Collectively, the Deep South Center for Environmental Justice, Sierra Club, 350 Louisiana-New Orleans, and the Alliance for Affordable Energy presented arguments in opposition to Entergy’s request to build a gas power plant in New Orleans East.
Our testimony, filed today, came to the same conclusion that many community members did over a year ago: We don’t need this expensive, old-fashioned gas power plant, and we shouldn’t have to pay for it for the next three decades.
Testimony came from local and national experts on issues ranging from energy economics, engineering, environmental justice, health, geology, and regulatory policy. Together, the Public Interest Intervenors’ ten points make a case to urge City Council not to burden New Orleans with the costs and impacts of this plant.
1) ENO’s reliability problems largely stem from its dysfunctional distribution system, which cannot be fixed by a new power plant. ENO customers suffered 2,242 power outages in the first 8 months 2016 alone–an average of 9 outages per day— none of which were caused by unplanned power plant outages or other shortages of capacity. Capacity surpluses can never serve customers if the poles and wires are in such disrepair that they frequently fail to deliver electricity.
2) ENO concedes that making transmission upgrades to five existing transmission lines will mitigate all reliability-based system constraints over the next ten years without building any new generation. These transmission upgrades are estimated to cost approximately $57.3 million, which is significantly less than the $232 million cost of the proposed CT plant and the $210 million cost of the alternative peaker plant.
3) Neither proposal by ENO will protect the citizens of New Orleans from outages due to major weather events such as hurricanes.
4) ENO has inflated its peak capacity forecast, making unrealistic assumptions about energy efficiency and renewables in New Orleans, so that it can argue that there is a capacity need to spend more $232 million on the plant, when the City may actually have a long-term capacity surplus.
5) ENO is recommending that the City Council base its decision on the unwarranted assumption that capacity prices in the MISO market will skyrocket and remain high for much of the 20-year analysis period. This is a risky bet that exposes ratepayers to higher costs in the likelier event that capacity prices will remain low.
6) The ground in New Orleans is naturally prone to subsidence, any human driven activity that causes subsidence will intensify a problem already known to exist. Subsidence in this instance is particularly alarming because the subsidence will occur very close to the newly-strengthened post-Katrina levees system that protects New Orleans East, Lower 9th Ward, and other nearby communities.
7) Either proposed plant would significantly increase air pollution, causing increased numbers of asthma, heart attacks, more frequent emergency room visits, lost school and work days, and increased numbers of deaths.
8) False statements by ENO have denied an environmental assessment of its industrial impact on the health, safety, environment, and quality of life predominantly African American and Vietnamese Americans families whose homes and schools are nearby the Michoud site, the location of ENO’s proposed gas power plant.
9) ENO failed to rigorously analyze alternative resource options such as energy efficiency, and solar PV. ENO failed to conduct a competitive solicitation process in choosing to pursue its proprietary build gas plant proposals as its preferred option to meet the City’s capacity and reliability needs.
10) The public record shows troubling indications of ENO’s long-term plan for building a gas plant, and the City Council’s consultants willing support, dating several years prior to complete, public review of ENO’s application and the need, costs, and benefits of building such a proposal. This raises concerns about the fairness of this proceeding and the assurance of due process.
A competitive solicitation should be issued for New Orleans capacity needs and its bids received and thoroughly reviewed. The Council is expected to make a decision in February following more testimony from their advisors, Entergy, and an evidentiary hearing scheduled for December. Follow our website for continued updates.
