Instead, Enbridge, the infamous pipeline company responsible for Line 3, Line 5, and the Weymouth Compressor, is proceeding with a 23% capacity expansion of the Algonquin pipeline. This pipeline runs from New Jersey through New York and into Connecticut, Rhode Island, and Massachusetts, bringing fracked gas from as far away as Texas.  The gas is then distributed to customers via distribution systems throughout New England. Enbridge claims more gas is needed for electricity generation and heating at the exact time we are seeking to reduce gas for these purposes.

Enbridge first announced this capacity expansion in late 2023, seeking customers willing to sign contracts. Since then the company has been proceeding with a series of supposedly independent “improvements and maintenance” on the pipeline, all consistent with their objective of increasing its capacity. Here is what we know so far.

• Enbridge is proceeding with a replacement pipeline with 4X the capacity of the existing pipeline in Rhode Island under the Sakonnet River, part of Narragansett Bay. Despite best efforts of the opposition, the Rhode Island authorities and the Federal Energy Regulatory Commission (FERC) approved the project at the end of June.
• At the same time, FERC also authorized the construction of a new metering and regulator facility in Coventry, CT, denying protests filed by the opposition.
• On state-designated Priority Habitat of Rare Species in Lincoln, MA, Enbridge is planning to remove 40 or more mature trees in order to gain access to replace the metering and regulator facility there. The site is on land owned by the City of Cambridge that was purchased to provide a natural buffer for the city’s water supply. Cambridge opposed the project, but Enbridge sued, claiming eminent domain. A settlement was reached on June 14.  Opposition is forming, including a tree sit-in. It appears that Enbridge is short-cutting the approval process that should have included at least the state environmental authorities.

What can you do?

1. Educate yourself and others about this problem.  See http://stopprojectmaple.org for more background and upcoming actions. Join activists in the Stop Project Maple coalition by contacting Martha Klein (puckyshouse@gmail.com).
2. Write Letters to the Editor of your local papers expressing your opposition.
3. Contact your local officials in Massachusetts, Rhode Island, and Connecticut to sign an opposition letter for your state. See https://stopprojectmaple.org/take-action/ for instructions.

The post Stand Against Fossil Gas Expansion in our Back Yards appeared first on Fix the Grid.

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.

The post Comments from Fix the Grid on Reliability appeared first on Fix the Grid.

For more industry news summaries from the Technical Committee, see Bob Person’s Resource Digest. The latest entries also include news of a solar PV concern challenging the special treatment given to MA wind and hydro projects, an analysis of reliability factors for various generation sources, the cancellation of Avangrid’s contract for offshore wind, and more data on the unreliability of natural gas.

The post New FERC Rules for Speeding up Grid Connections appeared first on Fix the Grid.

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 is supplied in large part by renewables. The Future Grid Reliability Study Phase 1 (FGRS Phase 1) seeks to identify operational and reliability challenges and was released in stages starting in July 2022. Phase 2, expected in 2023, will be an economic study to determine whether the existing market structures will be sufficient to provide the resources needed to meet the challenges identified in Phase 1. Both are part of the  ISO-NE Future Grid Initiative, and materials are available on the ISO-NE website. 

Groups such as Fix the Grid that are advocating for a rapid and complete transition of the grid away from fossil fuels need to look closely at studies like these since the need for reliability, a fundamental mission of any grid authority such as ISO-NE, could be used to slow walk the green transition. It is much easier to manage reliability in a grid composed of dispatchable fossil fuel generation than in one that is made up of distributed, variable generation like wind and solar until long-term storage technologies mature. And yet we must acknowledge that the challenges of providing reliability with a decarbonized grid are real.

Study Summary

The scenario of primary interest (Scenario 3–”deep decarbonization”) analyzed in the study consisted of modeling a 2040 NE grid that meets the goal for the New England states to reach an emissions reduction of 80% from 1990 levels as well as meeting the requirements of a doubling of electricity demand by that date. Electricity demand is projected to double because of the transition to electric heat and electric transportation. The complexities of such a grid include meeting demand with variable and distributed generation (wind and solar) and managing battery storage. The most important question posed by this study is whether a deep carbonization scenario could meet reliability criteria and, if so, how. The requirements for reliability, which come from federal and regional regulatory bodies, include that outages (aside from weather-related) caused by deficient resources shall happen on average for no more than 2.4 hours per year. Resource adequacy tools were used in the study to model the NE grid system on a minute-by-minute basis under variable weather conditions to determine if generation could meet demand at all times.

