Dear PSC Chairman Brown and Ms. Jodi Fansler:
No later than noon this coming Monday 30 June 2008, I will send you other issues about Iberdrola SA defrauding the State of New York and its citizenry.
Please permanently remove Iberdrola SA (and its affiliates) from doing business in NY State.
Iberdrola SA (including, but not limited to its wholly owned affiliate Community Energy Inc) is defrauding the monies of the residential ratepayers of NY State in the "Renewable Portfolio Standard Fund" and is defrauding the NY State taxpayers of monies via the REC program.
1. ATLANTIC-JERSEY WIND PROJECT, aka Atlantic City Wind Project (NJ):
Each of the five 1.5 MW turbines at the Jersey-Atlantic Wind Project (aka Atlantic City Wind Project) can produce 1.5 megawatts of electricity for a total wind farm nameplate capacity of 7.5 MW … “That’s equivalent to the annual energy consumption of about 2,500 homes,” said Paul Copleman, marketing operations manager at Community Energy Inc.
However, Iberdrola SA (Community Energy Inc) knows that the wind turbines at the Jersey-Atlantic Wind Project (aka Atlantic City Wind Project) only have a 10% effective capacity. The wind turbines installed in 2005 at Community Energy Inc’s (CEI’s) Jersey-Atlantic Wind Project are the same GE model 1.5 MW wind turbines in the same year 2005 that General Electric [aka GE Energy], the turbine manufacturer, in a report to the New York State Energy Research and Development Authority (NYSERDA) on 04 March 2005, stated: “Capacity factors of inland sites in New York are on the order of 30% of their rated [nameplate] capacity. Their effective capacities, however, are about 10% [of rated capacity], due to both the seasonal and daily patterns of the wind generation being largely ‘out of phase’ with the NYISO [New York Independent System Operator] load patterns.”
Therefore the 2005 version of the five GE 1.5 MW turbines being used at the Jersey-Atlantic Wind Project will only power 250 homes. That's only 10% of what Iberdrola falsely claims it is generating there.
Even taking into account Atlantic City's coastal location in New Jersey, the effective output of the five GE 1.5 MW turbines at the Jersey-Atlantic Wind Project would never more than double (due to coastal wind conditions) to 20% effectiveness, meaning that the Jersey-Atlantic Wind Project might be able to power a meager 500 homes.
Iberdrola SA (CEI) is claiming and collecting (from NY State) RECs and RPS money based on a 7.5 MW total output capacity at that wind farm, when Iberdrola SA (CEI) knows that the real output capacity of that coastal wind farm is somewhere between 10% (250 homes) and 20% (500 homes).
It is FRAUDULENT that CEI (Iberdrola) is fraudulently claiming it's supplying wind electricity from the Jersey-Atlantic Wind Project [electricity that will only power 250 to 500 homes regardless of state or location] to New York State when, in actuality, the Jersey-Atlantic Wind Project is supplying the entirety of that wind electricity throughout New Jersey.
It is similarly FRAUDULENT for Iberdrola SA (Community Energy Inc), in order to obtain RPS and REC money from New York State, to be falsely claiming a 7.5 MW output capability at the Jersey-Atlantic Wind Project which even GE says far exceeds the output capabilities of the GE wind turbines in use at the Jersey-Atlantic Wind Project.
It is also FRAUDULENT for Iberdrola SA (Community Energy Inc) to have written delivery contracts for future deliveries of Jersey-Atlantic Wind Project electricity which excessively exceed the ouput capacity what that wind farm's GE generators can actually provide the Jersey-Atlantic Wind Project's extensive list of already contracted New Jersey customers it specifically lists.
And it is FRAUDULENT, in order to obtain RPS and REC money from New York State, for Iberdrola SA (Community Energy Inc), which has contractually more than committed and used up all of the Jersey-Atlantic Wind Project electricity capable of being produced there, to write long-term supply contracts for electricity from the Jersey-Atlantic Wind Project electricity with customers located in New York State.
