PNGTS applies for Westbrook XPress Phase I pipeline project

An interstate natural gas pipeline system bringing gas from eastern Canada into Maine has asked U.S. regulators for approvals necessary for a project that would marginally increase the system's capacity to bring gas to Maine and the New England market.

At issue is Portland Natural Gas Transmission System (PNGTS), a pipeline that spans New England from the Canadian border to pipeline connections in New Hampshire, Maine, and Massachusetts. Its facilities include 142 miles of wholly-owned mainline from an interconnection with Trans-Québec & Maritimes Pipeline Inc. at the U.S./Canada border to Westbrook, Maine plus two laterals, as well as 101 miles of mainline from Westbrook to Dracut, Massachusets, which PNGTS owns jointly with another interstate pipeline, Maritimes & Northeast Pipeline, L.L.C. PNGTS operates pursuant to a number of federal approvals, including a certificate issued by the Federal Energy Regulatory Commission and a Presidential Permit authorizing its facilities for importing gas from (or exporting gas to) Canada.

On December 21, PNGTS applied to the Commission for authorization for Phase I its "Westbrook Xpress Project," which would increase the certificated capacity on the northern portion of its system from Pittsburg, New Hampshire, to Westbrook, Maine, by 42.482 million cubic feet per day (MMcf/d), effective November 1, 2019. The pipeline's application includes both public materials and materials that are protected against public disclosure as "controlled unclassified information", including privileged information and "critical energy infrastructure information."

In the public materials, PNGTS describes continued increased demand for natural gas: "Growing demand for natural gas for space heating, industrial processes and electric generation is driving a commensurate demand for incremental pipeline deliverability from abundant North American supply basins." PNGTS says its Westbrook XPress project "will provide access to, and allow for the transportation of, natural gas supplies from key North American supply basins such as Marcellus, Utica, and others" via Canadian pipelines. The company describes its Westbrook Xpress project is "a solution to meet this growing demand in areas of North America that have some of the highest residential gas prices in the winter." It envisions two distinct phases of the project: Phase I with an incremental 42.482 million cubic feet per day of certificated capacity, with an anticipated Phase II to bring an incremental 62.989 million cubic feet per day of capacity.

The Commission has docketed PNGTS's application for Phase I of the Westbrook XPress project as Docket No. CP19-32, and has issued public notice of the opportunity to intervene or comment through 5:00 pm Eastern Time on January 29, 2019.

US proposes offshore oil and gas leasing expansion

The Trump administration is taking steps that could ultimately lead to a significant expansion of U.S. outer continental shelf acreage available for oil and gas leasing.

Under federal law, the U.S. Bureau of Ocean Energy Management is charged with administering site leasing for energy development on the outer continental shelf. The Outer Continental Shelf Lands Act requires the Secretary of the Interior, through BOEM, to develop a five-year national plan for oil and gas sales in federal waters. The law requires the Secretary to balance criteria including environmental impacts, energy needs and resources, and adverse effects on the coastal zone.

On January 4, 2018, Secretary of the Interior Ryan Zinke announced a new Draft Proposed Program. He described its release as "an early step in a multi-year process to develop a final National OCS Program for 2019-2024," and as consistent with an April 2017 Executive Order implementing an "America-First Offshore Energy Strategy."

The Draft Proposed Program includes 47 potential lease sales -- the largest number of lease sales ever proposed for the National OCS Program’s 5-year lease schedule.  The plan includes 19 sales off Alaska, 7 in the Pacific Region, 12 in the Gulf of Mexico, and 9 in the Atlantic Region. Some of these areas have not seen leases sold in decades; for example, there have been no sales in the Atlantic since 1983 and there are no existing leases.

By contrast, the draft program includes 8 Atlantic lease sales between 2020 and 2024, covering federal waters offshore Maine, New Hampshire, Massachusetts, Connecticut, Rhode Island, New York, New Jersey, Delaware, Virginia, North Carolina, South Carolina, Georgia, and Florida. The Pacific leases would similarly be the first sold in that region since 1984.

According to the press release announcing the draft's release, "Inclusion of an area in the DPP is not a final indication that it will be included in the approved Program or offered in a lease sale, because many decision points still remain. By proposing to open these areas for consideration, the Secretary ensures that he will receive public input and analysis on all of the available OCS to better inform future decisions on the National OCS Program."

Even if an area is offered in a lease sale, it may not draw commercial interest; even if leased, an area might not actually be used for exploration and production. But the draft plan significantly expands the acreage that would be available for leasing -- according to the Secretary, "the current program puts 94 percent of the OCS off limits," while the proposed program "proposes to make over 90 percent of the total OCS acreage and more than 98 percent of undiscovered, technically recoverable oil and gas resources in federal offshore areas available to consider for future exploration and development."

BOEM has solicited public comment on the draft plan, which will inform several further rounds of proposals and comment, before a Proposed Final Program (PFP) is considered. In the meantime, until a new program is finalized and adopted, the present 2017-2022 Five Year Program remains in effect.

RGGI states propose tighter carbon budget

The nine states participating in the Regional Greenhouse Gas Initiative have announced consensus on proposed revisions to that program that would provide a further 30% reduction in the regional limit on emissions by 2030, relative to 2020 levels.  The proposed regional program changes are now available for stakeholder comment, after which each participating state will follow its own specific statutory and regulatory processes to propose updates to their own carbon dioxide budget trading programs.

