Remarks made by Steve Levesque at PUC Public Witness Hearing on CMP Rate Case proposal on 4/2/14
The Midcoast Regional Redevelopment Authority (MRRA) is a public municipal corporation created by Maine statute (18-A M.R.S.A. §13083-G) with the responsibility to effect the redevelopment of the former base to re-establish the economic footprint of the former military installation and create new jobs for Maine.
MRRA is a customer of CMP and is therefore substantially and directly affected by CMP’s proposal revenue requirement, rate design and rate plan proposals.
MRRA is also directly affected because its facility was designed and built as an integrated development to serve the national defense, supplying many if not all of its own vital services. Retaining that integrated character is key to the economics of the redevelopment, as the Legislature acknowledged when placing the entire property under the control of MRRA.
A major focus of the Reuse Master Plan of the former Navy base is the establishment of a renewable energy center to be a national center of excellence for the generation, distribution and management of renewable energy as part of a sustainable development grid “behind the meter”. The feasibility and effectiveness of this initiative would be substantially affected by CMP’s proposal regarding standby rates.
It is our belief that CMP’s current and now proposed new rate structure inhibits and even penalizes the economic re-purposing of the former Naval Air Station and job creation opportunities in Maine. When the Navy was operating the Air Station, they were charged a T&D rate at the Sub-transmission level. However, when MRRA took over the property is charged at large general service, primary time of use, which is substantially higher. We have to pass these additional costs on to our tenants. CMP has refused to assist MRRA in marketing the former base properties, however, it benefits greatly from new development activity occurring there. We also believe that we have been further penalized with a higher T&D rate as a result of our request for intervener status in this case.
MRRA is actively working with its first renewable energy partner, Village Green Ventures (VGV) on the proposed development of a project to construct an anaerobic digester and associated renewable generation facility at Brunswick Landing. The proposed facility will be capable of generating a large portion of the electrical requirements of MRRA and its tenants at Brunswick Landing on a “behind-the-meter” basis. MRRA and its tenants would therefore be substantially and directly affected by CMP’s proposal regarding standby rates.
One of the most significant challenges to attracting and growing businesses in Maine is the very high cost of bringing electricity to our business customers. Accordingly, Maine is not competitive with most other states, especially those in the south. At Brunswick Landing, we can overcome this challenge by generating some our needed power on campus and providing it to our new customers at a reduced cost. An additional surcharge would negate this benefit and make it that much harder to attract new business investment.
It would seem that CMP would welcome some locally distributed power generation, as it would reduce the burdens on an already stressed system. This is a real problem in the Brunswick area, where we experience a multitude of regular outages. This issue is of major concern to our existing businesses and we’ve had to come up with solutions to provide them with back-up options to ensure more reliable service.
Finally, the proposed rate case seems to be counter to federal and State of Maine policies encouraging the application of alternative energy technologies and distributed energy development.