Public Comment on Maine’s New Draft Energy Plan

To the Maine Governor’s Energy Office,

Thank you for the opportunity to comment on how Maine will pursue the goals set in the Maine Energy Plan. This is the Maine Policy Institute’s response to your request for public review and comment on the draft plan, its objectives, and the strategies it considers to pursue those objectives. We have also included feedback to the “Maine Pathways to 2040: Analysis and Insights” report by the Brattle Group and Evolved Energy Research, cited multiple times in your draft plan as “the Technical Report.” While the information provided below may not address all of the content of this plan, we hope it helps inform the final energy plan of the Governor’s Energy Office.

Overview

As a preface, we are stating our strong objection to the projected policy goal of 100% clean energy by 2040. According to a report by Always On Energy Research, New England will suffer major increases in energy costs and reductions in energy reliability if we continue to pursue these renewable-focused policies. To achieve this target, New England as a region will need to spend significant amounts of money overbuilding production and increasing supply to account for a transition to the majority of non-dispatchable energies, or we will suffer more frequent blackouts and unaffordable electricity by 2050.

According to the Maine GEO’s webpage and introduction of the report, there are three alleged benefits of pursuing the 2040 plan, all of which are poorly justified. There are several issues with the energy plan’s alleged benefits, one reason being that the benefit of “diversifying Maine energy sources” while also “reducing reliance on [..] fossil fuels.” is both false and contradictory. 

The technical report claims that in 2023, about 65% of in-state generation came from renewables. Logically, therefore, reducing fossil fuel usage would make Maine’s energy sources less diverse. If by 2040, Maine relies entirely on a small group of clean energy sources, such as solar, wind, and hydro, with no fossil fuels involved, then it is, by definition, less “diverse” than a power grid that includes another 4 or 5 minority energy types from fossil fuel sources. Parsing out whether an energy grid is more “diverse” has questionable relevance, but that is another criticism of the draft report bringing up this subject in the first place.

The second alleged benefit is greater regional clean energy cooperation on clean energy investments and greater utilization of the Inflation Reduction Act’s clean energy subsidies. The fact that a decidedly pro-fossil fuel presidential administration is incoming with a federal Republican trifecta means that many federal support structures for renewable energy have a shaky future. Additionally, such federal support may soon target fossil fuels rather than ignore them, making this issue anti-renewable rather than pro-renewable.

Lastly, this policy would allegedly advance the governor’s goal of increasing clean energy jobs in Maine. According to this same office’s 2023 Clean Energy Industry Report, Maine’s clean energy jobs only increased by 2,000 between 2016 and 2022, and the total as of 2022 is “over 15,000 workers.” Even if Maine increased its employment in the Clean Energy sector by five times the job growth over that period, we would still be almost 2,000 jobs short of the governor’s energy growth goals. Furthermore, using one clean energy policy goal as the justification of another clean energy policy goal amounts to circular reasoning and is incredibly weak considering the numerous costs of continuing to pursue such policies.

Also, several troubling assumptions are made in the technical report, which are likely incorrect. On Page 33, the report assumes that Maine’s three planned gigawatts of offshore wind will be built by 2040. However, Maine’s Sears Island Windport has hit a practical standstill due to the fallthrough of an expected $450 million+ federal grant and an incoming renewable-skeptical presidential administration. According to the National Renewable Energy Laboratory, it can take up to ten years to build a wind port. Due to the need for federal funding, the importance of in-state launching, and the timeline effectively requiring a future presidential administration to rubber stamp hundreds of millions of dollars of financing by 2030, the likelihood of meeting the 2040 timeline seems relatively low.

The technical report also assumes a steady decline in baseline energy consumption prices when significant cost growth has occurred over the last few years. Explaining the justification for this prediction in more detail would help provide insight into the logic of the GEO and its contracted firms. Lastly, the technical report fails to consider with significant depth the option of advancing nuclear as a dispatchable clean energy option. 

Analysis of Objectives in the Draft Energy Plan

The following section of this comment will consist of a response to the five objectives and accompanying strategies listed at the end of the draft Energy Plan. . 