Nine Northeast and Mid-Atlantic states -- Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont -- currently participate in RGGI, the first mandatory market-based regulatory program in the U.S. to reduce greenhouse gas emissions.  RGGI is composed of individual CO2 budget trading programs in each state, based on each state’s independent legal authority.  The program imposes an annual aggregate cap on greenhouse emissions from covered sources like fossil-fueled power plants in participating states.  For 2017, the cap is 84.3 million short tons (62.5 million short tons adjusted for banked allowances); it declines 2.5 percent each year until 2020.  Since 2008, participating states have reduced power sector carbon emissions by nearly 50 percent, while generating more than $2.7 billion in allowance auction proceeds for reinvestment in programs to benefit consumers.

RGGI participating states periodically conduct a "program review".  Following their 2012 Program Review, the RGGI states implemented a new 2014 RGGI cap of 91 million short tons -- 45 % below the prior 2014 cap of 165 million short tons. At that time, the participating states decided to commence the next program review no later than 2016.

RGGI's 2016 Program Review is ongoing.  According to an August 23, 2017 announcement, the participating states have reached consensus on proposed changes to the program design.  Proposed changes include a regional cap of 75,147,784 tons in 2021, which will decline by 2.275 million tons per year thereafter, resulting in a total 30% reduction in the regional cap from 2020 to 2030.  The proposed changes also include modifications to the existing Cost Containment Reserve and implementation of a new Emissions Containment Reserve which would add some flexibility to the cap size.

On behalf of participating states, RGGI, Inc. has announced a meeting on September 25 to gather stakeholder input.  According to the announcement, after reviewing stakeholder comments, conducting additional economic analysis, and updating materials, each participating state is expected to execute its own statutory and regulatory process to update its own carbon budget trading program.

Northern Pass files with NH SEC

The developer of the Northern Pass Transmission Project, a proposed high-voltage transmission line from Canada into New Hampshire, filed a formal application to New Hampshire regulators this week.

First proposed in 2009, the Northern Pass project would include about 190 miles of new direct current transmission lines and an AC-DC converter station.  Collectively, the project would be capable of importing over 1,000 megawatts of power from Canada into the New England electric grid.  Its formal sponsors are two companies affiliated under the Eversource family: Northern Pass Transmission LLC and Public Service Company of New Hampshire d/b/a Eversource Energy.

Early versions of proposal drew criticism and controversy over issues including siting, visual impacts, the potential use of eminent domain, and impacts to domestic renewable energy production.  After a series of public information meetings and other dialogue, Eversource released a revised route and plan in August 2015.

On October 19, Eversource announced that it had filed a formal application to the New Hampshire Site Evaluation Committee.  The Northern Pass Transmission application to the SEC is available on the project's website.  It describes a project cost estimate of $1.6 billion, and a capacity of 1,090 megawatts. 

The SEC was established by the state legislature for the review, approval, monitoring and enforcement of compliance in the planning, siting, construction and operation of energy facilities.  It includes members from the Public Utilities Commission, cabinet level commissioners, and two members of the public.  The SEC has jurisdiction to review applications for siting and construction of large-scale energy facilities and to issue a Certificate of Site and Facility enabling a project's development.  The process before the SEC is likely to play out through 2016.

NH regulation of solar PPAs, leases

If a solar energy company installs solar panels on its customers' roofs, and sells those customers the power they produce, will it be regulated like a public utility under state law?  A petition by Vivint Solar, Inc. has asked the New Hampshire Public Utilities Commission to declare that it will not regulate Vivint Solar as a public utility, competitive electric power supplier, or limited producer of electrical energy under state law.

Vivint Solar describes itself as the second largest installer of residential solar energy systems in the U.S. residential market, with approximately 42,000 residential customers and 274 megawatts of solar systems installed.  The company describes two primary business structures for residential solar projects: long-term power purchase agreements or PPAs, under which a customer agrees to purchase all of the power generated by a solar energy system installed on the customer’s rooftop; and solar leases, under which a customer leases the solar energy system which is installed at the customer’s site. In either case, the solar facilities are owned by Vivint Solar’s affiliates and financing parties to enable efficient use of tax benefits and low-to-no upfront costs for customers.

In its August 14, 2015 petition, Vivint Solar asked New Hampshire regulators for “regulatory clarity on how it may be regulated” if it enters the state to offer its PPAs and solar leases to New Hampshire customers. In particular, Vivint Solar argues that because it would not sell the electricity generated by its solar energy systems to the broad “public,” it is not a public utility under New Hampshire law. Vivint Solar also argues that its contractual relationship with residential customers is fundamentally different from the relationship between a competitive electric power suppliers and its customers, largely because Vivint Solar’s activity occurs on the customer’s side of the utility meter. The company  also asks the Commission to declare that it would not be a limited producer of electric energy, a kind of generator regulated lightly by the Commission. Vivint Solar also notes that its PPAs and solar leases promote New Hampshire’s goal of encouraging competition for retail access, and customer choice for more affordable electricity, as well as New Hampshire’s renewable portfolio standard and other clean energy policies.

The New Hampshire Public Utilities Commission has issued an Order of Notice in the case, with interventions due and a prehearing conference scheduled for early October.

