I face a dilemma. Based on my readings of past FERC decisions, FERC policy and the Gas Act I’m fairly certain that the FERC will appear to listen but ultimately will not consider any argument as to “why” and “whether” no matter how rock-solid and evidence-backed it is. As such, I feel to have any effect I must make a three-part argument:
- A meta-argument about why “the why” or “the whether” must be considered
- Frame my argument
- Make the core argument
This is huge task. The dilemma is as a private citizen I have limited time and resources and having to make multiple arguments will mean less time to spend on each argument. Less time means the arguments will be weaker therefore less likely to be considered. A Catch-22!
So I attempted to do one thing well rather then many things poorly in the Northeast Energy Direct Pipeline: Everyone is Right. . . so What is Wrong? argument. Based on limited feedback I think I failed. It stands up on its own but not very well because the framing is weak and the meta-argument is non-existant. On the other hand I can’t spend much more time on this.
So let me roughly outline a stronger framing that this could fit into if someone else has the time to run with it:
- Current, approved, planned projects have been shown to meet New England energy demand through 2030
- Since it greatly surpasses New England demand, it is over-supply and as such can create supply-driven demand.
- There is already strong evidence of supply-driven demand in the application for reversal of the Maritimes & Northeast pipeline as well as applications to export.
- This appears to be un-studied. I have not been able to find any reports that look at aggregate demand; the papers I have read only look at black-box New England market demand.
- Without the notion of aggregate demand it is utterly unclear what this will do to the New England energy market prices. As such, any argument about positive effects on price is invalid and should be stricken from consideration. It is simply unknown.
- New England’s energy portfolio is already too gas-heavy (47% and growing!) [this is the argument I made here]
- Increasingly from one fuel(gas) via one transport method(pipeline) from one location(Marcellus)
- I challenge the FERC to show what market or regulatory mechanisms hedge the risk of a severely unbalanced portfolio:
- The FERC doesn’t
- ISO-NE doesn’t
- The markets don’t
- States’ Renewable Portfolio Standards only have a tiny slice of the pie
- The FERC may argue that energy portfolios are not their domain however if it is an un-hedged risk it must be a consideration or else the FERC’s decisions risk being aware of it yet exacerbating it!
- There is both leading innovation and substantive progress in the New England energy market and over-supply could quash it
- New England has no domestic fossil fuel supplies; we traditionally have imported everything
- For the first time New England is generating a non-trivial amount of energy locally
- There has been pain but without pain there is no innovation; New England’s energy pain has resulted in New England energy innovation
- We already have ample gas underpinning to supply spinning dispatch for solar and wind (47% and rising); thus arguments that we need more gas to support renewables are invalid and should be stricken from consideration.
- The pipeline is easy; the easy route is not necessarily the right route.
- The economic risks are clearer then the economic benefits; thus it is an unnecessary exercise of eminent domain.