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…
Read MoreAccelerating a just transition to a democratic, transparent and renewable electric grid
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Technical Analysis
Takeaways from the ISO-NE Future Grid Reliability Study: Phase 1
by Roy Harvey and Kent Wittenburg on behalf of the FTG Technical Committee The Future Grid Reliability Study was undertaken by ISO-NE to plan for a transformed grid in which the generation mix changes radically from a large dependence on fossil fuels to one that meets the goals of decarbonization of the NE states and…
Read MoreTakeaways from the Jacobson Stanford Study on a 100% Renewable Grid
by Roy Harvey and Kent Wittenburg on behalf of the FTG Technical Committee To counter the view put forth by many power industry authorities in New England and elsewhere that fossil fuels are essential for grid reliability, there are two forms of evidence-based arguments available to renewable energy advocates. The first is reports from…
Read MoreTakeaways from the ISO-NE Future Pathways Study
By Roy Harvey and Kent Wittenburg on behalf of the FTG Technical Committee The Pathways Study, commissioned by ISO-NE, seeks to evaluate a number of alternative pathways forward in market structure and regulation to achieve the greenhouse gas reduction targets of the NE states. The assumed target is 80% reduction in carbon emissions by…
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Talk by Lorenzo Kristov
On Friday, November 15 the Technical Committee hosted a talk by Lorenzo Kristov, a visionary on the potential of distributed energy resources (DER) to enable a democratized, decentralized, and just electricity system. We had a great turnout of 57 participants…
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We have a new video about our action at the ISO-NE board meeting!
Check it out here , and many thanks to Ron Blau for creating it.
- An Independent System Operator (ISO) is a non-profit company authorized by the Federal Energy Regulatory Commission (FERC) to operate a regional electric grid, administer the wholesale electricity market, and plan the evolution of the grid. An ISO in North America is also a regional transmission organization (RTO) that manages the regional transmission grid (or what we often call, the grid).
- ISO-NE is New England’s ISO, and covers most of Massachusetts, Connecticut, Rhode Island, Vermont, New Hampshire, and Maine. The ISO-NE explainer summarizes these three key roles:
- Grid Operation: forecast, dispatch and direct the flow of electricity over the region’s high-voltage transmission system.
- Market Administration: design, run, and oversee markets that attract a large and diverse mix of participants to buy and sell wholesale electricity at the most competitive prices.
- Grid Planning: conduct the studies, analyses, and planning to make sure New England’s electricity needs will be met by considering the evolution of the grid over the next 10 years and beyond.
- FERC is the Federal Energy Regulatory Commission (FERC). It is an independent agency that regulates interstate natural gas pipelines, LNG terminals, and hydropower plants, and the interstate transmission of natural gas, oil, and electricity
- FERC also regulates all ISOs/RTOs across the country, including ISO New England. As the ISO-NE website explains, some ISO-NE actions require approval from FERC, including changes to market rules. The ISO-NE in general must comply with FERC rules and rule changes.
- The ISO-NE has control over proposing changes related to its own structure and electricity market rules, however, it must do so in consultation with the New England Power Pool (NEPOOL). NEPOOL consists of all the designated participants in ISO markets plus other designated stakeholders, including generators, transmission owners, energy service companies, electric consumers, and nonprofits. FERC approved this body to advise and vote on ISO-NE electric market rules and transmission tariffs.
- NEPOOL is a member of the North American Electric Reliability Corporation (NERC), which is responsible for ensuring the reliability of the electric power system in North America.
- ISO-NE carries out the mandate of the organization, while NEPOOL is the governance body that consults and votes on the market rules and changes. ISO-NE must consult NEPOOL when ISO-NE wants to make changes to rules or governing documents.
- NEPOOL is made up of a large group of members (ranging from generation companies to large industrial consumers to environmental advocates) that discuss and revise the proposals the ISO-New England is considering, and take non-binding “advisory” votes as to what they think the ISO-New England board should do. Corporate participants dominate voting, and corporate families have multiple companies in NEPOOL, and thus multiple votes.