NH explores electric grid modernization

New Hampshire regulators are considering whether and how to modernize the state’s electric grid. In a recently opened investigation, the New Hampshire Public Utilities Commission seeks to educate stakeholders about grid modernization and to explore to what extent that grid modernization is workable in New Hampshire.

Last year, the New Hampshire Office of Energy & Planning issued its 10-Year State Energy Strategy.  In that document, the administration called for "a more flexible and resilient electric grid to support new technologies, increase consumer participation in energy management, and fortify our resiliency in the face of price and supply volatility and extreme weather events."  The first step identified in the Energy Strategy was to open a PUC docket on grid modernization:

The electric grid is aging, and changing consumer use patterns, a new generation mix, and increased threats from severe weather events require a more modern system. The New Hampshire Public Utilities Commission should open a docket to determine how to advance grid modernization in the state. In light of the potential breadth of the topic, which could include dynamic pricing, better consumer access to technology, and even rethinking the role of utilities, an investigation or information ‐ gathering proceeding may be an appropriate first step. This less formal proceeding would give all stakeholders a chance to learn about grid modernization and could inform the specific areas that should be pursued within future dockets. This would allow the PUC and stakeholders to determine which approaches will benefit New Hampshire consumers, and when and how they should be implemented.

Earlier this summer, the New Hampshire legislature enacted House Bill 614, implementing the recommendations in the Energy Strategy.  As Governor Hassan noted in her signing statement, the bill requires the Public Utilities Commission to "begin a process focused on modernizing our electric grid to ensure that we are prepared for an innovative energy future and to set an electricity peak time reduction goal, which can help lower the high costs of producing electricity when demand is greatest."

That process is now underway.  The New Hampshire Public Utilities Commission opened its investigation by order dated July 30, 2015.  The Commission gave interested parties until September 17, 2015 to provide comment on the definition, or elements, of grid modernization that should be included in its investigation.  The Commission directed its staff to schedule a technical session following a review of comments submitted, and to develop a procedural schedule for the rest of the case.

NH conduit hydropower project approved

Federal regulators have determined that a proposed hydropower facility at a New Hampshire wastewater treatment plant can be built without a license, under a recently enacted law.  The Federal Energy Regulatory Commission staff has found that the Ammonoosuc Water Treatment Plant Hydroelectric Project proposed by the City of Berlin Water Works is a qualifying conduit hydropower facility under federal law.  Like other conduit projects, the Ammonoosuc project involves the addition of a turbine into an existing system of pipes and pressure reduction valves, and can create additional renewable energy with few incremental impacts.

Under the Federal Power Act, most hydropower projects in the U.S. require licensure by the Federal Energy Regulatory Commission.  But last year, Congress passed the Hydropower Regulatory Efficiency Act of 2013, easing the regulatory burden on projects.  That law exempts certain so-called "conduit" hydropower facilities from the licensing requirements of the Federal Power Act.  Conduit facilities generate electricity using only the hydroelectric potential of a non-federally owned conduit, such as a tunnel, canal, pipeline, aqueduct, flume, ditch, or similar manmade water conveyance that is operated for the distribution of water for agricultural, municipal, or industrial consumption, and is not primarily for the generation of electricity.  To qualify, conduit facilities must have an installed generating capacity that does not exceed 10 megawatts (MW), and must not have been licensed or exempted from the licensing requirements of Part I of the Federal Power Act on or before August 9, 2013.  The Federal Energy Regulatory Commission subsequently issued Order No. 800, updating its rules to conform to the newly streamlined process.

While qualifying conduit hydropower facilities are not required to be licensed or exempted by the Commission, developers of qualifying facilities must file a Notice of Intent to Construct a Qualifying Conduit Hydropower Facility with the Commission.  On August 28, 2014, the City of Berlin, New Hampshire's Water Works filed such a Notice of Intent.  The proposed Ammonoosuc Water Treatment Plant Hydroelectric Project would have an installed capacity of 21 kilowatts (kW) and would be located on the existing 16-inch-diameter raw water transmission main immediately upstream from the pressure-reducing valve for the City of Berlin's water treatment plant.  The project would have an estimated annual generating capacity of 85 megawatt-hours.

The newly streamlined process can work quickly.  On September 10, Federal Energy Regulatory Commission staff issued a preliminary determination that the proposal satisfies the requirements for a qualifying conduit hydropower facility, which is not required to be licensed or exempted from licensing.  The Commission then posted this preliminary determination for public comment for 45 days.

No public comments were received, so on October 31, Commission staff issued its written determination that the Ammonoosuc Water Treatment Plant Hydroelectric Project meets the qualifying criteria under section 30(a) of the Federal Power Act, and is not required to be licensed under Part I of the Federal Power Act.

With this finding in hand just 64 days after filing its application, the city water department can continue securing the remaining approvals necessary to develop the Ammonoosuc Water Treatment Plant Hydroelectric Project.  Securing a FERC hydropower license can be a major endeavor, so the streamlined regulatory treatment now available to qualifying conduit hydropower facilities can be a major advantage.  How many other water treatment plants and other conduit owners will follow the Berlin Water Works' path and develop their own hydroelectricity assets using this easier regulatory process?