Here were the most significant results:

• The base case models of Scenario 3 satisfied emissions reduction and increasing electricity demand expectations without considering variability due to weather.
  
  Scenario 3 in this study modeled a generation mix that met the emission reduction goals while satisfying a doubling of demand through “nameplate” capacity. (“Nameplate” is an indication of ideal generation capacity, but renewables are affected by weather conditions.) The scenario included all planned generator retirements and also the retirement of all remaining coal, oil, and refuse-burning plants. Natural gas generation continued but amounted to roughly half of the average 2005-2019 generation. The amount of renewables grew significantly to a total of 45.6 GW and included 17 GWs of offshore wind, 28 GW of solar, and .6 GW of battery storage–the amount was 2.5X the amount of renewables assumed in the base scenario 0, which was a continuation of current growth trends and conservative demand increase forecasts. It included two-way flows through interconnections outside NE to “bank” energy. Aside from the pending 1200-MW Hydro Quebec tie-line, the model included an additional tie-in from NY and Quebec.
  
• Alternatives were then explored to meet reliability requirements in the face of expected weather extremes and time-of-day limitations (on solar, in particular).
  
  The study’s authors explored alternatives to try and satisfy the reliability requirements while at the same time minimizing cost and curtailment conditions, in which renewables are generating more energy than can be consumed or stored for future use. Most significantly:
  
  • Scenario 3_P7 explored scaling renewables sufficient to meet reliability goals. It required doubling the amount of wind and solar over the base Scenario 3 case to 90 GW. There was also a relatively small amount of battery storage added. Analysis suggested that a large amount of generation curtailment would be expected at times when the renewables’ energy was not needed and storage was at capacity. Also, such a large increase in renewables would put an undue strain on the transmission system and require huge areas for wind and solar farms. 
  • The authors then examined the possibility of replacing part of this projected need for an increase of renewables with dispatchable (on-demand) power.  They came to the conclusion that reliability could be satisfied in a scenario where 19% of the otherwise required renewables were replaced by the equivalent of 3% of dispatchable resources. Today’s dispatchable resources are almost all fossil-fuel based, but possible future alternatives include green hydrogen, small modular nuclear units, and co-located storage and renewables. This conclusion was considered to be one of the most significant findings of the study. However, note that the role of storage was largely ignored.
    
• The study’s authors acknowledged that the current set of modeling tools is inadequate to evaluate options for a grid of the future.
  
  In the authors’ own words: “The FGRS Phase 1 is a turning point study for our region. Many existing long-term assumptions were called into question as part of this analysis, and results show that the methods by which the ISO and region at large evaluate future grids require an overhaul. The hypothetical future resources and demand mixes assumed by the FGRS are very different from today’s system and cannot be fully evaluated with our current tools or assumptions. The FGRS identifies and quantifies many reliability and operation challenges, transmission problems, and ancillary services gaps. Additionally, this analysis identifies areas where gaps of a future grid cannot as of yet be identified or quantified in sufficient detail to suggest a potential path forward.”

Observations from the Fix-the-Grid-Technical Group

The FTG-Technical group believes that studies such as this are important. However, they are only as good as the tools with which they are modeled and the validity of the assumptions that they make.  

• A grid of the future will be heavily dependent on managing demand as well as large amounts of storage. 
  
  It is misleading at best and potentially harmful to come to conclusions about a pathway for a future grid largely composed of renewables if one cannot model demand response and large amounts of different types of storage. The FGRS authors acknowledge these limitations. We look forward to next-generation modeling tools for ISO-NE planners and caution that policy makers should not draw premature conclusions from this study.
  
•  Other studies have come to different conclusions about the ability of 100% renewable systems to be reliable.
  
  • A study from Stanford, which has been examined by the FTG-Technical group, has come to the conclusion that a reliable grid throughout the US is possible with 100% renewables.  One of the significant differences between the Stanford study and the FRGS study is the use of green hydrogen for long-term storage in the Stanford study.
    
