#retireMcNeil These comments were submitted to the Regional Greenhouse Gas Initiative’s (RGGI) Third Program Review. Learn about RGGI, and submit your own comments at: https://www.rggi.org/program-overview-and-design/program-review Peter K. Duval Underhill, VT November 1, 2023 RGGI Program Review Comments Thank you for the opportunity to comment on elements of the Regional Greenhouse Gas Initiative’s (RGGI) Model Rule as part of the Third Program Review. I am a concerned Vermont resident and a former project analyst for an independent energy developer. I participated in the Vermont Public Service Board’s (now Public Utility Commission) Docket 5611, an investigation into environmental externalities. In 1992, I developed a proposal for a low-temperature district heating system for Burlington, VT, based on heat taken at the cooling tower of McNeil Generating Station. I support Partnership for Policy Integrity’s (PFPI) January 2022 comments. (1) The distortions in the c...

As Published in Seven Days, October 18, 2023 : Studied to Death The "simmering" subtitle of " Pipe Dream? " [September 27] suggests that the Burlington Electric Department has been working on its scheme to build a steam pipe to the hospital for a long time. Coming just three years after Corix's quite different proposal failed, this Burlington Electric/Vermont Gas Systems/Ever-Green Energy effort should meet the same fate as other attempts to cobble together a thermal project based on the McNeil Generating Station. Prior to the current proposal, there were at least 14 studies related to thermal project proposals for the McNeil site, ranging from greenhouses to steam transmission lines to various district energy system configurations, all of which led to "no go." I know because, with Dermot McGuigan, I wrote one of those reports, the 1992 proposal for a low-temperature, citywide district energy system — the right project at the right time. But the time f...

The proposed steam transmission line between the McNeil Generating Station and the University of Vermont Medical Center (an organization and facility that is distinct from the University) is a train wreck of a project. We could anticipate its 2023 crash from way back in 1984, or 1994, or 2004, or 2014. It may not even be necessary to know or understand the three essential elements of a good district system to judge the proposed steam pipe project. Consider the long history of studies and reports, all of which have resulted in "No Go" outcomes. And then add the fact that Burlington Electric Department, the operator of McNeil on behalf of 9 other Vermont utilities, has lost track of most of those studies. That kind of knowledge management does not inspire confidence. BED is only able to find 4 of 14 historical thermal project studies related to McNeil. There should be several more studies published since 2018, as BED has been spending money liberally in support of the project -...

There is a proposal being pushed by Burlington Electric Department (BED) to connect a steam transmission line between the J.C. McNeil Generating Station and the hospital. It's not good. Indeed, it's an idea that should have been stopped early at an internal BED meeting after about 10 minutes of discussion. In 1992, Dermot McGuigan and I developed a project proposal to serve Burlington with low-temperature district heat that would have taken heat from the cooling water at the McNeil Generating Station. It was a project for its time and the future, which is now here.  In 2023, district energy system supply temperatures in new systems are so low that uninsulated pipes can be used. (Lund, et.al., 2014,  https://doi.org/10.1016/j.energy.2014.02.089 ) created a widely reproduced graphic that illustrates the long-running temperature trend in district energy systems (also called district heating and cooling). The notion of using steam in a new system today is unfathomable. (Lund, et.a...

 My public comments ( PDF ) entered in Case No. 23-1870-PET : July 3, 2023  Vermont Public Utility Commission  Case No. 23-1870-PET  Dear Commissioners,  Thank you for the opportunity to comment on Case No. [ 2 ]23-1870-PET, as requested by the Commission’s Procedural Order of June 9, 2023.  Some time ago, I participated in the Public Service Board’s Docket #5611, an investigation into environmental externalities. There is one memory that I would like to share with you:  The investigation lasted many months and involve[d] utilities, environmental groups, and of course, the Department of Public Service (PSD, then DPS). Beginning in September 1992, Docket #5611 was a series of workshops on the general problem of environmental externalities and included greenhouse gas regulation. It was a thorough investigation using the best available information from the best universities and think tanks. I’ve lost track of the number of day-long meetings we had. It was...

 As Published on VTDigger, May 4, 2023 : Gish, Duval & Adams: Affordable Heat Act is not the climate action we need May 4, 2023, 7:07 am This commentary is by Chris Gish, Peter Duval and Ashley Adams. Duval lives in Underhill and participated in a Vermont Public Service Board investigation of environmental externalities. Adams, a business owner, lives in Burlington. Gish, a farmworker, lives in Burlington and organizes with Stop VT Biomass. The  Affordadable Heat Act,  S.5, would be a major step back for climate action in Vermont. The core of the bill was developed in closed-door meetings by some of Vermont’s biggest polluters, bypassing grassroots environmental groups and the Climate Council. It heavily favors biofuels that would push Vermont further from its climate goals.  As S.5 has advanced to the governor’s desk — likely to be vetoed and returned to the Legislature for further debate and a veto override attempt — more than 30 organizations and 230 individua...

  November 8, 2022 Election Results:  Governor Scott, congratulations on another victory.  Voters, thank you for voting and casting 4714 votes for me and the campaign that emphasizes an Earth perspective on issues. Voting is just the beginning. With hybrid meetings and online meeting packets, it is easier than ever to find an issue, research it, and track it through the political process.  Let me know, through the Take Action or Contact page, what issues interest you.