For “Objective A: Deliver affordable energy for Maine people and businesses,” the listed strategies focus on efficiently using federal funding to support renewable energy projects. As previously noted, federal funding is shaky support for renewable energy projects, even under the Biden administration. Furthermore, the incoming Trump administration will make this strategy even more unreliable. 

Additionally, the affordability of renewable energy in New England is questionable due to the $815 billion an expanded renewable energy resource mix would cost ratepayers through 2050. Lastly, the diversity of such a system has already been addressed, and it should be emphasized that a more diverse energy system is not simply a system with more allegedly “good” energy, but a more extensive mix of energy from different or diverse sources. Since this plan would make Maine heavily dependent on wind and solar energy, the current energy plan would do the opposite of diversifying our grid.

Objective B emphasizes our energy grid’s reliability, which is especially concerning to Maine Policy Institute. A non-dispatchable focused energy grid would require a massive investment in overbuilding energy production and storage. It would still be at risk of blackouts when an unexpected surge in demand occurs that exceeds energy storage capacity. A dispatchable energy system, clean or otherwise, is far superior in reliability and avoids much of the storage investment the draft plan requires.

Objective C is focused on responsibly advancing clean energy and discusses, in part, adding a clean energy standard on top of Maine’s current renewable portfolio standard. The report claims that the RPS saves Mainers $21 million annually. However, this increase in affordability is somewhat underwhelming when compared to the $220 million renewable energy mandates such as net energy billing costs ratepayers annually. Offshore wind will not increase this affordability either, as it has the highest all-in-system cost per megawatt-hour of all forms of renewable energy. While transitioning Maine’s RPS to include nuclear would be preferable to the status quo, the costs clearly outweigh the savings for renewable policies like this.

Objective D is to deploy efficient technologies to reduce energy costs, emphasizing electrification. Electric vehicle deployment is frequently a major target of projects like these. However, it should be noted that increased EV usage is unlikely to come to Maine soon. While increased public education and subsidies may look attractive on paper, the widespread public backlash to the Department of Environmental Protection’s policy concerning statewide EV mandates illustrates the strong public opposition to EVs.

Lastly, Objective E is to advance clean energy careers, and many of the strategies emphasize preexisting techniques such as expanding energy efficiency jobs and career pathway education. However, before advancing clean energy careers, we should both properly define what a clean energy career is and understand that not all clean energy careers are created equal. 

More than half of the clean energy careers are labeled energy efficiency jobs, a questionable category to include in this metric. Many of these workers simply install products that reduce energy consumption, rather than individuals working on clean energy production projects. Emissions reduction workers being included effectively doubles the total clean energy worker employment metric, and including this category in Maine’s energy plans will reduce the accuracy of any findings related to employment.

Second, many of these jobs are part-time clean energy work. If someone spends a few hours a week installing solar panels, they are considered an additional energy worker. Not only does this mean that this metric indirectly encourages Maine to create lower-quality part-time jobs as opposed to high-quality full-time employment, but it also causes further distortion of the clean energy job market. The 2023 Clean Energy Industry Report adjusts for this by summing multiple part-time workers into single full-time employees, called “intensity-adjusted employment.” Still, the draft energy report fails to include this lower figure. For context, the intensity-adjusted employment number is 11,063 workers, which is approximately 26% lower than the decontextualized number cited in the draft report.

For further context, nuclear energy pays far better. The average nuclear plant employs 500-800 workers and employs up to 9,000 workers during peak construction. Additionally, these nuclear workers’ salaries are 50% higher on average than other electricity generation employment. If Maine’s goal is to create clean energy jobs, this would be the better policy avenue to pursue.

Recommendations

Maine Policy Institute thanks you again for the chance to comment on the draft energy plan. First, we recommend emphasizing the actual costs advancing renewable energy will have to Mainers’ energy bills and energy reliability. Additionally, better-contextualizing employment data and nonrenewable alternative plans would better inform state policymakers as to the best policy strategies to pursue. Lastly, avoiding inaccurate descriptions of renewable energy policies as increasing affordability, reliability, or diversity of power sources would allow policymakers in Maine to more effectively consider the policy strategies and their drawbacks accurately.