The Maine Department of Energy Resources (DOER) is developing the next Maine Energy Plan, which will be delivered to the Governor and the Legislature in January 2027. DOER asked for public input through an online survey this fall, and Preserve Rural Maine submitted comments before the survey closed on October 30.
The survey limited how much could be written, so our comments had to be condensed. This post includes those comments, edited slightly for publication, followed by a fuller discussion of the issues we believe the plan needs to address.
Maine’s energy planning is often discussed in terms of generation targets and projected demand. Those numbers do not tell us where new generation and transmission will be built, what the total cost will be, or which communities and ratepayers will carry that cost. Those are the questions rural Maine needs answered.
Our comments to DOER
Below are three of the questions DOER asked in its public survey, followed by the answers we submitted.
Are there topics or priorities not included in the 2025 Energy Plan that you would like to see in the next plan?
Maine’s energy plan needs to look beyond generation targets and projected electricity demand. It needs to consider the entire electricity system required to support those targets, and the long-term costs and consequences of building and maintaining that infrastructure.
New renewable generation will require new transmission, particularly when resources are located far from existing transmission capacity and population centers. Intermittent generation also requires firm, dispatchable capacity and other balancing resources to keep the supply reliable when wind and solar are unavailable or insufficient. Those resources have their own infrastructure requirements and costs.
The plan should distinguish between installed capacity and the electricity that can actually be produced and delivered, taking into account capacity factors, seasonal and hourly production, curtailment, and transmission constraints. It should also show how electrification will affect peak and seasonal demand, and how much additional generation, transmission, and distribution will be needed under different levels of electrification.
Maine needs to account for the full cost of the transition, not just the cost of generation. That includes transmission, distribution upgrades, interconnection, storage, balancing resources, maintenance, and eventual replacement. The analysis should separate costs paid by Maine ratepayers, costs allocated regionally through ISO-NE, and costs of state procurement contracts, and it should identify which infrastructure serves Maine and which primarily serves regional needs.
Maine’s generation targets, the Northern Maine Renewable Energy procurement, the Maine Transmission Infrastructure Study, ISO-NE Long-Term Transmission Planning, and load growth forecasts should not be evaluated independently. The plan should identify where their assumptions differ and make sure the same resources or benefits are not counted more than once.
Where generation and transmission are built will have lasting consequences for host communities, property owners, agriculture, forestry, tourism, municipal tax bases, and the natural beauty that is part of Maine’s identity. A community hosting these projects does not necessarily receive the electricity or the benefits used to justify them. The plan should consider cumulative impacts, and meaningfully evaluate alternatives to new corridors, including existing rights-of-way, advanced conductors, grid-enhancing technologies, HVDC, storage, and non-wires alternatives.
Title 35-A, §10305 already requires the plan to address total energy costs for Maine consumers and to include supply and demand forecasts. We would like the next plan to answer these questions:
- How much additional generation will be needed, and what types?
- Where will it be built?
- How much transmission and distribution infrastructure will be required, and where?
- What will provide reliable electricity when intermittent generation is unavailable?
- What will the total system cost be, and how will it be divided between Maine ratepayers and the region?
- How will cumulative impacts on rural communities be accounted for?
- How will the state make sure its planning processes use consistent assumptions?
Maine needs to understand not just how much electricity it intends to generate or consume, but where that electricity will come from, when it will be available, how it will be delivered, what it will cost, and who will bear the consequences. We will be publishing a more detailed discussion of these issues.
How would you like to see DOER engage interested parties in the development of the plan?
DOER should engage interested parties early and throughout the development of the plan, rather than waiting until a draft is nearly complete to solicit public input. The public should have a meaningful opportunity to influence the assumptions, priorities, and recommendations included in the plan.
Engagement should include in-person regional meetings throughout Maine, including rural communities that may be directly affected by future energy generation and transmission infrastructure. Meetings should also be accessible remotely. Participation should extend beyond utilities, developers, and the energy industry to include property owners, municipalities, farmers, foresters, tourism businesses, ratepayers, and community organizations.