  • A recent white paper from a California energy company showed through modeling that providing all-renewable energy 99 percent of the time could meet hourly demand in its region. It concluded that the cost of doing so added minimal to no cost compared to matching demand with renewable power supply on an annual basis. Although there are clear regional differences between NE and California, it is still puzzling that the FGRS study concluded that a doubling of renewable capacity over nameplate capacity was needed to meet reliability.
    
• We need to think outside the box and question the assumptions that large increases in electricity demand are inevitable and that current standards for reliability are appropriate for a future of weather extremes.
  
  The US has one of the largest amounts of energy use per capita in the world. The US uses five times the energy per capita as Uruguay, which has succeeded in building close to a 100% renewable grid (see NYT article). It is time that our politicians and regulating authorities talk about reducing overall demand as well as shifting demand away from peak times. The tendency so far is simply to plan for meeting increased demand with increased generation. As for reliability, does it make sense to emphasize the objective of building a grid to achieve less than 2.4 hours of anticipated downtime annually when a much bigger problem is extreme weather events that are happening at an ever-more rapid pace that bring parts of the grid down for extended periods?
  
• We are facing a full-blown climate emergency and our grid-planning authorities should act accordingly.
  
  The “deep decarbonization” scenario for 2040 that became the focus of this study still emits 13.2 million tons of CO2 in New England annually. Phase 2 of the study should address the latest state policies, and Massachusetts, for example, includes a 2050 limit for electricity generation that is a 93% emissions reduction rather than an 80% reduction from 1990 levels. We will continue to monitor these studies.

The post Takeaways from the ISO-NE Future Grid Reliability Study: Phase 1 appeared first on Fix the Grid.

[read the full letter]

The post Open Letter to NE Governors and NESCOE representatives regarding FERC Winter Reliability Forum appeared first on Fix the Grid.

The post FTG advocates loud and clear at ISO-NE Consumer Liaison Group Meeting in Peabody appeared first on Fix the Grid.

No ‘silver bullet’: Report lays out fixes for interconnection delays plaguing US renewables and storage 5/25/23 Utility Dive Brief by Stephen Singer. The non-profit Clean Energy Group sponsored a study by Applied Economics Clinic outlining the interconnection problem and concluding that: 

• “policymakers need to establish interconnection processes to ‘take a systemic view’ of applications rather than examine interconnection applications and grid upgrades” on a case-by-case basis.
• “utilities, state officials, grid operators and the Federal Energy Regulatory Commission should iterate interconnection processes to ‘build in regular improvements, examine effectiveness, and coordinate stakeholders to tackle ad hoc coordination problems.’”
• “end the model of cost allocation for grid upgrades known as cost causation by spreading distribution system upgrade costs over a broader set of stakeholders than the projects applying for interconnection”
• “study proposed storage resources in a way that reflects how the resources would reasonably be expected to operate once interconnected.”

The generators who cry ‘wolf’: How competitive wholesale markets handle generator bankruptcy 5/24/23 Utility Dive Opinion by Mike Hogan. “During the recent Winter Storm Elliott, a shockingly large amount of generation receiving capacity payments from PJM and ISO New England failed to perform when called upon. Nearly all of it was fossil-fueled, most of it fueled with natural gas. Under the pay-for-performance arrangements established years ago following a similarly dismal performance during 2014’s ‘Polar Vortex,’ under which these generators have collected hundreds of millions of dollars a year to be reliable capacity, they face steep financial penalties for their failure to perform. Now some are seeking to evade those penalties, offering a flurry of excuses… Regardless of the validity of any of the excuses offered (or lack thereof), these generators are also attempting to fall back on the stratagem behind which the fossil industry customarily retreats when caught with their pants down — claiming a threat to reliability, in this case from the possibility that the penalties might drive some generators into bankruptcy… Recent history demonstrates this tired grandstanding about reliability should receive no weight in considering their appeals (or in considering changes to the market rules). Why? Bankruptcy rarely leads to a loss of the associated capacity, in fact, quite the opposite…”

Mass. agency dismisses 2 battery storage projects, citing lack of legal clarity over ‘generating facility’ 5/23/23 Utility Dive Brief by Stephen Singer. MA DPU will review proposals for two battery energy storage systems after – with prodding by local interest groups – MA’s Energy Facilities Siting Board couldn’t determine whether it had the jurisdiction to do so. 