- NEPOOL existed before FERC and ISO-NE were created. A timeline with simple explanations of the reasons for creating each of the organizations is here.
- The relationship between ISO-NE and NEPOOL is defined in a participants agreement with amendments and in an MOU (memorandum of understanding) that also defines the relationship between these two entities and NESCOE (see below for more on NESCOE).
- Generation companies own and operate the generation plants that supply electricity to the grid. In New England, most generation companies are investor-owned (private) companies that operate independent of utilities and state utility regulation. They seek to profit by selling their electricity either directly (through bilateral contracts) to wholesale electricity consumers such as utilities, or by selling their electricity in ISO-NE markets.
- Most of the remaining generation is owned by electric utilities. New England has dozens of municipal light plants (MLPs); these are allowed to own and generate electricity. In Vermont, investor-owned utilities still own generation, and even in the other five New England states which forced utilities to sell off their generation facilities during electric restructuring in the late 1990s and early 2000s, there are exceptions–e.g. in Massachusetts utilities may own some solar generation.
- Electric Utility Companies are sometimes called LDCs, local distribution companies, and include both state-regulated, investor-owned utilities like Eversource, Green Mountain Power, and Central Maine Power, and municipal utilities owned by the city or town in which they’re located.
- Utilities build and maintain distribution systems, buy power from the wholesale electricity markets and sell it to end-user customers, and meter and bill for each customer’s use. Utility-owned infrastructure generally includes substations, poles, wires and meters. Municipal utilities may also own their own generating plants. Most investor-owned utilities don’t make money off of generating electricity or providing transmission, but rather profit on the distribution infrastructure they build, usually set at about 9-11%.
- Each state has its own utility commission, a regulatory body: Massachusetts Department of Public Utilities (DPU), Connecticut Public Utilities Regulatory Authority (PURA), Maine Public Utilities Commission (PUC), New Hampshire Public Utilities Commission (PUC), Rhode Island Public Utilities Commission (PUC), and Vermont Public Utilities Commission (PUC).
- These departments oversee investor-owned utilities such as electric power, natural gas, and water companies. In particular, they set profit limits that investor-owned utilities can make, generally about 9-11%, and they generally require universal, safe and reliable access to electricity.
- At the federal level, the Environmental Protection Agency (EPA) implements laws passed by the U.S. Congress, including the Clean Air Act and the Clean Water Act. It sets national standards for air and water quality. Air quality standards limit the pollutants that a fossil fuel burning power plant can emit. Water quality standards limit the ability of power plants to use local water bodies for cooling or to release effluent, and set standards for impacts from hydropower.
- Other federal agencies may also play important roles. The US Army Corps of Engineers gives permits for construction near “navigable waters,” which include many to most waterways, and may undertake an Environmental Impact Statement or Environmental Assessment required by the National Environmental Policy Act (NEPA) when a pipeline or transmission line is to be built. The US Fish and Wildlife Service and the National Marine Fisheries Service have responsibility to ensure protection of endangered and threatened species and their critical habitats.
- States and tribes enforce these federal standards through their own regulations, and may pass more stringent regulations.
- At the state level, state environmental agencies oversee environmental regulatory programs, including for air, water, waste and land use. For example, the Massachusetts DEP “has the authority and responsibility for the management and control of air quality, regulation of the activities affecting wetlands, oversight and regulation of the quality of drinking water, management of water quality, control of pollution of all waters of the Commonwealth including groundwater, control of aquatic vegetation, regulation of the disposal of all solid wastes, the storage and transportation of hazardous wastes.” Other agencies are often responsible for fish and wildlife, and for recreational lands like parks.
- One reason is because our grid relies significantly on natural gas, which makes up the biggest share of New England’s fuel mix. The market for natural gas is global, and when Russia invaded Ukraine, gas supplies in Europe were constrained, and global prices went up. That made our natural gas, and our electricity, more expensive. Natural gas is regularly imported into New England from domestic and international sources. New England is also a net importer of electricity which is generated from Canada and New York. See ISO-NE’s Explainer here.