EPA carbon rule: how it works

Last week, the U.S. Environmental Protection Agency issued a groundbreaking proposed rule to limit carbon emissions from power plants.  EPA's Clean Power Plan would require each state to develop a plan to limit the amount of carbon dioxide its power plants produce per unit of electricity generated.  By reducing the carbon intensity of electric generation, EPA projects that the Clean Power Plan would would achieve a 30 percent reduction in CO2 emission from the nation's power sector below CO2 emission levels in 2005, resulting in net climate and health benefits of $48 billion to $82 billion.  Importantly, the Clean Power Plan would rely on federal and state cooperation to achieve this goal.

Public Service of New Hampshire's Schiller Station, in Portsmouth, NH, can burn coal, oil, and wood chips.

EPA proposed the carbon rule pursuant to its authority under Section 111(d) of the Clean Air Act.  As with other Section 111(d) regulations, the Clean Power Plan relies on a combination of federal emission limits and state implementation plans.  First, EPA proposed state-specific carbon dioxide emission goals, stated as an emission rate of pounds of CO2 emitted per net megawatt-hour of electricity generated.  Second, EPA offered states guidelines for how to develop, submit, and implement their own plans to reach those emission goals.

At the federal level, EPA set a carbon emissions rate limit for each state based on the agency's evaluation of how much the state could feasibly reduce emissions by adopting the "best system of emission reduction", or BSER.  Effectively, EPA considered each state's portfolio of electricity generating resources as well as how hard it would be to reduce its carbon intensity.

At the state level, EPA expects each state to propose a plan based on a combination of four "building blocks" or types of measures:

• Reducing the carbon intensity of generation at individual affected fossil-fired electric generating units (or EGUs) through heat rate improvements
• Reducing emissions from the most carbon-intensive affected EGUs by substituting generation at those EGUs with generation from natural gas combined cycle power plants and other less carbon-intensive fossil-fired units
• Reducing emissions from affected EGUs by substituting generation at those EGUs with expanded low- or zero-carbon generation
• Reducing emissions from affected EGUs through demand-side energy efficiency measures 

State plans would be subject to EPA approval, based on their enforceability, ability to achieve emission performance, verifiability, and reporting process.  EPA suggested that states may develop collaborative multistate programs.  States may also incorporate existing CO2 emissions reduction programs such as the Regional Greenhouse Gas Initiative or California's carbon market into their plans.  Procedurally, EPA expects that states would submit their plans by June 30, 2016, for review and approval, with the possibility of a one-year extension of this deadline.

EPA is now taking public comment on its proposed Clean Power Plan rule for 120 days, and will hold public hearings on the proposal in July and August.  EPA projects that it would issue its final Clean Power Plan rule in June 2015.

New England Clean Power Link proposed

A developer of electric transmission lines has proposed a new line that would connect New England to Quebec.  The so-called New England Clean Power Link would run about 150 miles from the U.S.-Canadian border to Ludlow, Vermont.  While the line shares some features with other proposed ties to the Canadian power grid -- including its development team -- the New England Clean Power Link differs from prior proposals in several regards.

Demand for electricity in the northeastern United States, and in particular for renewable power, has led to interest in developing several transmission lines to Canada.  Provincial crown corporation Hydro-Quebec has many large hydroelectric dams, and continues to develop Quebec's rivers for power production.  Meanwhile, Newfoundland utility Nalcor is developing gigawatt-scale hydropower on the Churchill River in Labrador, with aims to export the power to eastern Canada and the U.S.

This relative surplus of Canadian hydropower has led developers to propose transmission lines connecting Quebec resources to New England consumers.  These lines include the Champlain-Hudson Power Express from Canada to New York City, and the Northern Pass from Canada into New Hampshire.

The $1.2 billion Clean Power Link would have a capacity of 1,000 megawatts, roughly equal to the size of a nuclear power plant.  Like previous proposals, the newly-proposed line is motivated by the perceived opportunity to sell Canadian power in New England.  The Clean Power Link also shares features in common with other proposals, in that it would be a high-voltage direct current or HVDC line.  Notably, it would also be developed and financed by TDI New England, a Blackstone Group subsidiary led by the team behind the Champlain-Hudson Power Express.

Like that line, it would run about 100 miles under Vermont's Lake Champlain.  South of the lake, the Clean Power Link proposal features lines buried underground.  This contrasts with the Northern Pass, whose traditional wires-on-towers architecture has drawn significant opposition in New Hampshire.

The Clean Power Link faces a regulatory process including environmental and energy permitting, and is also dependent on the market forces that motivated its proposal.  It is unclear whether any of the proposed transmission lines to Canada will actually be built, let alone which one.  For now, TDI aims to build the line and place it in service by 2019.

Northern Pass transmission line faces public hearings

A proposed high-voltage transmission line across the U.S.-Canada border in northern New Hampshire faces a series of public hearings this month.  The Northern Pass transmission line would provide an additional tie between Hydro-Quebec's electric grid and the New England grid, and would expand U.S. imports of electricity from Canada.

The project is proposed by Northern Pass Transmission LLC, an entity jointly owned by NU Transmission Ventures, Inc., a wholly-owned subsidiary of Northeast Utilities, a publicly held public utility holding company, and NSTAR Transmission Ventures, Inc., a wholly-owned subsidiary of NSTAR, a publicly held public utility holding company.

