Monday, February 18, 2019

IMAPP Pondering 4 Options for Incorporating Clean Energy in NE

By Rich Heidorn Jr.

AUBURNDALE, Mass. — Stakeholders are considering four proposals for making New England’s markets more accommodating to state clean-energy initiatives, including a carbon adder in the energy market, potential changes to the capacity market and a possible new “clean energy” market.

ISO-NE IMAPP clean energy

Doot | © RTO Insider

David T. Doot, counsel and secretary to the New England Power Pool, outlined the changes to about 200 attendees at the Northeast Energy and Commerce Association’s 2017 Renewable Energy Conference on March 6.

Doot said the four long-term proposals were narrowed from the 17 proposed over seven meetings of the Integrating Markets and Public Policy (IMAPP) initiative last year. Officials announced last month that IMAPP will suspend its monthly meetings until May to allow ISO-NE time to develop “a conceptual market approach” that could be implemented in the near term for “accommodate[ing] state-supported capacity resources while appropriately pricing other resources in the Forward Capacity Market.” The delay also will allow states time to analyze long-term proposals discussed to date and for them to hold “off-line” discussions with stakeholders. (See NEPOOL Extends IMAPP Timeline.)

“We at the moment are in a pause … because ISO-NE has said, ‘We have to give you something to deal with the here-and-now that we’re worried about,” Doot explained. “They’re going to come back with something for us to debate and digest in the May timeframe.”

Infancy or Unruly Teens?

ISO-NE IMAPP clean energy

O’Connor | © RTO Insider

Panel moderator David O’Connor, senior vice president for energy and clean technology at ML Strategies, set up the panel by describing IMAPP as a “work in progress,” adding that “by various metrics it could be described as yet being in its infancy.”

But Doot characterized the initiative as being in “the unruly teen years.”

“We’re well beyond our infancy at this point. … We get into this room [and] there’s a lot of people talking to each other, by each other, at each other — in varying levels of decibels depending on what exactly is going on.”


Doot said it was essential that New England stakeholders be proactive in developing a solution, noting that FERC has two cases pending before it challenging zero-emission credits for nuclear generators in NYISO and PJM.

“If we — NEPOOL or New England — don’t do something, FERC is going to do it. They will do something to us or for us. And I can predict with some degree of certainty that we won’t like it,” Doot said.

ISO-NE IMAPP clean energy

Gerwatowski | © RTO Insider

“So I think what we need to do is decide whether we’re going to take the opportunity in New England to establish how we want to change the marketplace in order to help the states achieve what they’re trying to achieve in a way that allows the rest of the market to function, or whether we’re going to have FERC tell us how they’re going to do it. Because what we currently have is not necessarily sustainable in the long term.”

Ron Gerwatowski, an energy and regulatory policy consultant, formerly with National Grid, agreed on the need to eliminate what he called the current “market schizophrenia.”

“Somebody’s going to take a meat ax to this if we don’t fix it on our own,” he said.

Four Proposals Explained

Doot said the proposed carbon adder would be included in energy offers and energy clearing prices and collected from carbon emitters under an allocation to be determined.

A second alternative, proposed by the Conservation Law Foundation, calls for a “Carbon-Integrated” Forward Capacity Market (FCM-C), under which a new ZEC market would be integrated with the FCM.

A third option, offered by RENEW Northeast and NextEra Energy, is a Forward Clean Energy Market (FCEM), a new forward market for new clean energy resources. As initially proposed, the FCEM would expand to include supports for existing renewable resources.

“We’ve been moving a little bit away from that in part because the price tag is so high,” Doot said. “What they’re now talking about is a capacity clean energy market just for new [resources] but that they would allow for support of existing resources through some form of carbon pricing.”

The fourth proposal is a two-tiered pricing construct, with the FCM clearing at one price for existing resources and a lower price for state-supported resources offered at below competitive prices, an effort to protect prices from being suppressed.

‘Civil War’

Gerwatowski said one challenge is that the states are not unified in their goals, referring to “somewhat of a civil war” between the northern and southern states.