The Iberdrola SA affiliate-owned Jersey-Atlantic Wind Project lists long-term multi-year contracts of Jersey-Atlantic Wind Project electricity to numerous large New Jersey located customers which include but are not limited to: institutions (Rowan University), industries (Johnson&Johnson’s New Jersey corporate locations), businesses (nine New Jersey stores of Whole Foods Market plus NJ-located warehouses plus one NY City store of Whole Foods Market; and to the Geraldine R. Dodge Foundation; and to the Sandy Alexander lithography/printing Company) -- that's far more than the equivalent of the 250 to 500 home real maximum capacity output of its five GE 1.5 MW wind turbines, the effective rating output of which GE Energy brought to NYSERDA's attention in 2005. That's DEFRAUDING the NYS "RPS" Fund and the NYS "RECs payout system, etc.
Additionally, the Iberdrola (CEI) operated Atlantic City Wind Project also supplies wind electricity to the New Jersey facility of the Atlantic County Utilities Authority (ACUA) waste water treatment center (handling 70% of that ACUA's site's total electrical requirements).
Additionally, six utility companies in New Jersey are offering to each of their customers three wind electricity products generated at Iberdrola's (Community Energy Inc's) Jersey-Atlantic Wind Project. The six utility companies are: Public Service Electric & Gas (PSE&G); Jersey Central Power & Light (JCP&L); Atlantic City Electric; Rockland Electric; Orange & Rockland; and Jersey-Atlantic Wind. The three Jersey-Atlantic Wind Project generated products which all six companies offer their customers are:
(1) A 100% New Jersey-based wind product in 100-kWh monthly increments is being offered under the brand name Jersey-Atlantic Wind. By clicking on the wind product “Jersey-Atlantic Wind” at this website, it opens the website of the owner and marketer of that product who, you guessed it, is Community Energy Inc (Iberdrola SA).
“New Jersey Wind is a renewable electricity certificate product delivered to the regional electric grid ... by the Jersey-Atlantic Wind Farm in Atlantic County, NJ.”
(2) Under the Iberdrola SA (Community Energy Inc) brand name NewWind Energy®, a blend of A 100% New Jersey-based wind product in 100-kWh monthly increments is being offered under the brand name Jersey-Atlantic Wind. By clicking on the wind product “Jersey-Atlantic Wind” at this website, it opens the website of the owner and marketer of that product who, you guessed it, is Community Energy Inc (Iberdrola SA).
“New Jersey Wind is a renewable electricity certificate product delivered to the regional electric grid ... by the Jersey-Atlantic Wind Farm in Atlantic County, NJ.”
(3) Under the Iberdrola SA (Community Energy Inc) brand name NewWind Energy®, a blend of wind (50%), low-impact hydro (49%), and solar (1%) is being offered.
Obviously, Iberdrola's (Community Energy Inc's) Jersey-Atlantic Wind Project which can only produce enough electricity for 250 to 500 houses cannot possibly produce the massive quantities of wind electricity which Iberdrola SA claims to be producing for numerous very big electricity using customers and markets in New Jersey. “New Jersey Wind is a renewable electricity certificate product delivered to the regional electric grid ... by the Jersey-Atlantic Wind Farm in Atlantic County, NJ.”
(2) A blend of New Jersey-based wind (50%) and low-impact hydro (50%) is being offered under the brand name Jersey-Atlantic Wind. By clicking on the wind product “Jersey-Atlantic Wind” at this website, it opens the website of the owner and marketer of that product who, you guessed it, is Community Energy Inc (Iberdrola SA).
“New Jersey Wind is a renewable electricity certificate product delivered to the regional electric grid ... by the Jersey-Atlantic Wind Farm in Atlantic County, NJ.”
Obviously, there is nothing left for New York State, whose residential ratepayers have had their Renewable Portfolio Standard (RPS) monies swindled in 2005 by NYSERDA action which sent their monies to Community Energy Inc to build that out-of-state project in New Jersey (the Jersey-Atlantic Wind Project), and whose NY State taxpayers have had their NY State income tax monies swindled by NYSERDA's payment of that money to Iberdrola SA (Community Energy Inc) in exchange for Iberdrola SA (Community Energy Inc) self-issued RECs for Jersey-Atlantic Wind Project electricity. Clearly it is a facade to believe that actual wind generated electricity from this project.
The fact that the the relatively tiny Jersey-Atlantic Wind Project (aka Atlantic City Wind Farm) had a $12.5 million project cost when it opened 12 December 2005 but only 21 full months later had $0 debt is indicative of massive defrauding of the RPS fund and the REC system.
