Let’s Work Towards Sustainable Energy in 2021:Project 2015A is a Bad Idea

Submitted by Jerry Halberstadt on Thu, 12/09/2021 - 02:38

December 3, 2021

To: Mayor Ted Bettencourt, Peabody City Hall, Peabody 01960. By email

Dear Ted,

I look forward to meeting with you to discuss ways for Peabody to build a campaign for sustainable energy. We can seek funding from the Commonwealth and the Federal government to develop a model program that embraces all citizens, all City departments as well as the City Council, and the Peabody Municipal Light Plant.  Going forward, Peabody can develop community-wide programs to address the need for sustainable energy solutions, while renewing and strengthening the city. [You may wish to review the material I shared with you in 2012 for some basic concepts: Reducing energy costs in Peabody: A strategy for revitalization in 2012] [At the time of writing, I had not been aware of the Net Zero plan involving the Metropolitan Area Planning Council, PMLP, and the Peabody Department of Community Development.]

I [have shared] this letter with the Hull Municipal Light Plant to help inform their decision on the peaker plant.

If Peabody residents had been given timely information and the possibility for expressing their opinions, there would have been massive opposition.  As reported by Tracy Valletti,

“It turns out that Peabody residents are almost unanimous in their opposition to this gas plant, and they know that building it would represent a huge step backwards for our community.”

Peabody is a proud community that, working together, can move quickly and far, by learning from the work done in Hull, on the South Shore, and in the Berkshires.  Innovations abound—in Plymouth, the town provides free charging stations for electric vehicles, encouraging tourism.

The issues are:

How can leaders of Peabody, elected officials, faith leaders, and others with prominence in the community justify the negative impacts on health, the environment, and the climate from the proposed peaker plant?

There is no valid justification. People across the Commonwealth are protesting the peaker plant. They cannot justify getting their electricity at the cost of the health of residents of Peabody and surrounding towns. Adrienne Allen, MD, MPH quotes what area patients who have health conditions caused or exacerbated by pollution say to her—

"I am short of breath, I can't walk."

We don’t have data on the emissions of the current plants because there are no nearby air quality monitoring stations, and there is no serious enforcement because of outdated laws, as reported by ProPublica. We must rely on established correlations between particulate emissions, for example, and rates of disease and death due to lung disease.

“According to Francesca Dominici, a biostatistician at the Harvard T. H. Chan School of Public Health in Boston, Massachusetts, there is no amount of fine particulate matter [PM 2.5] that is safe to breathe because it is known to penetrate deep into the smallest crevices of the lungs and enter the bloodstream.”

Reviewing the response to my freedom of information request to the City of Peabody, I was struck by the lack of concern about the plant. Officials asked,

“Do we have to do anything?” and seemingly were relieved to hear, “No.”

Everyone looked the other way, except for the Peabody Health Department, which spoke out to seek proper evaluations of the health and environmental impacts. Peabody Board of Health Seeks Health & Environmental Review of Peaker Plant.

State Senator Joan B. Lovely and Representative Sally Kerans joined with demonstrators protesting the lack of transparency and the health impacts of the plant which have not been evaluated. Activists in Peabody cannot justify the plant, and strongly oppose it because, among other bad effects, it will lead to more frequent flooding of the homes of our friends in Hull. There can be no justification for continuing to burn fossil fuels, because by so doing, we are hastening terrible conditions that will engulf our children and grandchildren. Burning fossil fuels poses a threat to public health, with WHO’s report stating that

“the burning of fossil fuels is killing us. Climate change is the single biggest health threat facing humanity.” —Shirin Ali

Traditional economics and accounting have dealt with financial profit and loss, and ignored other issues as “externalities.” Perhaps external to the books of account, but not external to people. Just consider the costly impacts on health, the environment, and global warming. Can agencies of the Commonwealth, including the municipal light plants and MMWEC truly serve the public interest if their only measure of success is maintaining cheap rates and reliable service? And when we have the technology at hand that can provide reliable power at an equal or lower lifetime cost, without the downside threat of stranded asset status, can we justify building another fossil fuel plant? And have we considered how much risk is involved—surely a prudent investor would not put money into yet another fossil fuel plant.

Do we need 2015A to meet capacity obligations?

No, we don’t need 2015A—capacity can be purchased from ISO-NE at reasonable cost for the next decade, as projected by MMWEC in their presentation to Peabody in April.  PMLP can purchase  capacity power from renewable sources. MMWEC could use battery storage, either distributed, or at another MMWEC member site with sufficient area.

Can we decrease our use of fossil fuel, and increase our use of renewables?  Can we reduce our use of power overall, and especially during times of peak demand?

There are a number of effective strategies to reduce power, including peak capacity power. These generally depend on the municipal plant providing technical and financial resources and coordination among all parties in the municipality: city agencies and buildings, factories, offices, and homes.

