The sacrifice of language 

One of the earliest victims of deceitful policy is clear language. Of particular note in the case of the Lowell Wind Project:

Every professional policy analyst would state under oath that before a policy could be called “cost-effective” that it must first be “effective.”

In the current policy context which includes every wind project that has ever been built in the world, the net emission of CO2 increases. For every ton avoided by emission free energy, there are 7 tons added by expansion of fossil fuels (Energy Information Administration).

In performing my cost-effectiveness analysis, I assumed that “100 % availability” meant “100% availability”, an apparent legitimate interpretation of those words. In their letter to the Irasburg Select Board GMP and VEC explained why “100 % availability” does not mean “100 % availability”. Similarly they explained why “prior to loss factor being applied” does not mean “prior to loss factor being applied.” Due to these “critical errors” on my part I over-estimated the cost-ineffectiveness of the Lowell Wind Project; instead of being 12 times more expensive than what is considered reasonable, it is only 7 times more expensive. The critical error, in my opinion, is that the Public Service Department, our employees, didn’t catch these errors.

In order to receive a certificate of public good, this project must be part of a “least cost integrated plan”. Commissioner Miller of the Public Service Department clearly stated at the VEC meeting last Saturday that there is currently no integration of energy policy; therefore, there is clearly no integration of this project into an overall energy strategy.

The “least cost integrated plan” that would solve both our dependence on foreign oil and our contribution to global warming would be either a national cap and trade policy or a carbon tax. With either of these policies in place, we could solve these problems at a cost of $25 per metric ton of green house gas emissions. According to my now corrected cost-effectiveness analysis, the Lowell Wind Project is costing us $188 per metric ton, certainly not the least cost alternative.

As a final point, GMP and VEC were able to identify the “critical errors” in my analysis because my analysis is a public document available at http://energizevermont.org/?p=3530. None of the details that support their allegation that the Lowell Wind Project is the best alternative for Vermont are available as public documents. We are being asked by our Public Service Board to trust the corporations. I prefer Ronald Reagan’s approach on this matter, “trust but verify.” I have expanded my diagnosis of regulatory capture of the Vermont Public Service Board and Department of Public Service by the energy industry to every state that has approved an alternative energy project that costs more than $25 per metric ton of CO2 emissions avoided.

Perhaps you recall that in major public policy issues over the past 5 decades – like the alleged attack of U.S. destroyers in the Gulf of Tonkin, the alleged weapons of mass destruction in Iraq, and the more recent alleged safety of bundled mortgages – the minority opinion at the time was proven correct.

Though regulatory capture by the energy industry is pervasive in this country, we can stop it in Vermont.

Sincerely,

Ron Holland

Irasburg