New Jersey has its own Renewable Portfolio Standard (RPS) fund to develop wind farm projects in New Jersey. So wasn't New Jersey's own RPS monies being used to fund and develop the New Jersey located Community Energy Inc (CEI) Jersey-Atlantic Wind Farm? Or has Iberdrola SA (Community Energy Inc) instead been windfall profiting (at an alarming rate) by double dipping RPS monies from both of the states (New Jersey and New York) for Iberdrola SA's wind farm located in New Jersey?
Crookedly, New York State (NYSERDA) has given away its NY State residential ratepayers' RPS fund monies to develop the New Jersey located wind project (giving its owner Community Energy Inc / Iberdola SA immediate windfall profits). But New Jersey does not use any of its New Jersey State residential ratepayers' RPS fund monies to develop any wind projects located in New York State.
The Jersey-Atlantic Wind Farm is a New Jersey located project. Therefore, its owner (Iberdrola SA's Community Energy Inc) was paid numerous free grants awarded by the State of New Jersey, among which are:
(1) A State of New Jersey huge monetary grant under the New Jersey's "Grid Supply Program".
(2) Community Energy Inc received a $1.7 million grant from the New Jersey Board of Public Utilities [aka the New Jersey Board of Public Utilities (BPU) Office of Clean
Energy's (OCE) new REED (Renewable Energy and Economic Development) Program].
(3) A $1.92 million supply grant through Atlantic City Electric [most likely garnered by Atlantic City Electric from State of New Jersey and Federal tax monies].
(4) The State of New Jersey also offers [to Community Energy Inc's Jersey-Atlantic Wind Project] a 'new technology incubator' additional tax write-off / additional grant program for wind power project companies (new technology companies) which are already operating in the State of New Jersey and to other 'new technology companies' which are newly locating to New Jersey.
Plus, because it is located in New Jersey and sells it electricity to New Jersey customers, Iberdrola SA's Community Energy Inc's Atlantic City Wind Farm issues massive numbers of Renewable Energy Certificates which are redeemed for massive amounts of State of New Jersey provided cash. In fact, the New Jersey REC payments fund is quickly approaching bankruptcy due to the extraordinary numbers of RECs that Iberdrola SA's Community Energy (and others like them) are self-issuing in New Jersey.
Plus, because it is located in New Jersey, Iberdrola SA's Community Energy Inc's Atlantic City Wind Farm receives massive amounts of tax breaks from the State of New Jersey as:
(1) Production Tax Credits (PTCs) deducted from a New Jersey income tax form.
(2) [Rapidly] Accelerated Depreciation deducted from another New Jersey income tax form.
(3) Carbon Credits.
Plus, Iberdrola SA's Community Energy Inc's Atlantic City Wind Farm receives massive amounts of tax breaks from the Federal Government as:
(1) Production Tax Credits (PTCs) deducted from a U.S. income tax form.
(2) [Rapidly] Accelerated Depreciation deducted from another U.S. income tax form.
(3) Carbon Credits.
NY State's REC and RPS payout system is a joke. You're seeing the financial fraud that happens with the fox (Iberdrola SA) in charge of the henhouse.
Iberdrola's use of New York State monies for wind power projects in New Jersey (and Pennsylvania) is deplorable, corrupt, and is part of a massive wind power racketeering scheme.
Kick Iberdrola SA (and its affiliate Community Energy Inc) permanently out of the State of New York for having its wind electricity customer Whole Foods Market sell wind REC cards to grocery shoppers at Whole Foods Market.
Stop sending RPS monies out-of-state. In February 2005, the Renewable Portfolio Standard (RPS) "ratepayers" fund of NYSERDA paid NY State ratepayers' monies to build a NEW JERSEY located wind "farm" (the Atlantic City Wind Farm).
Stop the unethical practice of allowing Iberdrola to combine the use of REC money and RPS money for the same facility and its output.
Stop allowing New York State to issue RPS money and REC money to Iberdrola SA (and its affiliates) for any purpose anywhere.
Sincerely,
Daniel M. Wing, Jr.
(ph: 585-224-6758)
139 Thistledown Dr.
Rochester, NY 14617-3020
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