Will 2015A reduce capacity costs, act as a buffer against volatility, and provide a net profit that will reduce ratepayer charges?

Solar, wind, and battery storage systems are  winning capacity auctions  in ISO-NE. Lifetime renewable plus battery storage costs, including depreciation, upkeep, and operating costs as well as capital costs are declining below the costs of fossil generation. Investors have started to delay or abandon plans for gas-fired plants because the economics no longer favor them.

“Low gas prices and high-capacity payments that helped drive a near-doubling of installed combined cycle gas capacity in the last decade have gone away,” said Dennis Wamsted, IEEFA energy analyst.

Is the investment in 2015A a secure bet, or is it likely to end in a significant loss to ratepayers when the plant, as is likely, becomes a stranded asset?

Setting aside health and environmental issues which may put pressure for new legislation to limit the use of fossil fuels, the steadily dropping costs of capacity based on renewables will render the cost of power from project 2015A unmarketable

Is the contract between MMWEC and Peabody iron-clad, or could it be broken on the basis that the premises and outlook provided by MMWEC are invalid because inaccurate and false?

This needs review by an attorney.

A prudent investment? Is Project 2015A a good way to save money for use to develop renewable options?

Recently, PMLP agreed to guarantee $10 million for MMWEC to start work on the project. Why wouldn’t PMLP have directly applied that money to developing renewables and helping to reduce peak demand? For example, to assist the city, factories, business, and homeowners to install solar electric on rooftops along with battery storage that can be applied to meet capacity requirements.

The MMWEC bonds for the peaker plant are explained in a bonds rating document from Fitch. The Fitch report asserts that the ratepayers will have to pay for this project regardless if it works or fails. However, we know that ratepayers were not given timely and fair information nor the opportunity to object effectively. This is surely a form of taxation without representation. There has been no serious due diligence that would have protected the ratepayers. I have reviewed some of the financial projections of MMWEC comparing the use of battery storage with a gas-fired generator; the data on batteries is not accurate. None of the risks and downsides that would lead to the plant becoming a stranded asset have been considered. Many of the alleged benefits of the project are not valid.

According to the Fitch report, the major basis for the rating is the credit rating of PMLP. Not considered by MMWEC, PMLP, or Fitch: the cost to the average ratepayer in Peabody, in the event that the plant becomes a stranded asset, will be on the order of $3,000. The social costs from burning carbon would be $5 million annually, much of that in terms of health care costs, sickness, and death. According to the Fitch document, there is no agency that can intervene or interfere. But we, as citizens, are speaking out against this harmful project. I appeal to our elected state and local leaders to speak out against the project, and use their leadership positions to stop this project before it does irreparable damage to their constituents. The Commissioners of the Peabody Municipal Light Plant should cancel their participation in this poorly-conceived project.

Going forward, Peabody can seek state and federal support for innovative, community-wide programs to address the need for sustainable energy solutions, while renewing and strengthening the city.

Thank you for your consideration,


Jerry Halberstadt—Member of Breathe Clean North Shore, Coordinator of CleanPowerCoalition.org

Tracy Valletti—Tracy M. Valletti, MS, is the Owner/Managing Partner Northeast Care Management and Consultants, LLC; was a Candidate for Peabody Municipal Light Plant Commissioner; and Member, Breathe Clean North Shore.

Susan Smoller—Member, Breathe Clean North Shore

Ron Smoller—Member, Breathe Clean North Shore

Judith Black—founding member of  Sustainable Marblehead

For additional detail and background, please see:

Strategen Consulting, Assessment of Potential Energy Storage Alternatives for Project 2015A in Peabody, Massachusetts, Clean Energy Group, Massachusetts Climate Action Network, July, 2021


Blackout of Common Sense, (Part 1)

Blackout of Common Sense (Part 2)

Let’s Renew the Peabody Municipal Light Plant Partnership with Peabody

Tracy Valletti wrote,

“I am completely against building a fossil fuel power plant. Burning fossil fuels is dangerous to our health and environment and people who live in the area have an increased risk of respiratory illnesses. This project is moving us backwards in terms of global climate initiatives. Frankly, I’m surprised this was approved not only because of the obvious dangerous environmental impact but because no health and environmental impact study was performed on behalf of those who live here. It sits right on the Waters River and this project comes on the heels of Salem and the North Shore residents fighting to take the Salem coal plant down. We need to be aligned with the state’s decarbonization goals defined in the Climate Roadmap law and according to studies these goals will be impossible to meet if we are still operating these types of plants and the peaker plant will then become a stranded asset.”

Valletti proposes

“...a new Peabody master plan that will engage the city, its departments, and its residents to strategically address a vision that not only aligns with the legal requirements recently put forth in the Massachusetts Climate Road Map law, but also addresses economic development, zoning, and the city’s future. To fully satisfy trust and transparency, I would like to set clear goals by further clarifying solid public awareness, engagement, participation, and activity goals with feedback mechanisms in order to ensure future success.”