grid for everyone, but the region is not bothering to use us as a resource. New Hampshire should join residents in pushing ISO New England to facilitate more and better demand response resources. If we can implement better demand response, we don’t have to maintain as many oil or gas facilities that rarely get turned on.
Energy efficiency makes everything cheaper. It saves money on electric bills and makes housing more resilient in extreme heat or extreme cold. It is reliably cost-effective, and the state should be prioritizing it.
Battery storage is another resource that can be available on-demand during peak energy use. It can provide cheap, reliable energy during those times because our electric system can charge those batteries during low energy use times. Battery storage can prevent us from using the most expensive fuels in the state (which, at the moment, is oil).
8. Generate in-state economic activity without reliance on permanent subsidization of energy.
Right now, our entire energy system is subsidized. Coal, oil, and gas continue to be a resource because of huge government subsidies. The same is happening with wind and solar power. Renewable energy resources are our best bet for in-state energy independence. They are also resources that we can sustainably rely on. Oil and gas reserves are a finite resource. Local renewable energy projects will also bring new, reliable jobs to the state. It’s vital for us to consider the positive economic impact local energy production would have in New Hampshire. It would create thousands of good jobs and support local supply chains.
9. Protect New Hampshire’s interests in regional energy matters.
New Hampshire is not an island. We are connected to the regional energy grid that Massachusetts, Maine, Vermont, Connecticut, and Rhode Island are connected to. New Hampshire’s resistance to working collaboratively with our neighboring states is hurting New Hampshire residents as seen by the fact that our energy costs are currently the highest.
10. Ensure that appropriate energy infrastructure is able to be sited while incorporating input and guidance from stakeholders.
Much like this public comment period, this point directly contributes to the Department of Energy’s goal to service NH residents in a transparent, honest, and effective way. The ongoing conversations about ensuring new projects can be sited and connected to the grid efficiently and safely are incredibly important. The stakeholders who should be providing input and guidance as more projects move forward should include residents impacted by infrastructure in their communities, local elected officials, energy experts, utility companies, environmental advocacy organizations, scientists, and the company sponsoring the project. It is important to ensure that the people and environments impacted are part of the conversation to ensure the least negative impacts possible.
We appreciate that the Department of Energy is considering all aspects of the energy system including environment, cost, siting, reliability, and innovation. We recommend broadening the resources that the Department of Energy uses to make their assessments, as the Lazard study that is referenced in the previous strategy document does not have a full account of the impacts of energy policy. It is obvious that clean energy, energy efficiency, and improved transmission will reduce costs, generate local revenue and jobs, and improve our environmental sustainability. We implore the Department of Energy to bring this 10-year strategy into the modern reality of the electric grid. Thank you.
Signed,
350 New Hampshire