We would particularly like to see DOER engage municipalities and property owners in areas already being considered for significant energy infrastructure. Statewide energy planning can look very different on paper than it does to the people whose land, roads, communities, and tax bases may be affected. Those perspectives need to be included before the plan establishes assumptions about where and how future development will occur.
DOER should make supporting studies, data, forecasts, modeling assumptions, and cost estimates available well in advance of public meetings so participants have a reasonable opportunity to review the information and prepare informed comments.
There should also be opportunities for more detailed discussion of specific issues, including generation and transmission needs, grid reliability, electrification, infrastructure costs, and the impacts of energy development on Maine communities.
Finally, DOER should maintain a public record of the input received and explain how substantive comments and recommendations were considered in developing the final plan. Public engagement should be an ongoing part of the planning process, not simply an opportunity to comment on decisions that have already been made.
Please share any other feedback you have.
One of our greatest concerns is that Maine’s energy planning is moving forward through multiple separate processes, each addressing a piece of the state’s energy future, without a clear and comprehensive picture of how all of those pieces fit together. Generation procurement, transmission planning, electrification, grid reliability, and regional energy commitments are interconnected. Decisions made in one process create consequences in others, and those consequences extend well beyond the energy industry.
The scale involved is significant. The TIDE transmission project selected through ISO-NE’s 2025 Long-Term Transmission Planning process has an estimated cost of approximately $2.2 billion and is intended, in part, to accommodate up to 1,200 MW of additional onshore wind generation in northern New England. That is one project.
The state needs to be transparent about the assumptions being used, the projects being contemplated, the costs being projected, and the long-term infrastructure requirements. It should also clearly distinguish between what is needed to serve Maine’s electricity consumers and what is being developed to meet broader regional objectives. A project can have a favorable projected generation cost while still creating substantial additional system costs.
The plan should also explain what resources will be available during extended periods of low wind and solar production. It is not enough to identify how much renewable generation Maine wants to add without explaining how the electricity supply will remain reliable when that generation is not available.
We would also encourage DOER to give greater consideration to the long-term interests of Maine’s rural communities. Much of the land being considered for energy generation and transmission is privately owned or part of communities whose economies and character depend on agriculture, forestry, tourism, and the natural beauty of the state. These communities should not be viewed simply as available locations for infrastructure. Their land-use priorities, property rights, municipal authority, and long-term economic interests deserve consideration in statewide energy planning.
Energy policy should not be developed in isolation from land-use planning, economic development, and the interests of the people who will live with the consequences of these decisions for decades.
Maine needs an energy plan that is realistic about costs, honest about infrastructure requirements, attentive to reliability, and transparent about who benefits and who bears the burdens. The plan should evaluate alternatives, identify uncertainties, and acknowledge where additional information or analysis is needed rather than treating projections and policy objectives as settled outcomes.
Ultimately, the purpose of energy planning should be to ensure that Maine has reliable and affordable energy while protecting the long-term interests of its communities and ratepayers. Meeting generation targets should not become an end in itself, separate from those broader responsibilities.
Thank you for the opportunity to comment.
A closer look at what is missing
The following was not part of our submission. It is a fuller discussion of the issues behind our comments, which we could not include because of the survey’s character limit.
Generation and transmission go together
New renewable generation sources will require new transmission infrastructure, particularly when those resources are located far from existing transmission capacity and population centers. Additional intermittent generation also creates a need for sufficient firm, dispatchable capacity and other balancing resources to maintain a reliable electricity supply when wind and solar generation are unavailable or insufficient. Those resources have their own infrastructure requirements and costs.
Where will all this new generation be built? Where will the transmission infrastructure be built? How much new infrastructure will be required to connect generation to the existing grid, move electricity through Maine, and deliver it to the areas where it is needed? These are fundamental questions that should be answered as part of the state’s energy planning, not deferred until individual projects are proposed.
Maine’s own transmission planning efforts show the scale of what may be involved. The Maine Transmission Infrastructure Study and ISO-NE’s Long-Term Transmission Planning process identify substantial transmission needs associated with future generation, regional reliability, and the movement of electricity between Maine and the rest of New England.