Federal judge dismisses whale case, upholds permits for offshore Vineyard Wind project 5/23/23 Utility Dive piece by Diana DiGangi. “Judge Indira Talwani of the District of Massachusetts ruled Wednesday that the advocacy group Nantucket Residents Against Turbines failed to demonstrate that the wellbeing of the endangered species wasn’t sufficiently taken into account by the Bureau of Ocean Energy Management and National Marine Fisheries Service when permitting the project… The project currently faces three other lawsuits, with two of them representing the interests of the fishing industry.”

The post No silver bullet for interconnection woes, generators play the bankruptcy card, and more appeared first on Fix the 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 regions or countries that have actually succeeded in building close to 100% renewable grids such as Uruguay. (See recent New York Times Magazine article and podcast.) The second is academic studies that have modeled, in considerable detail, 100% renewable energy systems. (See Breyer et al., “On the History and Future of 100% Renewable Energy Systems Research.”) The article by Jacobson et al. that we summarize here is an excellent example from a burgeoning field of research showing that 100% renewable energy systems are not only possible, but can be as reliable, cheaper, and of course healthier for the planet and all its living inhabitants than fossil-fuel-based energy.  The Jacobson study directly addresses the issue of grid stability (reliability) in the US for a 100% renewable energy system for electricity, transportation, heating, and industry. The methodology uses a tool that models meeting projected demand without blackouts throughout the US in variable weather and compares business as usual with a 100% renewable+storage energy system.  The analyses include electricity use, total energy demand, costs, payback periods, and land use, showing that a 100% renewable energy system is the clear choice.

Study Summary

Goal and constraints

• • Electrify everything: industrial heat, long-distance trucking, ships, aviation, etc.

• • All power comes from wind + water + solar (WWS) with storage.

• • Demand response (e.g., delay 85% of EV charging and 70% of industrial heat to avoid peaks)

• • No blackouts; meet continuous load every 30 seconds

• • No new hydro generation; small amount of tidal and wave power; some new pumped hydro storage. No imports from Hydro Quebec, etc. No nuclear fission or fusion.

Findings

• • Electrification halves (-57%) total energy use but doubles (+103%) electricity use compared to Business as Usual (BAU).  96% of WWS energy would come from solar and wind.

• • Interconnecting regions increases long-distance transmission costs, but reduces total energy costs by reducing storage and excess generation capacity; also reduces land requirements. 

• • The upfront capital cost of transition of 50 states is $8.9 trillion if the lower 48 states are well-interconnected and $11.0 trillion if the 50 states are divided into eight isolated grids. 

• • Battery storage systems with 4-hour duration (MWh energy/ MW peak discharge rate) are adequate.  Batteries with 8-h to 62-h storage may match demand better and be more cost-effective.

• • WWS plan could create 4.7 million long-term net jobs. 

• • WWS plan would save 53,200 deaths from air pollution in US and millions of illnesses a year.

Financials

• • The time to pay back the cost of the WWS system is the capital cost of the new WWS system divided by the difference between the WWS and Business as Usual (BAU) annual cost.  Cost may represent only the private cost (fuel, maintenance, cost of financing, etc) or total social cost (private cost + climate and health impacts).

• • The time to pay back the cost of the infrastructure needed for the USA due to private cost savings from WWS is 5.7 years. 

• • The payback time due to social cost savings (including health and climate) is 1.5 years.

• • WWS energy use is less than half that of BAU.  Also, WWS costs less per kWh than BAU.  Thus, total energy system costs are much lower for WWS than BAU.

Land use

• • Footprint area of new utility photovoltaic (PV) & concentrating solar thermal power (CSP) generators would need 0.29% of US land.

• • Spacing area for new onshore wind turbines would need 0.55% of US land but some spacing area can be used for utility PV, reducing total land use

• • Total area needed for footprint plus spacing is 0.84% of U.S. land or less. For comparison, ~1.3% of U.S. land today is used by the fossil fuel industry.

• • Footprint and spacing in MA are 2.25 and 2.03%; in ME, 0.18 and 0.07%.

Conclusion

• • WWS + storage is technically feasible by 2035

• • It would cost $10T, but that’s less than Business as Usual (BAU)

• • It would take a lot of land and a doubling of electrical infrastructure

New technologies (not included in the report) such as long-duration storage, small modular reactors, or fusion would give more options to improve cost, land use, resilience, etc. 

