TAKE ACTION: Tell FERC To Reject Coal and Gas Subsidies in New England
The New England electrical grid regulator (ISO-NE) just held its latest “forward capacity auction” sending hundreds of millions of dollars to keep dirty fossil fuel plants alive.
Now, we have until April 12th to send comments to FERC, the Federal Energy Regulatory Commission, opposing these results.
→ THE FORWARD CAPACITY AUCTION: EXPLAINED
Through a system called forward capacity payments (effectively, money paid years in advance for electric companies to be ready to operate), fossil fuel generators like the coal-fired Merrimack Generating Station receive subsidies from our electric bills. On average, 10-20% of our electric bills go to fossil fuel subsidies through this mechanism.
This February, ISO-NE (our regional energy grid operator) held an auction to determine future forward capacity payments. During this year’s auction, Merrimack Generating Station received payments to remain open through 2025. It’s time to show up for our community: we want to join together in demanding they end subsidies for fossil fuels in New England now.
Now, FERC (the Federal Energy Regulatory Commission) will review the auction results and take comments from people like us. You don’t need to be an energy or climate expert - write what you like, but keep in mind it is a public document and that folks working for FERC will review it.
→ WRITING YOUR COMMENT: TALKING POINTS
So, what should go in a public comment? It generally helps to have a short personal narrative, a key fact or two about the issue, a reminder about the context of climate change, and commonly-held values or motivations.
(It’s fine to emphasize one or some of these much more than others--actually, it’s good! Having plenty of people submit comments will make sure we cover all the important angles, so don’t worry about trying to say everything. You can lean into what compels you the most.)
Overall, 10-20% of our electric bills go to subsidies that support fossil fuel generators.
The ISO-NE is holding the purse strings - they should be using our ratepayer dollars to invest in New England’s collective future, not propping up dinosaur fossil fuel plants.
We are still burning coal in New England for electricity, and we are all paying for it: the Merrimack Generating Station in Bow, NH was allocated over 12 million in subsidies for 2024-2025 through this year’s forward capacity auction.
In one hour of operation, Merrimack Station releases greenhouse gas emissions equal to 26 years in the life of an average American.
Forward capacity payments to Merrimack Station keep coal on the grid “just in case it’s necessary,” enriching out-of-state hedge funds at a huge cost to ratepayers. Coal is not necessary: we have enough energy on the grid without it. New England has the highest reserve margin of any region in the country.
ISO-NE is tasked with maintaining the reliability of our electric grid, but fossil fuel infrastructure actually contributes to unreliability, since climate change brings more of the weather conditions that cause outages. For example, this Connecticut case study predicts power outage increases of 42%-64% by the end of the century due to increased heavy wind and precipitation.
Burning coal is a nonessential, immoral act that increases risk of respiratory illness and damages the planet.
The most vulnerable people in our communities, especially Indigenous, Black, and other people of color, are even more at risk from the pandemic, pollution, and economic injustice right now. So, whether we burn coal is a question of justice.
Without these fossil fuel subsidies, money could be directed to projects that increase long-term reliability and increase, rather than destroy, climate resilience: efficiency, conservation, low-income assistance, and renewable energy.
Watch us read the No Coal No Gas open letter to ISO-NE, at an action at their headquarters in Feburary. (Can’t see the video? Click here to watch.)
Here is No Coal No Gas’s official written statement.
→ SUBMITTING A COMMENT: THE PROCESS
Getting a comment to FERC has more steps than we wish it did, because government bureaucracy isn’t made for ordinary people to navigate. But we’ve laid it all out below to make things as easy as possible!
(One note before you start--the website will log you out automatically after 30 minutes. Your comment also has to be attached as a file, such as a .PDF, .DOCX, .RTF, .JPG, or .PNG. So, save yourself the headache and put your comment together first! If you’re still looking for help on what to say, go back to the talking points.)
1. Comments on the ISO-NE’s auction results are submitted through FERC Online - eFiling. Going to this link will ask you to log in. Unless you’ve previously made a FERC account, press the New User link to register. You can also register by going directly to FERC Online - eRegistration.
