2017 Draft Comprehensive Energy Strategy

Endorse the Roundtable's Comment re Offshore Wind in the draft CES

In June 2016, more than 150 people from across CT endorsed the Roundtable's statement urging that CT's new energy strategy be aligned with its climate commitments.  Now that the draft has finally been released, we have an opportunity to speak up and ensure that the final document represents a bold vision for the clean energy future we need.

CT's new draft Comprehensive Energy Strategy (CES) was released at the end of July, and the Department of Energy and Environmental Protection (DEEP) is accepting public comments until September 25th at 4:00pm.

We have set up this webpage as a place to collect resources and talking points to facilitate the active engagement of CT residents in the public comment process.

If you have something to suggest adding to this page, send it to john@ctclimateandjobs.org

Background Resources

Public Comments

  • Submit written comments by September 25, 2017 @4pm
    • email to: DEEP.EnergyBureau@ct.gov
    • snail mail to: Debra Morrell, DEEP - Bureau of Energy and Technology Policy, Ten Franklin Square, New Britain, CT 06051
    • Connecticut Fund for the Environment has created this handy online portal with suggested talking points to craft and submit your written comments.
  • Provide oral comments at one of the 4 remaining public hearings (details/directions here)
    • 8/21, 6:30 p.m., Fort Trumbull State Park Conference Center in New London
    • 8/29, 6:30 p.m., Torrington City Hall in Torrington
    • 9/6, 4:00 p.m., DEEP’s Hartford Office
    • 9/7, 6:30 p.m, the Connecticut Agricultural Experiment Station (CAES) in New Haven
  • Review written comments already submitted here

Talking Points

  • This coalition letter includes some additional talking points.
  • The draft CES provides no assessment of overall impact on greenhouse gas (GHG) emissions; we need to know whether the proposed set of strategies are deemed sufficient to put CT squarely on the path to achieving the mandated goal of a 10% reduction in emissions below 1990 levels by 2020. (see the Roundtable's initial press release)
  • A proposed cap on "behind-the-meter" solar installations (20 MW annual cap) would impose an 80% cut in 2021, compared to 2016 installations, which were greater than 90 MW (see Acadia Center's analysis)
  • The proposed extension of the Renewable Portfolio Standards (RPS) to 30% by 2030 -- representing 1% growth in the decade 2021-2030-- actually slows the pace of expanding renewables from the current rate of 1.5% annual growth. This coalition fact sheet from last spring presents a strong argument for expanding the RPS to 50% by 2030.  Expanding our commitment to in-state renewables will create more jobs in CT.
  • The draft CES contains an inadequate treatment of offshore wind development, including the unsubstantiated statement pasted below; with neighboring states moving ahead with aggressive procurement of offshore wind resources being developed in federal waters south of RI and MA, the CES should include a serious analysis of the potential role of offshore wind in meeting energy needs while providing in-state jobs and economic development. (Register now for our upcoming labor forum on offshore wind.)

Much of the wind potential is offshore, which is likely very expensive, or is in northern New England in areas that do not have adequate transmission facilities to move the power to load centers in southern New England. (p 15)

  • Indequate ramp-up of energy efficiency programs to match the achievements of other states in the region; the draft CES essentially lays out a "steady as she goes" approach, rather than embracing a rapid expansion of our efficiency programs as the best and most cost-effective way to achieving our emissions reduction targets.  Other states in the region, notably MA and RI, are achieving much higher rates of demand reduction through their energy efficiency programs, and CT should establish higher targets that draw upon lessons learned in those states. (See the section on Efficiency on pages 5 and 6 in this letter from Acadia Center.)  CT's energy efficiency sector accounts for an estimated 34,000 jobs - jobs that cannot be outsourced  - because the buildings are located here!
  • Speed up the adoption of electric vehicles (EVs) - With transportation responsible for nearly 40% of the state's GHG emissions, CT has committed to having 154,000 EVs on the road by 2025.  To achieve that target, the CES needs to establish a much stronger incentive program and commit to adding more charging stations.
  • Statewide shared solar program - With the selection of projects for the small pilot program finally completed this past spring, the CES needs to provide a clear roadmap to developing a full-scale shared solar program (more info here).
  • New Conservation Charge proposed for oil and propane heat customers - The draft CES recommends implementation of a new charge for oil and propane heat customers like the small monthly fee paid by electric and natural gas customers to support the state's energy efficiency programs. This is a sensible step toward ensuring that all residents have equitable access to adequately funded efficiency programs, regardless of fuel source. This change would expand funding for energy efficiency, strengthening the growth of CT's green jobs economy.