For example, the TIDE transmission project selected through ISO-NE’s 2025 Long-Term Transmission Planning process has an estimated cost of approximately $2.2 billion and is intended, in part, to accommodate up to 1,200 MW of additional onshore wind generation in northern New England. Its costs are allocated across the six New England states based on their share of regional peak electricity demand. This is a significant investment, and it is only one example of the infrastructure costs associated with meeting regional energy objectives.
The plan should explain how Maine’s generation targets, transmission needs, and regional commitments fit together. It should also identify which infrastructure is intended to serve Maine’s electricity needs and which projects are being developed primarily to address regional needs or move electricity to other states.
Installed capacity is not the same as delivered electricity
The plan also needs to distinguish between installed generation capacity and the actual electricity that can be produced and delivered. Nameplate capacity does not tell us how much electricity a resource will generate over the course of a year, when that generation will be available, whether it can be delivered when needed, or whether transmission constraints will limit its use. Capacity factors, seasonal and hourly production profiles, curtailment, congestion, and resource availability all need to be considered.
Electrification will change demand
Further beneficial electrification of transportation, heating, and other energy uses will increase electricity demand. That additional demand will require additional generation and potentially significant upgrades to transmission and distribution infrastructure. The plan should demonstrate how projected electrification will affect peak demand, seasonal demand, and the amount of electricity required at different times of day and throughout the year.
It should also address how much additional generation and infrastructure will be needed under different levels of electrification, rather than assuming that new renewable generation and the existing grid will be sufficient to accommodate future demand.
Reliability when the wind and sun are not available
The increasing integration of intermittent resources also creates operational challenges. Grid operators must continually balance supply and demand while managing changing power flows, voltage, frequency, reserves, and transmission constraints. Variability in renewable generation can increase the need for flexible resources, reserve capacity, and grid-management capabilities. The costs of balancing, maintaining, and upgrading the system need to be included in the state’s assessment.
The plan should also explain what resources will be available during extended periods of low wind and solar production, how those resources will be fueled or supplied, and what transmission infrastructure will be needed to make them available. Storage, imports, dispatchable generation, demand response, and other balancing options should be evaluated realistically, including their costs and limitations. It is not enough to identify how much renewable generation Maine wants to add without explaining how the electricity supply will remain reliable when that generation is not available.
The full cost of the energy transition
The cost of generating electricity is only one part of the equation. Maine needs to account for the costs of transmission construction, distribution upgrades, interconnection, storage, balancing resources, grid modernization, ongoing maintenance, and eventual equipment replacement. These costs should be evaluated together so that consumers and policymakers can understand the total cost of delivering reliable electricity.
The analysis should also distinguish between costs paid directly by Maine ratepayers, costs allocated regionally through ISO-NE, costs recovered through distribution rates, and costs associated with state renewable energy procurement contracts. Long-term operating and maintenance costs should not be overlooked simply because they do not appear in the initial construction estimate.
A project can have a favorable projected generation cost while still creating substantial additional system costs. Those costs need to be considered when comparing energy sources and determining what is actually affordable for Maine consumers.
Planning processes need to be considered together
Maine has multiple planning and procurement processes underway that affect the same overall electricity system. These include renewable generation targets, the Northern Maine Renewable Energy procurement, the Maine Transmission Infrastructure Study, ISO-NE’s Long-Term Transmission Planning process, projected load growth, beneficial electrification, and regional generation and transmission development.
These processes should not be evaluated independently. The state needs to explain how their assumptions, timelines, costs, and infrastructure requirements fit together.
For example, how are Maine’s renewable generation targets being reconciled with the transmission capacity that will actually be available to connect and deliver that generation? How are the assumptions used in the transmission studies being reconciled with Maine’s own electricity demand forecasts? Are the generation projects being considered in one procurement also being accounted for in other regional planning processes? Are the same projected resources or benefits being counted more than once?
The plan should identify where assumptions differ between these processes and explain how those differences are being addressed. Maine should not be making long-term commitments based on one set of projections while separate planning processes are using different assumptions about future demand, generation, or transmission needs.