ISO-NE IMAPP clean energy

Left to right: O’Connor, Norman, Doot, Krich, Kearns and Gerwatowski | © RTO Insider

“We have some uniformity among Connecticut, Rhode Island and Massachusetts … with respect to the very aggressive goals to reduce greenhouse gas emissions. We’re in a very different place, I think, in New Hampshire and Maine — and in Vermont it’s hard to read with the new administration coming in,” Gerwatowski said, referring to Republican Gov. Phil Scott, who replaced Democrat Peter Shumlin in January.

“If you’re in the southern states, anything that’s going to drive greenhouse gas reduction, even if it comes at some costs, is going to be something that should be under consideration,” he said, referring to carbon pricing and long-term contracts for renewables.

“They have a different perspective in the north. … They’re not quite as convinced that these are the right ways to go in designing the future. We’ve heard some of the states, like New Hampshire in particular, saying, ‘Look, you guys want to do something to raise prices in order to meet your goals, that’s OK. But I’m not paying for it.’”

Capacity Market Limitations

ISO-NE IMAPP clean energy

Krich | © RTO Insider

Abigail Krich, president of Boreas Renewables, said that while New England’s capacity market has provided price signals to encourage development of natural gas generators, it is insufficient for resources such as wind. Boreas worked on the FCEM proposal as a consultant to RENEW Northeast.

A combined cycle plant that wins a seven-year capacity contract at $7/kW-month can lock in almost 60% of its overnight capital costs, and a simple cycle turbine with the same contract would lock in 70% of its capital costs — both percentages high enough to secure financing, she said.

“A wind project, even if it’s actually more cost effective overall when you look at energy, capacity, [renewable energy credits], things like that … they can only lock in about 6% of their capital costs,” she said. “You can’t take 6% of your capital costs as locked-in revenues and go get financing for a project based on that.”

That, she said, is why long-term power purchase agreements are being sought for renewables. “We need these to be financeable projects,” she said.

ISO-NE IMAPP clean energy

Norman | © RTO Insider

Jon Norman, vice president of government and regulatory affairs for Brookfield Renewable, said the current capacity market was designed primarily to support conventional fossil generation and doesn’t address a growing gap in value recognition for existing sources of non-emitting generation, including hydropower and wind projects with expiring PPAs.

“At some point there needs to be a stable price signal” for existing clean resources, he said. “In the absence of that, you … end up over the long run cycling capital through and just putting it into new resources. And then old resources are either exporting somewhere else or they’re retiring. I don’t think that’s a good outcome.”

ISO-NE IMAPP clean energy

Kearns | © RTO Insider

Matt Kearns, chief development officer for Longroad Energy Partners, said that states have generally found long-term contracts the cheapest way to meet their renewable portfolio standards.

“We’ve seen the most consumer savings generated by these larger procurements. … The result has been to attract cheap capital and drive down the cost of the product to the consumer,” he said. “Sending a signal to the market for a 15-year contract, you tend to get very competitive, good results.”

What Would FERC Do?

Doot said that he has been asked whether FERC has the authority to approve market rules that incorporate carbon policy. The commission has scheduled a technical conference for May 1-2 on the energy and capacity markets in PJM, NYISO and ISO-NE.

Before President Trump’s election, Doot said, FERC was “begging us to come forward with something under our voluntary market structure that they can consider and potentially say yes to. Now, that was FERC before President Trump.”

After Trump? “There’s just no way of predicting,” Doot said.

Doot ended the session by returning to a question about how consumer advocates can ensure that ratepayers don’t “double pay” for carbon reductions through both an ISO-NE-wide carbon price and state initiatives such as renewable portfolio standards.

“The answer is ‘Show up.’ Because at the end of the day we have to come up with a solution. … If we don’t come up with a solution, I’m not sure you have an assurance that you aren’t double paying.

“It’s up to us — the marketplace — to help define how it is we’re going to address these challenges. If we don’t, the federal government and the state governments are going to do it, and I’m not sure that the marketplace is going to be happy with the outcome.”

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