On Sept. 11, 2015 Jones River Watershed Association submitted comments to the state’s Executive Office of Energy and Environmental Affairs (EOEEA) regarding a recent Environmental Notification Form and Waiver Request from NRG. NRG is the company that owns the Canal Generating Station (CGS) on the Cape Cod Canal.

CGS is a fossil fuel electrical generation facility (oil/gas), currently with 2 units. It stopped operating on a regular basis around 2009. It went totally dormant from 2009-2010 due to financial reasons. It’s now part of what’s called the “capacity market,” and will be until at least 2018. In other words, CGS receives capacity payments just for being there to run when the grid calls on them (during times of high electricity demand – e.g., heat waves, cold snaps).

On July 31, 2015 NRG submitted an Environmental Notification Form and Waiver Request to EOEEA. The waiver request is for a “Community Solar Project” and the Environmental Notification Form is for the construction and operation of a dual-fueled, simple-cycle electric generating facility (“Canal Unit 3”).

Here’s an excerpt from our comments letter:

“JRWA is keenly aware of climate change and the impending impacts that it brings. We encourage renewable energy systems especially when they have no or expressly limited impacts on sensitive ecosystems and habitats. JRWA has no objection to the issuance of a waiver for the community solar aspect of the Canal project, and consider that the local permitting and regulatory authorities can manage any questions and secure any needed considerations.

We expect that the Canal Unit 3 will provide a Draft and, at least, a Final EIR; and we would expect to be able to review and comment on those documents, including any supplemental information. We are especially interested in water consumption, discharges, and impacts on the marine environment as well as regional air quality as it relates to burning of fossil fuels, in this case.

We understand that Canal 3 is designed to operate as a peak energy facility and may run as much as half of the year, with ULSD fuel oil being used half of that time, depending on the availability of natural gas via the Algonquin pipeline. We continue to have questions regarding the operation of Canal Electric and its relationship to the operations of Pilgrim Nuclear, and especially the relationship between Units 1, 2 and the new Unit 3. That is, when Pilgrim is off-line, or decommissioned, how will the operations of the Canal facility be effected? Is it possible that Canal 1, 2, and 3 would operate beyond the current practices and expectations? This relationship (to Pilgrim and the changing demands for distributed power) should be explicitly addressed in the EIR. JRWA is concerned that further downgrading at Pilgrim will take the facility off-line and could result in increased use at Canal 1& 2 and negatively impact Cape Cod Bay.”

It is important to us to keep an eye on the big picture and ensure we don’t trade one environmentally detrimental energy source for another. We will continue to monitor NRG’s Canal Generating Plant to ensure Cape Cod Bay is protected now and in the future.

Read JRWA’s full comment letter here →