The project includes a high-voltage direct current or HVDC transmission line capable of transmitting up to 1,200 megawatts of power from Canada to the U.S. or from the U.S. to Canada.  45 miles of line would connect the northern HVDC converter terminal in Québec to the U.S.-Canada border into New Hampshire.  The line would extend south from the international border approximately 140 miles to an HVDC converter terminal that would be constructed in the city of Franklin, NH. 

Federal law governs the import and export of electricity.  To construct, operate, maintain, or connect an electric transmission facility crossing the borders of the United States, Northern Pass must first obtain a Presidential permit issued by the U.S. Department of Energy.  Under the National Environmental Policy Act, this approval requires the Department of Energy to consider the environmental impacts of granting the permit.

Since its unveiling in 2011, the Northern Pass project has provoked controversy.  The public has voiced concerns over the environmental and economic impacts of large-scale Canadian hydropower, the risk of private property being seized by the developer through eminent domain, and a route through New Hampshire's White Mountain National Forest and nearby mountains and woodlands.  In response, Northern Pass retooled its route, triggering a need to revise the project's environmental impact statement.  As part of that process, the Department of Energy has scheduled four additional scoping meetings in New Hampshire:

• Concord, NH, Grappone Conference Center, 70 Constitution Avenue, Monday, September 23, 2013, 6-9 p.m.;
• Plymouth, NH, Plymouth State University, Silver Center for the Arts, Hanaway Theater, 17 High Street, Tuesday, September 24, 2013, 5-8 p.m.;
• Whitefield, NH, Mountain View Grand Resort; Spa, Presidential Room, 101 Mountain View Road, Wednesday, September 25, 2013, 5-8 p.m.; and
• West Stewartstown, NH, The Outback Pub at The Spa Restaurant, 869 Washington Street, Thursday, September 26, 2013, 5-8 p.m.

Thousands of stakeholders attended the first round of scoping meetings in 2011, overwhelmingly expressing concerns about the project and its route.  While Northern Pass has made some efforts to address and accommodate these concerns, many - like New Hampshire Governor Maggie Hassan - continue to express concerns about the project's potential impacts on the White Mountain National Forest, as well as on New Hampshire's economy, environment, natural resources, communities and people.  This month's events may draw similar attendance to those in 2011 - the New Hampshire Congressional delegation has asked the U.S. Department of Energy to move the West Stewartstown meeting to Colebrook to accomodate more seating.  Public testimony at this month's scoping sessions will shape the Department of Energy's environmental review process, and may affect whether and how the line is eventually developed.

Study quantifies New England distributed generation, growth

Distributed generation – small-scale electric generation facilities installed at consumer sites – plays a growing role in the resource mix used to meet society’s needs. Typical distributed generation assets include solar photovoltaic panels and co-generation or combined heat and power units developed at homes and businesses. A study released yesterday found that distributed generation capacity in New England could roughly triple in the next decade – and that regional electric grid operator ISO New England Inc. needs to account for distributed generation in its planning.

As New England’s regional transmission organization, ISO New England plans for and coordinates the development of electric transmission infrastructure. In the past decade, New England ratepayers have spent approximately $5 billion on transmission additions and expansions. ISO New England’s 2012 Regional System Plan calls for the investment of another $6 billion in transmission projects in the coming years. As a result, regional transmission rates roughly tripled between 2006 and 2010, and continue to grow.

ISO New England’s plans are based on its forecasts of future system needs, including anticipated load growth and changes in the electric generation portfolio used to satisfy customer demand. But ISO New England may be underestimating the extent to which non-transmission alternatives like distributed generation can satisfy demand at a lower total cost than transmission line development. According to “Forecasting Distributed Generation Resources in New England: Distributed Generation Must Be Properly Accounted for in Regional System Planning”, prepared by Synapse Energy Economics Inc., ISO New England is significantly underestimating the current and potential distributed generation in New England, particularly with respect to solar photovoltaic resources.   According to Synapse, “This practice results in the ISO ignoring likely transmission and reliability benefits and overestimating electricity load—with ratepayers being asked to pay for larger, more expensive transmission upgrades than are needed.”

ISO New England predicts that about 800 MW of solar photovoltaic generation will be installed in New England by 2021, but excludes other types of distributed generation from its projection. But Synapse found that over 980 megawatts of distributed generation assets are already installed in the six New England states. By 2021, Synapse predicts that this could grow to over 2,855 MW based on existing policies and development trends.

Synapse Energy Economics, Inc., Forecasting Distributed Generation Resources in New England: Distributed Generation Must Be Properly Accounted for in Regional System Planning, at page 19.

State policies and the favorable economics of distributed generation projects are driving their adoption on a wider scale than in previous years.  For example, after exceeding its previous solar photovoltaic target, Massachusetts recently increased its target to 1,600 MW.  Renewable portfolio standards, net metering policies, and feed-in tariffs all contribute to the proliferation of distributed generation, as does a cost differential that makes natural gas-fired cogeneration more cost-effective than burning oil for heating and purchasing electricity in commercial and industrial applications.

Synapse’s report concludes, “It is essential that the ISO stop ignoring the impacts DG resources have on system planning—both their benefits and their challenges. This report provides a reasonable estimate of what the future holds for these resources and makes one thing very clear: assuming that these resources do not exist is unacceptable.”

Whether and how ISO New England and the states take distributed generation into account remains to be seen, but if the trends noted in the Synapse report play out to even a modest degree, non-transmission alternatives such as distributed generation may be able to limit further increases in regional transmission rates.