Comments from Fix-the-Grid Technical Group

A key finding of this study relevant to ISO-NE future planning is that a reliable grid is possible by 2035 without fossil fuels. How this is accomplished is by, essentially, building sufficient renewable energy generation capacity along with storage and transmission to be able to meet all projected peak demand periods. Renewable energy generation that is not needed to service immediate demand can be stored in some form for future use. The study looked primarily at ramping up battery storage requirements since permitting and building additional pumped hydro and hydro storage may be more difficult. They found that concatenated 4-hour storage batteries, technically feasible today, supplemented by hydrogen storage, would be able to meet the requirements. 

The transition to all-renewables might be considered expensive, but the payback period, including health and environmental costs, is just 1.5 years according to this study.  And ongoing costs are radically less than business as usual, which is today’s mix of fossil fuel generators, nuclear, and limited renewables.  

The major obstacles to accomplishing the needed tasks to achieve the vision of the Jacobson study are (1) political will and (2) bureaucracy and cost related to siting and interconnection of generation and transmission equipment. These significant challenges were not covered in the study.

Limitations of this study acknowledged by the authors include an assumption of a perfectly interconnected transmission system in each region.  Another is some uncertainty about the weather model–whether it is representative of the real world up to 2050 and whether it captures extreme weather events. All modeling has limitations, but the growing body of research of which this study is a part is showing that renewable energy advocates should not accept the dogma that fossil fuels and/or nuclear are necessary into the foreseeable future for a stable grid.

References

Mark Z. Jacobson, Anna-Katharina von Krauland, Stephen J. Coughlin, Frances C. Palmer, Miles M. Smith (2022) “Zero air pollution and zero carbon from all energy at low cost and without blackouts in variable weather throughout the U.S. with 100% wind-water-solar and storage,” Renewable Energy 184:430-442. Download.

Image by tawatchai07 on Freepik

The post Takeaways from the Jacobson Stanford Study on a 100% Renewable Grid appeared first on Fix the Grid.

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 2040 over 1990 levels. The study is about what pathways would cost the least to get to the desired outcome, and  examines complications and market distortions that could result. It also examines the implications for region-wide coordination among the New England states for implementation of each pathway. The final Pathways report was delivered in April 2022, and it is currently being evaluated by NEPOOL, the NE states, and others. Comments have been submitted by the power industry and some environmental groups. Materials are available through the ISO-NE Future Grid Initiative .

Advocacy groups should understand this study since it is likely to be used as a rationale for proposed market changes by ISO-NE going forward. It is vital to recognize the larger context and also any limitations and questionable assumptions in order to provide input to decision makers for the grid of the future in New England.  After study and discussions, the Fix-the-Grid Technical Committee concluded that the study was limited by its failure to take environmental justice and the social and environmental costs of carbon fully into account and by its omission of the role of limiting demand and energy storage in the grid of the future. We also found that issues with carbon pricing, the solution favored by the study, were not acknowledged. Further, there were open questions about the proposal for a new clean energy market, and the process of how to use studies like this in ISO-NE lacks transparency and public participation.

Study Summary

The study examined four pathways and came to the following conclusions about each. Comments from other organizations are summarized in italics.

1. 1. Status Quo: The NE states continue independently to fund renewable energy development by funding power purchase agreements with clean energy developers. This was found to be the most expensive of the alternatives, largely because it is dependent upon uncoordinated administrative processes in each of the states and does not necessarily incentivize the least costly alternatives at the appropriate time.

       

      • • A comment by Advanced Energy Economy noted that the study makes the questionable assumption that the mix of purchasing agreements will not change going forward. Changes could easily affect the outcome.
      • • Other clean energy advocates also question the conclusion that this pathway is necessarily the most expensive. Also, among the alternatives, it would require the fewest changes and negotiations among the states.

1. 1. Forward Clean Energy Market: A new centralized market is proposed for tradeable clean energy certificates for future energy. The conclusions were that this mechanism would be more efficient than the Status Quo but that it does not guarantee that new clean energy sources would displace fossil fuels.  It also would require a lot of work to set up. Lastly, it might result in negative energy prices, an inefficient market distortion, since some companies might make money by paying others to accept energy that the companies have already been paid to produce through energy certificates in advance.