- Additionally, as ISO-NE argues, our region relies on just-in-time fuel delivered through pipelines, barges, or trucks. New England’s pipeline infrastructure is relatively small compared to other regions, and these factors result in greater imbalances in the supply and demand curve when supply cannot meet demand for these reasons.
- For more info, see slides from the FTG-sponsored Electric Bills Webinar.
- ISO-New England is run by a small board of directors, while full time professional staff carry out daily operations.
- To fund the services the ISO provides, ISO-NE “collects fees from the buyers and sellers in the region’s wholesale electricity markets and from the customers that use regional transmission services. Those service rates are set at a level that lets them recover only what they need to operate.” Part of that operation cost is employee’s salaries.
- The mission statement includes three main roles: “Through collaboration and innovation, ISO New England plans the transmission system, administers the region’s wholesale markets, and operates the power system to ensure reliable and competitively priced wholesale electricity.”
- The formal mission statement does not contain any reference to renewables or clean energy. However, a part of ISO-NE’s vision for the future is “to harness the power of competition and advanced technologies to reliably plan and operate the grid as the region transitions to clean energy.” This vision is also outlined in their strategic plan, including four pillars to support this vision, which entails “significant amounts of clean energy, balancing resources, energy adequacy, and transmission investment.” However, ISO-NE does not have a timetable with deadlines to realize concrete goals.
No. While the ISO-NE website contains a wealth of information on forecasting, reports, planning and other areas of their work, NEPOOL deliberations and votes are private and closed. In addition, prior to the 2022 ISO-NE board meeting, the public was not able to comment on or attend board meetings. The minutes and presentations to NEPOOL are available on the ISO-NE website, including the monthly Chief Operating Officer reports to the NEPOOL participants Committee.
The monthly report by ISO-NE to the NECPUC (New England Conference of Public Utility Commissioners) contains a useful summary. The June 2023 edition is linked here and the external affairs website contains all monthly reports.
- There are three main ways that state officials can influence decision-making processes at ISO-NE:
- Appealing to the NEPOOL Participants Committee: Multiple members of each sector, including municipal light departments, are registered as participants in NEPOOL. This includes a representative from the MA Attorney General’s Office, who sits as a Vice-Chair (Source). Public entities that sit as decision makers for NEPOOL would be subject to pressure from local or state officials.
- Renewable resource and transmission advocacy: in order to shift ISO-NE’s decisionmaking, state and local officials can push for increased renewable energy policy in their state that in turn impacts what generation ISO-NE has at its disposal when trying to meet regional demand. Local officials could also participate in the planning process of new transmission lines where applicable.
- The New England States Committee on Electricity (NESCOE) represents the collective perspectives of all six New England states in regional electricity matters. The governors in each state appoint members of NESCOE, but ISO-NE does not have to necessarily pass or implement NESCOE recommendations or policies. More information on the relationship between NESCOE and ISO-NE is available here and more on how NESCOE has been actively pushing ISO-NE on clean energy can be found in this article.
- Public utility commissions (PUCs) regulate the investor-owned utilities (IOUs) that operate within the state, which include electric and gas utilities. PUCs set retail rates for the utilities and monitor their compliance with both federal and state regulation.
- ISO-NE, in contrast, operates the bulk power system and the New England grid. ISO-NE operates wholesale electricity markets. PUCs and ISO-NE do not usually overlap in their responsibilities: PUCs regulate IOUs, and ISO-NE manages the regional power system.
- Our grid uses electricity generated here in New England and imported from other regions including New York and Canada. About 45% of demand (or load) in 2022 was met by natural gas. Nuclear provided 23%, renewables including solar, wind, refuse and wood 11%, and non-imported hydropower 7%.
- The fracked shale revolution, which has been ongoing for decades and subsidized by government money and ratepayers, has led to cheap natural gas. In our region, we’ve gone from 15% of our electricity mix consisting of natural gas in 2000, to over 45% today. The Marcellus play is closest to New England and most prolific. Environmental and health costs are externalized, meaning that we do not pay for them in the price of natural gas. More recently, prices have skyrocketed due to shortages associated with the war in Ukraine.
They have significant influence. View Tyson Slocum’s presentation for more.