To provide the best possible analysis of Central Maine Power’s plan, Acadia Center engaged a technical consultant via GridLab to write a report identifying areas for improvement. These comments incorporate the consultant’s findings and reflect the joint positions of Acadia Center, the Natural Resources Council of Maine, the Conservation Law Foundation, and the Union of Concerned Scientists.
The coalition identifies several deficiencies in the utilities’ development of the plans, as following:
1) the Environmental, Equity, and Environmental Justice (EEEJ) assessments;
2) deficient use of the Commission-approved scorecard;
3) insufficient analysis of Ambient Adjusted Ratings;
4) failure to propose an adequate assessment framework; and
5) the limited selection of battery storage and load management as preferred solutions.
The coalition also identifies several areas for improvement in the next planning process:
1) improvements to the EEEJ assessment to include more meaningful, quantitative metrics;
2) improvements to the NWA process;
3) establishment of a standardized solutions library;
4) greater engagement from the Commission during the 18-month planning period;
5) improving access to information and data through the Case Management System (CMS);
6) more strategic use of technical working groups; and
7) disadvised use of “no regrets” terminology.