The impacts on Maine communities
Where generation is developed and where transmission infrastructure is constructed will have lasting consequences for the communities hosting these projects. Large-scale generation facilities, transmission corridors, substations, and associated infrastructure can change the character of rural communities, affect property owners, alter existing land uses, and place additional demands on municipal services and infrastructure.
The plan should identify the geographic areas likely to be affected by future development and consider the cumulative impacts of multiple energy projects. It should also address how the state intends to balance its energy objectives with municipal planning authority, property rights, existing land uses, and the long-term interests of the people who live in these communities.
A community hosting a large generation or transmission project does not necessarily receive the electricity produced or transported through that infrastructure. The plan should consider this distinction when evaluating community benefits, economic impacts, and the distribution of costs and benefits across the state.
There should also be consideration of the long-term impacts on property values, agriculture, forestry, tourism, municipal tax bases, and the natural beauty that is an important part of Maine’s identity and rural economy. These are not incidental concerns. They are part of the cost of developing energy infrastructure, even when they do not appear in a project’s construction budget.
Alternatives to new transmission corridors
New transmission corridors and greenfield construction should not be treated as the default solution without a thorough evaluation of alternatives. Existing rights-of-way, reconductoring, advanced conductors, grid-enhancing technologies, high-voltage direct current transmission, energy storage, distributed generation, demand response, and non-wires alternatives should be evaluated for their ability to meet identified needs.
The Maine Transmission Infrastructure Study considered several of these options, including the use of existing transportation and railway rights-of-way and strategic undergrounding. The state should carry that work forward and identify where these alternatives can realistically reduce the need for new corridors or lessen the impacts on communities and property owners.
The analysis should compare these options based on cost, reliability, deliverability, construction requirements, land-use impacts, and long-term performance. It should also consider whether the projected need for new infrastructure can be reduced through more efficient use of existing grid capacity or changes in how and where electricity is generated and consumed.
The questions the plan needs to answer
Maine’s energy plan should consider the entire system, not simply the amount of renewable generation the state intends to procure or the amount of electricity it anticipates consuming. At a minimum, it should answer these basic questions:
- How much additional generation will be needed to meet projected demand, and what types of generation will provide it?
- Where is that generation expected to be built?
- How much additional transmission and distribution infrastructure will be required, and where will it be located?
- What resources will provide reliable electricity when intermittent generation is unavailable?
- How will the state account for the costs of balancing, maintaining, and upgrading the grid as the generation mix changes?
- How will the costs of generation and infrastructure be divided between Maine ratepayers and regional consumers?
- How will the state account for the cumulative effects of generation and transmission projects on rural communities, property owners, municipalities, and existing land uses?
- What alternatives to new transmission corridors will be considered, and how will those alternatives be compared?
- How will the state ensure that its own energy plan, utility grid planning, and regional transmission planning use consistent assumptions and forecasts?
Looking at the full picture
The central questions are not just how much electricity Maine wants to generate or how much demand it expects to have. They are how that electricity will be generated, where it will come from, when it will be available, how it will be delivered, what infrastructure will be required, what the total costs will be, and who will bear the consequences of building and maintaining that system.
Maine has a responsibility to look at the full picture before making long-term commitments that will affect electricity consumers, property owners, municipalities, and communities for decades. Without that full picture, it is difficult to determine whether the state’s energy objectives are achievable, affordable, or consistent with the long-term interests of Maine and the people who live here.
We would like to see the Department’s energy plan address these issues directly, with supporting data, realistic projections, and a clear accounting of the infrastructure and costs involved.
How you can stay involved
DOER’s online survey for the plan closed on October 30, but there will be more opportunities to weigh in. State law requires DOER to hold at least two public meetings and accept public comment on a draft of the plan before it is finalized.
- Sign up for plan updates on DOER’s Maine Energy Plan page so you know when the draft is released.
- Watch the DOER public meetings page for upcoming sessions.
- Contact DOER directly through its Contact Us page with your own concerns.
If you live in or near an area being considered for energy generation or transmission, your perspective is especially needed. Statewide plans look very different on paper than they do from the ground.
Sources
2027 Maine Energy Plan Kickoff Meeting slides
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