Dear ISO New England Environmental Advisory Group:

ISO New England plays a pivotal role in influencing energy policy in our region.

It is imperative that your reports contain accurate and complete data about greenhouse gas emissions from electricity used in New England.

The 2019 Air Emissions Report undercounts the greenhouse gas emissions because it treats imported Canadian hydropower as having zero emissions.

Hydro-Quebec’s own reports show the emissions are not zero. Science shows its emissions can be on par with fossil fuels.

We are in a climate crisis. There is no time for shell games with counting carbon emissions to the atmosphere.

We ask you to add a caveat to the 2019 Air Emissions Report to show that the report is undercounting emissions because it is not counting greenhouse gas emissions from Hydro-Quebec electricity used in New England.

We urge you to take steps to immediately close this carbon accounting loophole by requiring accurate and complete accounting of greenhouse gas emissions from Canadian hydropower imported to New England.

Thank you.