Assessing Hurricane Sandy's energy impacts

Yesterday Hurricane Sandy made landfall in New Jersey, but the magnitude of the storm meant that heavy winds, strong rains, and a powerful coastal storm surge affected a broad swath of the mid-Atlantic and northeastern parts of the United States.

One consequence of the storm is widespread power outages.  As of 8:00 AM yesterday, about 36,000 electricity customers had lost power in Connecticut, Delaware, New Jersey, New York, North Carolina, Rhode Island, and Virginia.  By 2:00 PM yesterday, outages were up to over 316,000, in the states listed above as well as in Maryland, Massachusetts, New Hampshire, and Pennsylvania.  At that time, New York had the most outages (105,089 customers, or about 1%), but New Hampshire was the hardest hit in terms of percentage affected (18,190 customers, or about 3%).  These reported outages came six hours before the storm officially made landfall, making outage numbers much higher today -- some reports indicating 8 million customers without power.

[Update: as of 9:00 AM this morning, the Department of Energy reports 8.1 million customers without electricity, including 62% of New Jersey, 31% of Connecticut, and 23% of Rhode Island.]

In addition to these power outages, some electricity generating facilities have shut down.  The U.S. Nuclear Regulatory Commission (NRC) reports three nuclear power units in the Northeastern United States had to shut down and two units reduced as a result of impacts from Hurricane Sandy.  Reasons range from water pump failure to encroaching high water to problems on the external power grid.

Another consequence of the storm is disruption to oil refineries.  By 1:00 PM yesterday, two mid-Atlantic refineries had closed, with four more shutting down part of their production.  In total, 1.1 million barrels per day of refining capacity had been disrupted due to the storm.

Today, as the storm has moved inland, crews are working hard to recover from the storm.  It is still early to assess the total damage from the storm, as well as whether its disruption to energy infrastructure will be temporary or longer-lasting.

NH renewable thermal energy standard

New Hampshire Governor John Lynch has signed a new law expanding the Granite State's renewable portfolio standard to cover thermal energy.

Avalanche Falls in the Flume Gorge, New Hampshire.

Since 2007, New Hampshire has required most electricity providers to source 23.8% of their electricity from renewable resources by 2025.  The state legislature recognized four classes of renewable resources, and prescribed gradual increases in each class's share of the total electricity served in the state.  Class I resources cover most new renewable electricity generating facilities installed after January 1, 2006.  Class II covers solar-generated electricity from facilities that began operation in 2006 or later.  Class III covers existing biomass systems up to 25 megawatts, and methane gas, predating 2006.  Class IV covers power produced by existing small hydroelectric facilities up to 5 MW that meet environmental protection standards.

Some of these electricity generating technologies, such as the combustion of biomass to power steam turbines, also produce significant amounts of heat.  Other technologies like solar hot water, wood pellet boilers, or geothermal heat pumps may not generate electricity, but can displace the use of fossil fuels that would otherwise be used for heating.  This useful thermal energy has not previously been covered by New Hampshire's renewable portfolio standard.  This means that people and businesses have not been able to create renewable energy certificates (RECs) by putting this thermal energy to productive use.  As a result, the efficient use of this thermal energy has not been incentivized as has the production of electricity from renewable resources.

Enacted by the New Hampshire Senate and House earlier this month, and signed by the governor yesterday, Senate Bill 218 (text available via the New Hampshire General Court website) expands New Hampshire's renewable portfolio standard to cover heat or thermal energy.  As of January 1, 2013, the useful heat produced by renewable power technologies can qualify to produce RECs which can be used to satisfy the renewables requirement.  While Class I thermal energy RECs have a lower price cap than Class I electrical RECs - $25 instead of $55 - the ability to produce and sell thermal RECs will enhance business opportunities to use steam or heat produced from renewable resources.

3 years of RGGI carbon market results

A report released this week by the Regional Greenhouse Gas Initiative (RGGI) shows that carbon dioxide emissions from power plants in RGGI member states fell by 23% over the program's first three years.

RGGI, the first major market-based greenhouse gas regulatory program in the United States, represents a cap-and-trade approach to reducing the emission of carbon dioxide and other greenhouse gases.  Ten states - Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island and Vermont - originally agreed to cap and reduce the greenhouse gas emissions of their electrical energy sectors by 10% by 2018.  (New Jersey subsequently withdrew from the compact effective January 1, 2012.)  RGGI's first three-year compliance period ran from January 1, 2009 through December 31, 2011.

This week's report documents the performance of the RGGI member states in reducing greenhouse gas emissions from the electricity sector.  According to the report, 97% of covered power plants - 206 out of 211 covered units - met program compliance obligations.  (Raw data on each plant's performance is available through the RGGI CO2 Allowance Tracking System, also known as COATS.)  Over the three-year period, annual CO2 emissions for the three-year period averaged 126 million short tons.  This represents a 23% reduction compared to 2006-2008. 

Part of the reduction may be attributed to increased state investment in energy efficiency as well as the economic slowdown.  However, CO2 emissions in the region decreased nearly ten times more than electricity consumption did: according to the U.S. Energy Information Administration, three-year average electricity consumption across the ten-state region experienced only a 2.4% decrease over the same time. This points to another significant trend in northeastern electricity markets: a shift away from coal to natural gas as the combustion fuel of choice for thermal power plants.

