In a protest to the Federal Energy Regulatory Commission, RENEW Northeast explained how ISO New England’s proposal to give a no-bid contract to the Mystic 8 and 9 fossil fuel generation units will provide “undue” preference, advantage and prejudice prohibited by the Federal Power Act to those units at the expense of state policy resources like wind and solar. This discrimination will hinder attainment of state policy requirements and increase consumer costs.
The current Forward Capacity Market (“FCM”) rules subject new state-sponsored capacity resources to a Minimum Offer Price Rule (“MOPR”), which requires these sponsored assets to bid into FCM at an administratively determined price. The ISO believes that state-sponsored resources must be mitigated in the FCM to avoid a significant overbuild of the New England power system. In its fuel security proposal, however, the ISO seeks to treat resources that have been retained for fuel security- not state sponsored resources- as price-takers in the FCA. The ISO asserts that treating fuel security risk units as price-takers “considers the contribution to resource adequacy of these resources when determining Capacity Supply Obligation (“CSO”) awards and setting the FCA clearing price,” and “will prevent the region from procuring more resources than are needed to meet its resource adequacy objectives.” Of course, the same argument is true for state-sponsored resources. In requiring units having fuel security out-of-market agreements but not units having state-sponsored agreements to be price-takers in the FCA, the ISO is taking a position contradictory to its position on state sponsored resources and one biased against the contributions of state-sponsored resources. It is also one that gives “undue” preference and advantage to those retained fossil fuel units.
Should this provision enter the Tariff, it will join another aspect of the FCM design that disadvantages renewables which is the calculation of the CSO of variable renewable resources like wind and solar compared to generation with interruptible fuel like natural gas generation. While wind and solar are variable, the ISO operates an accurate forecasting system that renders a fleet of solar and wind resources dependable. Nevertheless, the CSO of variable resources is reduced to reflect actual wind and solar. By comparison, all the factors that are driving the next round of fuel-security market improvements that the ISO must submit to the Commission by July 1, 2019, which are pipeline capacity limits and outages, disruptions that can accompany oil and LNG deliveries and limitations due to air emission permits, are limited to fossil fuel resources whose CSOs are not adjusted downward despite the limitations of their fuel sources. The ISO’s lead-off memorandum to begin stakeholder discussions to meet the July 1, 2019, deadline states that the ISO will not be making any changes to the FCM, as it finds it is meeting its requirements for capacity, but will focus on energy market changes to address fuel security. Although a CSO is designed to give the ISO a call-option on the energy from a capacity resource, the ISO apparently has no plans to reduce the CSO for resources they believe are causing the fuel security risk.
At the ISO New England Planning Advisory Committee on September 27, 2018, RENEW Northeast will be providing feedback to ISO New England on the Second Maine Resource Integration Study that is based on RENEW’s written comments.
RENEW Northeast submitted testimony to the Connecticut legislature’s environmental committee in favor of amending a law passed last year that is having a chilling effect on developers seeking new sites for utility-scale solar projects in Connecticut. Under the law, the Department of Agriculture is able to force a utility-scale solar energy project into the more expensive and lengthy Siting Council permit process designed for the evaluation of large (over 65 megawatts) fossil-fueled plants. To achieve Connecticut’s environmental, renewable and economic development goals, a solar energy project should not face a riskier and costlier permitting process compared to smaller projects (65 megawatts or less) to be fueled by natural gas or oil, or a permanent housing or commercial development.
Misses Opportunity to Invest in New, Clean Energy –
RENEW is disappointed today that Massachusetts chose to affirm its decision to sign a long-term contract for existing provincially owned power in Quebec. The failure of Northern Pass provided a chance to revisit that first choice by considering whether it would have been better to have purchased energy from all-new wind and solar resources. Instead, Massachusetts has chosen to keep the Northern Pass Project bid alive and add a back-up proposal for transmission to Quebec in case negotiations with the Northern Pass Project are unsuccessful.
RENEW Northeast praises Chairman Pacheco, Vice-Chairman Eldridge and the Massachusetts Senate Committee on Global Warming and Climate Change for releasing today visionary legislation to advance a significant deployment of new renewable energy sources. The bill’s acceleration of the annual growth rate in the Massachusetts Renewable Portfolio Standard (RPS)- the amount of renewable energy utilities and retail suppliers must provide to their customers- from the current 1 percent per year to 3 percent per year will spark a revolution in displacing the region’s greenhouse gas emitting generation with emissions-free resources.
RENEW Northeast commends today’s decision of the New Hampshire Site Evaluation Committee to deny the application of the Northern Pass transmission line. This project and the associated energy from Hydro-Quebec, as the winning bidders out of last week’s Massachusetts Clean Energy RFP, would have cost Massachusetts ratepayers $500 million annually for 20 years. Despite this high cost, it would only bring energy from old generation rather than from new renewable resources that can enable Massachusetts to achieve its required greenhouse gas emissions reductions.
Connecticut has some of the highest electricity rates in the nation, and in January they will increase even further.
The Connecticut Department of Energy and Environmental Protection (DEEP) will soon release the final version of its three-year Comprehensive Energy Strategy, which aims to create a cheaper, cleaner, more reliable energy future for our state’s residents and businesses.
In a Providence Journal op-ed, RENEW Northeast and the Rhode Island chapter of the Sierra Club explained how National Grid’s rate increase was caused by the retirement of one old dirty plant, driving up consumer prices to pay for new dirty plants. We urged that instead of continuing to rely on these dirty plants and the volatility of imported fossil fuels, we should invest in New England communities, more jobs, and long-term price stability through clean energy, such as wind and solar.
The Connecticut General Assembly has enacted Senate Bill No. 943, “An Act Concerning the Installation of Certain Solar Facilities on Productive Farmlands” that singles out the least-cost form of solar development by imposing a permitting process established for large-scale fossil fueled power plants. As RENEW explained in a recent op-ed, this bill penalizing solar development placed on farmland will jeopardize past and future energy solicitations intended to bring clean energy, low electricity prices, economic development and sound environmental policy to the state.
This post is by John Rogers who is a senior energy analyst with the Union of Concerned Scientists and a director on the RENEW Northeast board.