Shumlin’s Comprehensive Energy Plan

by Meredith Angwin

Shortly after Governor Shumlin took office, he said he was very surprised to see that the State Energy Plan included Vermont Yankee operating past March 2012, operating “beyond its design date.” He claimed “my team (is) frankly scrambling to put together a shutdown plan that should have been designed over the years…we have grid challenges, we have challenges in rates….”

Shumlin, an opponent of the Vermont Yankee plant, did not change his opinion of “design date” after the NRC extended Vermont Yankee’s federal license until 2032. Instead, he and his team put together a plan for Vermont without Vermont Yankee, the Comprehensive Energy Plan (CEP). The plan was written under the auspices of the Department of Public Service (DPS) and is now going through the public comment process.

The CEP was released on September 14, and the public comment period ends on October 10, less than a month later. The CEP covers electricity, heating, transmission, and transportation. It is over 600 pages long, including the appendices. The main volume is 368 pages. Less than a month does not give the public much time to review the documents.

What is a Plan?

The CEP includes ambitious renewable goals, but little actual planning. Among other things, it doesn’t address the issue of electricity supply without Vermont Yankee in a straightforward fashion. For example, in the summary document,(volume 1 on the Energy Plan page) the electricity section (pages 7 through 9) includes expansion of the standard offer program for renewable energy, and hiring a new “renewable energy project development director” for DPS. The electricity section does not mention natural gas, and it does not acknowledge any gap in the electricity supply.

However, the home heating section, does note that there might be an electricity supply gap. On page 11, the home heating section encourages the expansion of a gas pipeline into Vermont because “Natural gas can address two key needs: reduce Vermonter’s reliance on overseas oil for heating….and help fill a gap in electric supply.”

The CEP contains goals such as “90% of our energy needs by renewable sources by 2050.” (page 3 of summary document). There are no numbers or dates for future construction of wind energy, for example: nothing like this much wind energy by this date. The CEP does contain a solid recapitulation of Vermont’s historic energy demand and supply sources. However, that is not the same as a forward-looking plan.

The Institute for Energy and the Environment of Vermont Law School(VLS) announced that they had extensive input on the CEP.

The Law School input is clear in the CEP. It contains historical data, many things to consider in choosing energy sources, and a great deal about “process” and “stakeholders.” However, the CEP is not what an engineer would call a plan.


Despite its major lack of content, the plan has come under fire from VPIRG (Vermont Public Interest Research Group). Shay Totten, of Seven Days, blogged about VPIRG’s early criticism of the plan. VPIRG felt the plan did not move far enough and fast enough about renewables.

According to Totten, Ben Walsh of VPIRG did some quick calculations about renewable goals, and fired off an email titled “Really? This is what we waited for?” Walsh pointed out that Vermont utilities added 1.6 percent new renewables under Governor Douglas, and, calculating back from the goals, the CEP calls for only 1.1 percent new renewables per year.

Four hours after Walsh sent the email, his boss, James Moore of VPIRG, apologized in another email: “We are thrilled to have a comprehensive energy plan that shows real vision for where this state can and should go.” However, Moore noted that “There are parts of the plan that we feel are weak, like the renewable energy requirements.”

Shay Totten has some interesting comments on what this exchange means in terms of the usually cozy relationships between Governor Shumlin and VPIRG. It is worth reading his entire blog post.

However, the controversy between VPIRG and the State has continued. The Rutland Herald reported today that James Moore of VPIRG criticized the renewable energy plan even more strongly, claiming that the administration target puts renewable energy growth in Vermont on a slower annual pace than it is on now.

Elizabeth Miller, the DPS Commissioner, said she wasn’t sure how VPIRG calculated this renewable energy target (number). Having more long-term goals than actual numbers led to this controversy.

Examining a Plan Goal

It is worth looking at an example of plan goals.  A chart on page 14 of the plan shows the plans for Greenhouse Gas emissions for the future in Vermont. The level of greenhouse gases produced from the electricity sector is shown as rising rapidly after 2012, presumably after Vermont Yankee closes.

The CEP states it does not take a stand on Vermont Yankee Page 150 of Volume two says: “This plan will not take a position on whether VY should continue to operate; that is the role of state laws and processes and is the subject of the pending lawsuit.” However, since the impetus of writing the plan was to have an energy plan without Vermont Yankee in the mix, this statement is a bit disingenuous.

Looking at the greenhouse gas chart again, we also note that projections for lowering greenhouse emissions are (at minimum) aggressive, and probably unworkable.It is a chart of goals, not a plan.

A Way to Comment

There are still nine days left to send input to the DPS on the CEP. Though the plan itself is quite long, the summary document is only 19 pages, and can be reviewed rapidly. The public comment page

or the email address are probably the best ways to comment, though there are public meetings on October 3 and October 6, also.

The CEP approval process is moving forward rapidly. The length of the CEP documents and the shortness of the comment period are somewhat intimidating. Still, it is possible to comment, and citizens interested in Vermont’s energy future should do so. Perhaps pick only one topic, and comment on that. As citizens, we have an obligation to have our voice heard.

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