Pittsfield NH dam repowering project

As governments and businesses consider the hydroelectric potential of existing non-powered dams, competition is heating up to claim and evaluate the best sites.  Federal regulators yesterday resolved a conflict between two developers by awarding a preliminary permit to a developer interested in studying the feasibility of repowering or rebuilding hydroelectric energy production at an existing mill dam on the Suncook River in Pittsfield, New Hampshire.

Another former mill dam in the heart of a New England village: the Doughty Dam in North Berwick, Maine.

Yesterday's order by the Federal Energy Regulatory Commission (9-page PDF) granted a preliminary permit to KC Hydro LLC of New Hampshire to study the feasibility of the Pittsfield Mill Dam Hydropower Project.  Originally built for industrial purposes, the Pittsfield Mill Dam is currently owned by the New Hampshire Department of Environmental Services.

As described in KC Hydro's original permit application (11-page PDF), the project concept involved either restoring an existing but mothballed 415 kW turbine which previously operated under an exemption from licensing, or installing entirely new facilities (potentially with a 530 kW capacity) to capture the hydroelectric potential of the water already impounded behind the dam.

After KC Hydro submitted its preliminary permit, another developer - AMENICO Green Solutions, LLC - applied for a competing preliminary permit for the same site.  AMENICO proposed a similar project, which focused on restoring the existing 415 kW turbine.  AMENICO noted that it had property rights to the site, which it claimed KC Hydro did not.

Noting that the applications were comparable, FERC recited its standard for resolving the competing claims:

Staff has reviewed the applications and found no basis for concluding that either applicant’s plan is superior to the other. Neither applicant has presented a plan based on detailed studies or the results of agency consultation. Where the plans of the applicants are equally well adapted to develop, conserve, and utilize in the public interest the water resources of the region, the Commission will favor the applicant with the earliest application acceptance date.

Because KC Hydro had applied first, FERC awarded the preliminary permit to KC Hydro.  In doing so, FERC noted that a permit applicant is not required to have obtained all access rights to a project site as a condition of receiving a preliminary permit.  However, FERC did note that a preliminary permit does not grant a right of entry onto any lands, so a permittee must obtain any necessary authorizations and comply with any applicable laws and regulations to conduct any field studies.

With its preliminary permit in hand, KC Hydro now has 3 years to investigate the site and apply for a full project license.  Will the Pittsfield dam ultimately be repowered?

Securing solar panels against theft

As more solar panels are installed in remote locations, how can they be secured against theft?

New Hampshire's Swift River, along the Kancamagus Highway.

Between new, more efficient technologies and government incentive programs, people are installing solar photovoltaic panels at a much faster rate than in the past.  While most solar PV projects are being developed on industrial or commercial buildings or homes, remote or off-the-grid solar projects form a growing sector of the market.  This can be particularly cost-effective where traditional grid-based electricity would be cost-prohibitive to install.  For example, the National Park Service is using solar panels to power campground facilities in remote locations, as are state park units and other public land management agencies like the U.S. Forest Service.

Theft of these solar panels and related electric equipment may be a growing problem in some locations.  For example, the Manchester Union Leader reports that thieves stole a variety of equipment including solar panels, electrical panels, charge controllers, inverters and deep cycle batteries from Forest Service facilities along New Hampshire's Kancamagus Highway this past winter.  Along with associated vandalism, the damage and losses to the campground and visitor facilities in the White Mountain National Forest are reported to exceed $10,000.

For some years, electric utilities have faced similar challenges in the form of copper theft, where thieves steal wires and other electric equipment for its value as scrap metal.  As people, businesses and agencies other than utilities become distributed producers of electric energy, they are being exposed to the parallel risk of solar panel theft.  Securing solar energy equipment could take a variety of forms, from physical security (e.g. bolting the equipment down more securely) to monitoring, patrols, or electronic surveillance.  Adding more security to an installation may increase its costs somewhat, but may be a good investment for some situations compared to the risk of loss.

June 20, 2011 - hydrokinetic power

Flowing water contains large amounts of usable energy.  Beyond traditional dam-based hydroelectric generation, water’s power can be captured using hydrokinetic technology.  A hydrokinetic project generates electricity from moving water: the flow of tides, waves, ocean currents, or unimpounded rivers.  Most hydrokinetic projects will need regulatory approval from the Federal Energy Regulatory Commission, a process that is still evolving but is getting easier over time.

The Oyster River Dam in Durham, NH.

While humans have long recognized the power of moving water, cost-effective technologies for converting this power into electricity are still in their infancy.  The U.S.’s first federally-licensed hydrokinetic project was commissioned in 2009.  This project on the Mississippi River in Hastings, Minnesota features a 100 kW turbine mounted on a barge tethered in the output channel of an existing hydropower plant: the Army Corps of Engineers’ 4.4 MW Lock & Dam 2.  Under typical operating conditions, the Hastings project produces 35 kilowatts of power.

Technology continues to evolve rapidly, and each new design has to be tested.  Under limited circumstances, developers can test turbines without obtaining a FERC license.  In 2005, dealing with Verdant Power’s testing of underwater turbines in the East River in New York City, FERC ruled that a license is not required for a hydrokinetic project if the technology is experimental; the proposed facilities will be used for a short period for studies needed to seek a license; and the power generated from the test project will not be transmitted into, or displace power from, the electric grid.

