Mr. Ronald C. DeCurzio
Chief Executive Officer
Massachusetts Municipal Wholesale Electric Company
327 Moody St, Ludlow, MA 01056

We, the undersigned community members, advocates, organizations, and elected officials are gravely concerned about MMWEC’s continued efforts to develop Special Project 2015A, a 60 MW natural gas and oil peaker power plant located in Peabody, Massachusetts. Our concerns, described below, center primarily around the Environmental Justice impact this project will have on local community members, especially given that the plant will contribute to the cumulative impacts of pollution that local communities will face. Additionally, moving forward with the peaker plant is counterproductive to Municipal Light Plants’ ongoing effort to combat climate change and transition to a clean energy future. This is especially the case in light of new State Policy, which establishes an emissions standard for Municipal Light Plants.

According to applications for permits, Special Project 2015A will emit nearly 51,000 tons of the greenhouse gas carbon dioxide into the atmosphere every year - the equivalent of adding 11,000 combustion engine cars to Massachusetts' roads each year. Furthermore, the peaker plant will require installing a natural gas compressor to increase natural gas pressure, a new 200,000-gallon oil tank, a 90-foot smokestack and a new 2,500 to 7,500-gallon tank to hold either aqueous urea or the hazardous gas, aqueous ammonia. This activity will not only have a highly detrimental impact on our environment and climate, but it will also further burden neighboring environmental justice communities with worsening air pollution and continued poor health.

According to the Department of Environmental Protection, there are two communities designated as Environmental Justice communities within half a mile of the proposed project, and a school less than a quarter-mile away. These communities already face increased exposure to harmful pollutants from the 68 MW in peaker power already installed at the proposed site of construction. Given their intermittent yet frequent output, peaker power plants generally emit higher levels of pollutants per unit of energy compared to other energy facilities. Peaker plants respond to high energy demand. Therefore, it can be reasonably expected that the plant already installed will run concurrently with Special Project 2015A, thus exacerbating the health impacts already present in neighboring communities. While claims have been made that the plant currently in operation will be retired, there have been no indications of this action being taken. At a time when alternative solutions are available, further exposing Environmental Justice communities to harmful pollutants is an option that we cannot accept.

Special Project 2015A is also unreasonable in light of the climate crisis the Commonwealth and global community faces. Scientists tell us that we stand "on the brink of failure when it comes to holding global warming to moderate levels" unless we take "unprecedented actions" to cut carbon emissions over the next decade. In January, Governor Baker committed the Commonwealth to an ambitious target of net zero emissions, noting that "meeting this challenge will require bold action and partnership throughout every sector of the economy." Finally, the legislature just passed bold legislation that puts the Commonwealth in a position to address the climate crisis. Notable in this legislation is the inclusion of a non-emitting standard for Municipal Light Plants - the first of its kind in the Commonwealth - which establishes a net-zero target by 2050. Instead of assisting in this mandatory target, Special Project 2015A inhibits Municipal Light Plants (MLPs) in achieving this goal by financially committing the 14 participating Municipal Light Plants to a dirty energy source for at least 30 years. In addition, the rapid energy transition in the Commonwealth and across New England will likely result in the need to retire Special Project 2015A before 2050 - leaving it to be a stranded asset that customers of participating MLPs will be stuck paying off for years after it has stopped supplying energy.

In 2021 alternative and affordable solutions to natural gas peaker plants are viable and economical. These alternatives were perhaps not as viable in 2015 when this project was proposed, however, MLPs must begin investing resources that move the state towards our carbon emission reduction goals. A 60 MW battery storage facility connected to either the grid or solar is not only technically feasible, it could be price competitive with Special Project 2015A. Despite this being a widely understood notion in the energy community, the permitting application for Special Project 2015A does not consider or rule out the viability of clean alternatives such as battery and storage to meet the demand claimed. Given that the project was delayed by more than four years, excluding an analysis of clean alternatives and cumulative impacts does a disservice to participating MLPs and the communities that will be adversely impacted by this project.

Taking these concerns into account, we call on you, as the Chief Executive Officer of MMWEC to withdraw the proposal to move forward with this project and, instead, replace it with a project that will reduce the burden on the communities of Peabody and Danvers, and support participating Municipal Light Plants in becoming leaders of the Commonwealth’s transition to a clean, renewable future.