Dear Secretary Theoharides,

We, the undersigned community members, advocates, organizations, and elected officials are gravely concerned about MMWEC’s continued efforts to develop Special Project 2015A, a 55 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 already 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.

According to applications for permits, Special Project 2015A will emit up to 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 90-foot smokestack and a new 2,500 to 7,500-gallon tank to hold aqueous urea. 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 recently updated maps provided by the Department of Environmental Protection, 2015A is set to be built directly in an environmental justice community. In addition, the proposed site is less than a mile from seven other environmental justice communities located in Peabody, Danvers, and Salem. These communities represent over 10,800 people living in environmental justice communities whose health, environmental quality, and wellbeing will be directly impacted by the proposed dirty peaker plant.

These communities already face increased exposure to harmful pollutants. In Peabody specifically, there are already two natural gas peaker generators, three locations of toxic release, 15 air pollution sources, and 85 sources of hazardous waste. In spite of the existing pollution in and around the EJ communities of Peabody, 2015A has, thus far, not conducted an Environmental Impact Report (EIR) or a Community Health Impact Assessment (CHIA) to determine the impact of the proposed project on community health and the local environment. However, the Next Generation Climate Bill, enacted into law in June of 2021, requires EIRs for all projects that are in or near Environmental Justice communities. It further requires that the cumulative impact of such a proposed project is identified and considered. At a time when increased protections for Environmental Justice Communities were just enacted into law, it is irresponsible and unjust to allow this project to move forward, especially without additional studies to determine the real impact the project will have.

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 state enacted 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 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. During MMWEC’s pause, Massachusetts Climate Action Network worked with the Clean Energy Group and Strategen to conduct an analysis of viable alternatives to this project. Based on an annualized cost comparison of 2015A and standalone storage, standalone storage was assessed to be the more cost-competitive option and the option that provided important additional benefits―including reliability and reduced emissions. Alternatives such as battery storage were perhaps not as viable in 2015 when this project was proposed. However, now that technology has advanced, MLPs must begin investing in resources that move the state towards our carbon emission reduction goals. Given that the project was delayed by more than five years, excluding an analysis of clean alternatives does a disservice to the participating MLPs and the communities that will be adversely impacted by this project.

We call on you, and the Office of Energy and Environment Affairs including the Department of Public Utilities and the Department of Environmental Protection to:

1) Reject MMWEC’s request to receive $170,000,000 in publicly financed bonds to fund the peaker on the basis that this project does not serve the public interest and runs counter to the DPU’s stated goals of promoting safety, equity, and emissions reductions.

2) Acknowledge the change in circumstances and state law since the project was initially brought forth in 2015 and re-open the MEPA process, thereby ensuring that the rules put in place by the recently implemented Next Generation Climate Bill are applied to this project and an environmental impact report (EIR) of this proposal is conducted.

3) Conduct or support community members and municipal government in conducting a Community Health Impact Assessment (CHIA) so that the impact that this proposal will have on the already overburdened community of Peabody is understood.

4) If the results of the EIR or CHIA show that this project will harm the community and contribute to the climate crisis, stop this proposal from moving forward and, instead, direct MMWEC to replace it with a project that will reduce the burden on the communities of Peabody and Danvers.

5) Use this opportunity to explore how the Office of Energy and Environmental Affairs can most effectively support participating Municipal Light Plants in becoming leaders of the Commonwealth’s transition to a clean, just, renewable future.