By Michael Kuser and Rich Heidorn Jr.
New England’s public power utilities aren’t convinced that ISO-NE’s proposed two-tiered capacity auction is the best way to incorporate state clean energy procurements into the wholesale markets.
At FERC’s May 1-2 technical conference on state policies and wholesale markets, ISO-NE presented its Competitive Auctions with Subsidized Policy Resources (CASPR) proposal, which it said would incorporate state-mandated renewable generation while preventing oversupply and addressing objections to a regional carbon tax. (See ISO-NE Two-Tier Auction Proposal Gets FERC Airing.)
In post-conference comments filed with the commission, several major New England stakeholders indicated they were willing to consider the RTO’s plan.
The Massachusetts Department of Public Utilities said it “generally agrees” with the four objectives of the ISO-NE proposal: “(1) competitive capacity pricing; (2) accommodating the entry of state policy resources into the [Forward Capacity Market] over time; (3) avoiding cost shifts; and (4) a sustainable, market-based approach.”
The New England States Committee on Electricity (NESCOE) said it will provide analysis later this year “on a variety of mechanisms through which states could execute policy objectives,” including Path 4 long-term “achieve” proposals and near-term Path 2 “accommodate” proposals such as CASPR. “NESCOE will continue to work with ISO-NE, market participants and others to explore potential solutions that could improve upon the status quo,” NESCOE told FERC.
However, the RTO’s plan got a wary response from the Eastern New England Consumer-Owned Systems (ENECOS). “The history of New England’s Forward Capacity Market (FCM) has not been a happy one from the perspective of small, vertically integrated utilities,” the group wrote. “To suggest — as some have in the technical conference — that the answer to the ‘threat’ posed by the prospect of large-scale entry of variable-energy, renewable resources into the current centralized auction construct is to create yet another centralized auction construct [invites] extreme skepticism.”
The group said any solution “should be coupled with restoration of the right of self-supply for load-serving entities as a means of satisfying their share of regional capacity obligations.”
ENECOS said both Paths 1 and 3 are “preferable to the more structurally profound proposals — such as carbon ‘adders,’ or creation of yet another centralized capacity auction construct for ‘clean’ energy.”
The Northeast Public Power Association (NEPPA) also had doubts, saying “the capacity market construct is ill-equipped to achieve the policy outcomes FERC, states and consumers desire.”
“When ISO-New England announced the settlement creating the FCM, NEPPA members worked to ensure not-for-profit load-serving entities (LSEs) retained the right to use their own existing resources to meet their capacity obligations,” NEPPA said. “That negotiated benefit was lost when FERC approved the minimum offer price rule (MOPR), which suddenly made the FCM a mandatory construct. ISO-New England is now effectively the single buyer and single seller of wholesale electricity in the region.”
NEPPA also criticized the MOPR as a “flawed construct.” It attached to its comments a concurring opinion by former FERC Chair Norman Bay, a parting shot before his resignation in February in which he called MOPR “unsound in principle and unworkable in practice.” (See Bay Blasts MOPR on Way Out the Door.)
The MOPR would be applied only in the first of the auctions under CASPR. In the first stage, ISO-NE would clear the auction as it does today, applying the MOPR to new capacity offers to prevent price suppression. In the new second “substitution” auction, generators with retirement bids that cleared in the primary auction would transfer their obligations to subsidized new resources that did not clear because of the MOPR. Because the substitution auction will not use the MOPR, it will clear at lower prices than the primary auction, enabling existing resources to buy out their obligations at a lower cost in return for retiring, the RTO says.
CASPR arose out of the New England Power Pool’s Integrating Markets and Public Policy (IMAPP) initiative — a response to state officials’ concerns that consumers could face excessive costs if state renewable procurements were not incorporated into the capacity market and generators’ fears that out-of-market resources will suppress capacity prices. New England states are set to procure more than 3,600 MW of nameplate renewable generation.
Another proposal that arose from IMAPP is the Carbon-Linked Incentive for Policy Resources (CLIPR), proposed by Brookfield Renewable, the Conservation Law Foundation and NextEra Energy.
The “CLIPR Coalition” said long-term Path 4 proposals are preferable to interim Path 2 plans. It asked FERC to issue a policy statement directing the RTOs to submit “achieve” solutions to the commission in the near term and requiring them to file quarterly reports on their progress.
Under the CLIPR proposal, LSEs would pay state “policy” resources an energy price premium that would fluctuate based on the “marginal carbon intensity” of the dispatch, “a direct analog to the LMP but computed as lbs-CO2/MWh instead of $/MWh.”
The New England stakeholders also disagreed over how quickly the region must act and how involved FERC should be in the process.
State officials generally downplayed the urgency. NESCOE said “the overall level of state-sponsored clean energy procurements that have taken place or are expected in the near-term comprises a small percentage of installed resources on the system.” It also defended state sovereignty and urged the commission not to take “prescriptive action.”
The Massachusetts DPU noted that the states’ procurement of clean energy resources “will extend over many years.”
“There is no evidence to suggest the current market construct is causing any decrease in merchant investment,” said a joint filing by the Connecticut Department of Energy and Environmental Protection, Public Utilities Regulatory Authority and Office of Consumer Counsel. “On the contrary, New England has attracted a large amount of new investment over the last several years, including renewable generation.”
The New England Power Generators Association (NEPGA) sees it differently. “NEPGA believes that the wave of out-of-market resources beginning to crest in New England threatens the very viability of a competitive wholesale electricity market,” it said. “The need is urgent, with a necessary direct and swift response from FERC and the wholesale markets.”