2. In order to use eFiling, you will need to verify your account with a link sent to your email and continue the registration form, which will ask for your address as well as some other optional information. Skip the fields that ask about your employer and organization, since you will be commenting as a private citizen.
3. Once your account is fully set up and you are logged in, you can select eFiling. Make sure you do NOT select eComment instead. The eComment portal will not accept the docket number for the ISO auction results.
4. At this point, you can complete the later registration steps if you skipped them earlier! Then, you will need to select the filing type. Click “General,” then “Comment (on Filing, Environ. Report, or Tech Conf.)” Don’t worry about the “Filing Type (Fee)” column - there will not be a fee to comment!
5. On the next page, enter the docket number, ER21-1226, into the search. Press the blue plus sign to select it.
6. Finally, you’ve reached the screen where you can upload your comment. If you’d like to add additional files to support your comment, such as art, you can do that too. Here’s FERC’s full list of file formats you can attach, also linked on the upload page.
7. Once you’ve uploaded your file(s) and made any changes to the order and descriptions, you will be asked to specify the filing parties. Change from the default selection to mark “as an individual,” then click next.
8. On the next page, enter your email again and press “add as signer,” then “next.”
9. Accept the default description that auto-fills when this page loads and hit next
10. On the next page, hit submit.
11. A successfully submitted comment looks like this:
12. You should get an email confirmation that your comment was submitted- check to make sure you received it!
Questions about this process? Feel free to reach out to Marla at marla@climatedisobedience.org.
→ EXAMPLE COMMENT
Dear FERC,
Every hour that the Merrimack Generating Station burns coal, it releases greenhouse gas emissions equal to 26 years of life by an average American. That’s not much longer than I have been alive-- and in JUST ONE HOUR of operation. The plant itself has been around since 1960. It’s hard to imagine just how much GHG emissions have come out of this plant, but it’s even harder to imagine that it’s regulator, ISO-NE, has funded it until at least 2025. I’m writing to appeal the results of the 2021 Forward Capacity Auction-- this plant needs to be shut down. Every other plant in the region has been shut down, but this beast is still belching noxious gasses into neighborhoods and ecosystems along the Merrimack River.
At the recent Environmental Advocacy Group meeting for the ISO, we were told that for native energy generation in 2019, coal was down ~60%. In 2020, coal was down ~66.7% from that. Still, despite this incredibly sharp decline, the coal plant is still going to be funded for the next four years. I understand that shutting down coal plants is expensive--if my math is right for Merrimack it’d cost at least $10,122,000--but that’s negligible to the costs of continuing to burn coal. (Based on numbers from Decommissioning US Power Plants, a 2017 study by Resources for the Future.)
Knowing that we should have abandoned coal decades ago, myself and many others have been working to shut the station down. We’ve put fear aside, and removed coal, blocked trains carrying it, and refused to pay subsidies for it. Meanwhile, the ISO appears too afraid of the cost of shutting the plant down to do anything about the fact this plant is killing, and will continue to kill, people.
Each train that brings another 10,000 tons of coal to the plant can cause untold pain. Stopping those behemoth trains meant easing suffering, even if momentary--maybe a child will have one less asthma attack, or maybe a grandmother won’t get cancer… maybe the hurricanes will come just a little more gently. You can overcome the fear of a three quarters of a mile-long train charging at you when you realize the consequences of letting that train pass through. Stopping this coal from burning means stopping the inertia that we find the fossil fuel industry in, but we need the help of regulators to finish the job.
Folks at FERC have sifted through many comments from young people pleading for our future--for the regulators to shut down fossil fuel projects. We are so often told that we make our elders hopeful, and that we’re speaking truth to power. I don't do this work because I am deluded by hope--I don't believe I will see some triumphant moment where we "win" and suffering and oppression are cancelled. I do this because I can ease just a little of the suffering; that's the burden I can carry, and I invite you to help us carry it. The one thing that can give me hope that we might make it out of this crisis would be for those in power to join us in reshaping the way we use energy. That has to include ending the use of coal.