This opportunity to test turbines without a license is limited.  Most hydrokinetic projects will need to get FERC approvals such as a preliminary permit, license, or exemption from licensing.  Tomorrow, I'll look at some of those paths toward developing and operating a renewable hydrokinetic energy project.

May 26, 2011 - NJ to withdraw from greenhouse gas compact

New Jersey Governor Chris Christie has announced that he will pull New Jersey out of the nation's leading regional greenhouse gas cap-and-trade program.

The Maine State House, seen on a recent day of legislative debate over energy policy.

Since 2007, New Jersey has participated in the Regional Greenhouse Gas Initiative.  RGGI is the first market-based greenhouse gas regulatory program in the United States.  RGGI represents a cooperative effort by Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island and Vermont.  These ten states agreed to cap and reduce their electrical energy sector's greenhouse gas emissions by 10% by 2018.

While each state's legislature implemented its own version of the compact, the overall structure is that carbon allowances are auctioned off to the power sector.  Proceeds from these auctions are invested in energy efficiency, renewable energy, and other clean energy technologies.  The program has been a success in creating jobs, reducing greenhouse gas emissions from the power sector, and funding high-yield energy efficiency projects at businesses.

If New Jersey withdraws from RGGI, it will be the first state to end its participation in the program.  Other states are considering whether to stay in the compact.  For example, New Hampshire recently considered the question, and the Maine Legislature's energy committee recently voted to support a bill to withdraw from RGGI if enough other states withdraw first.  Under LD 793 as amended, Maine would withdraw from RGGI if the total carbon dioxide emissions budget for remaining states is less than 35,000,000 tons.  While New Jersey's departure alone would not shrink the program below Maine's proposed threshold, it would represent the first concrete erosion of RGGI's base.

April 14, 2011 - Canadian hydro imports as renewable

What energy sources are renewable?  What does renewable mean?  Any state developing a renewable energy standard would be wise to consider these questions.  There is broad consensus on a core group of technologies, while the degree to which some other energy sources may be renewable remains a subject of debate.  When it comes to renewable portfolio standards - laws mandating that a certain portion of electricity sold be sourced from qualified renewable resources - it can take an act of the legislature to deem a particular resource type "renewable".

Wood pellets: biomass for homes, on display at a gas station.

The Nova Scotia Legislature is currently considering this very question.  The provincial minister of energy and natural resources proposed a bill to declare hydroelectricity "renewable electricity" by legislative mandate.  That bill, Bill No. 15 classifies hydroelectricity as renewable electricity, for the purpose of meeting Nova Scotia's 40% renewable electricity by 2020 goal.  Bill No. 15 would apply to hydroelectricity generated in Nova Scotia - there are about 40 small hydro plants in Nova Scotia, collectively supplying about 11% of provincial capacity - as well as to hydroelectricity produced elsewhere and imported into the province.

Many states and provinces are wrestling with the question of whether hydroelectricity imported from Canadian large-scale hydro projects should count towards their own renewable portfolio standards.  For many states in the northeastern US, importing hydroelectricity from Hydro-Quebec is one option; New Hampshire's review of the proposed Northern Pass transmission line raises these issues.  In Nova Scotia's case, the province is a partner in the Muskrat Falls portion of the Lower Churchill hydro resource in Labrador.  A 180-kilometer underwater cable called the Maritime Link will connect Labrador and Newfoundland with Nova Scotia.  Nova Scotia will put up 20% of the project capital, in exchange for which it will receive 170 megawatts of hydroelectricity for 35 years, with an option for an additional 330 megawatts.  The province expects this one project to account for a quarter of the province's 40% renewable mandate.

In this context, what does Bill No. 15 do?  By proposing to clarify that imported hydroelectricity counts toward the province's renewable energy standard, does the bill imply that it is not currently clear that hydro is renewable?  Or is Bill No. 15 simply part of the overall package of Nova Scotia's 40% renewable electricity mandate, helping clarify that Nova Scotia can rely on cost-effective regional resources in its pursuit of environmental goals?

April 11, 2011 - Northern Pass transmission

The Northern Pass project - a proposed high-voltage DC transmission line capable of sending about 1200 MW of power from Hydro-Quebec into New England - continues to be controversial.  The $1.1 billion line from the Canadian border has been proposed by Public Service of New Hampshire's parent Northeast Utilities, along with utility NSTAR and Hydro-Quebec.  These utilities promote the line as empowering New England markets to buy renewable power from Canada - primarily from Hydro-Quebec's nearly 40 gigawatts of hydro capacity.  Opponents raise concerns both about local siting issues related to the line - which runs through the White Mountain National Forest and a number of communities - as well as about the impact of importing gigawatts of Canadian renewable power on the development of renewable power projects in New England.

Now, two of New Hampshire's Congressional delegation, Senator Kelly Ayotte and Representative Charles Bass, have sent a letter to Secretary of Energy Chu expressing opposition to the project in its current form based on the public hearings that have been held.  They call on the Department of Energy to study alternatives to building towers along the Northern Pass's route through New Hampshire - alternatives like burying the lines or using existing rights-of-way.  The Congressional delegation points to a need to protect New Hampshire's north country lands as "prime economic assets and pristine landscapes."

If the Northern Pass project is to be developed, proponents may have to navigate the political waters as well as the regulatory process.