       

      • • Many clean energy companies and environmental advocacy organizations did not find the warnings about negative prices convincing. 
      • • The New England States Committee on Electricity (NESCOE) has signaled interest in this option.
      • • There are many questions about how this new future energy market would relate to the existing capacity market.

1. 1. Carbon Pricing: The study found that this would be the cheapest pathway and the simplest to implement.

       

      • • Virtually all the fossil-fuel power companies who commented are in favor of this in part because some generation sources such as combined cycle natural gas would be incentivized over more carbon-intensive generation. 
      • • Some clean energy companies and environmental advocacy organizations objected to any further incentives for fossil-fuel-based generation.
      • • As noted below, carbon pricing has largely failed to date in the US because it is politically unpalatable.

1. 1. Hybrid: This pathway combines a version of the Forward Clean Energy Market (with the wrinkle that only new clean energy sources are eligible) with carbon pricing. The study concluded it would be less costly than all pathways except carbon pricing alone. This would likely be the most complex pathway to implement but combines the merits of carbon pricing (which increases market costs of electricity)  with a Forward Clean Energy Market (which decreases market costs).

       

      • • Some commented that excluding existing clean energy sources from the market would be inadvisable.
      • • NRG Energy fleshed out more details of this proposal in  “Straw Proposal for a Market-based Approach to New England’s Clean Energy Future”

Observations from the Fix-the-Grid Technical Group

We have questions and concerns about the scope and content of this report and the process of its roll out.

• • By design, this study evaluated alternative pathways for the future grid purely from an economic perspective rather than through a moral or environmental justice lens. This is a significant limitation.

     

    • • By not adequately accounting for the costs of near term fossil fuel use on the climate, not to mention the public health/environmental justice costs, this study underplays the benefit of earlier more aggressive decarbonization and the costs of continued delay. 
    • • Some overbuilding of renewable generation resources, though possibly not ideal in economic efficiency,  should be acknowledged as providing social and environmental benefits over the alternative of fossil-based peaker resources.

• • The study ignores the role of meeting decarbonization goals through limiting energy demand and underplays the role of storage.

     

    • • There is minimal consideration of conservation, time-of-use pricing, or demand response, though it is acknowledged that new rate structures and demand management could be useful in the future. 
    • • The report does not adequately consider the pace of future technology innovations including cost reductions that are particularly likely in energy storage such as iron-air and redox flow batteries.
    • • There is no direct linkage assumed between renewables and storage, which should be part and parcel of one form of reliable energy supply. Storage and dispatch of renewable energy could be tracked through the existing Generation Information System.

• • Issues with carbon pricing were ignored.

     

    • • The conclusion that carbon pricing alone is the most desirable pathway forward should be viewed skeptically since to date fossil fuel interests have been easily able to prevent carbon costs from rising commensurate with environmental and social costs by appealing to pocket book political issues. (See “The Trouble with Carbon Pricing.”) 
    • • It is no accident that comments from the fossil industry almost universally favored this proposal.

• • While some form of the forward clean energy market proposal may be worthy of our support, the study leaves many questions unanswered.

     

    • • Consistent with other organizations’ comments, we have questions about how a new forward clean energy auction would be conducted (in light of the challenges we see with the current capacity market structure).
    • • We also fail to understand how it would operate with existing capacity markets and how a centralized market could address EJ concerns, traditionally a purview of the states. 

• • The process of how this report will be used lacks transparency, and it is lacking in public participation. According to ISO-NE’s updated roadmap and their 2023 work plan, the goal is for the preferred pathway to be discussed and determined in 2023, followed by implementation.

     

    • • How can we be sure that the decision will not be made behind closed doors, that it will dispassionately consider interests other than fossil-fuel-based generation?
    • • How will the roles of ISO, NESCOE and NEPOOL  be weighted?
    • • How can the public be involved in the deliberations moving forward?
    • • How can the ISO be held accountable for their decisions? 

For additional thoughtful criticisms of the Pathways Study, we particularly recommend the comments by Advanced Energy Economy and from No Coal No Gas.

The post Takeaways from the ISO-NE Future Pathways Study appeared first on Fix the Grid.