Comments from Fix the Grid on Reliability

The Fix the Grid Technical Committee has submitted comments on FERC’s 2023 New England Winter Gas-Electric Forum in Portland, ME. Forty-four environmental, social, and labor organizations across New England joined with Fix the Grid to sign on to the FERC forum comments.

The comments to FERC were based on the letter sent to state representatives prior to the Portland Forum in June. The main points concerned the need to take account of demand-side solutions and energy storage in planning for reliability and also to incorporate environmental justice issues, public health, and environmental impacts in all planning. A central demand was to convene a public forum with these issues in mind.  The high-level recommendations were as follows:

  1. Put environmental justice and low-income communities front and center.
  2. Ensure that energy efficiency and other demand-side solutions are on an equal footing with supply-side options to ensure resource adequacy.
  3. Appropriately value clean energy storage and renewables for operations, market, environmental, and reliability studies and assessments.
  4. Modernize the grid with improvements to transmission planning and interconnection.

Aside from submitting the comments to FERC, the Technical Committee also referenced the document in comments to ISO New England regarding the EPRI weather impact study, which was a central part of the forum. It was noted that the EPRI weather reliability analyses have provided no evidence to favor keeping the Everett Liquified Natural Gas Marine Terminal open.  In separate comments, Roy Harvey requested a scenario with large amounts of renewables and storage for the next phase of modeling reliability in the ISO-NE network. ISO-NE accepted his suggestion for analysis within the limitations of their modeling tool. You can read the full text of the Fix the Grid comments submitted to FERC here. Roy’s suggested scenario, one of the stakeholder-informed sensitivity analyses to be performed, is described on page 22 of this report from the NEPOOL Reliability Committee.