Acadia Center Submits Comments on Versant’s Proposed EEEJ Methodology and Recommended IGP Solutions

Acadia Center Comments on Versant’s EEEJ Considerations and Potential IGP Solutions

Specific comments include:

Tracking and Analysis of EEEJ Benefits

• Any evaluation of environmental justice impacts should involve a continuing dialogue with affected EJ communities, to ensure that the most important impacts – both positive and negative – are being captured in the metrics that Versant uses
• Versant should include a more comprehensive cost and benefits analysis in its alternatives evaluation to ensure the most valuable solution serving the most disadvantaged customers can be clearly identified.
• Versant should weave the EEEJ assessment tools throughout the other scorecard evaluations that Versant intends to perform such that there is a complete accounting of EEEJ considerations throughout the IGP solutions alternatives analysis.

Integrated Grid Plan Solutions Recommendations

• Acadia Center strongly supports the robust evaluation of non-wires alternatives (NWAs), including grid-enhancing technologies (GETs), in the solution sets that Versant evaluates
• Acadia Center also recommends that, when Versant evaluates NWA solutions, that those solutions not be evaluated in isolation, with each technology analyzed on its own, but rather in solution sets of multiple NWAs, as research has found that the concurrent deployment of multiple GETs can improve substantially over their individual effectiveness.