About 170 stakeholders turned out Thursday for ISO-NE’s teleconference review of the Phase One proposals in its Boston competitive transmission solicitation, overwhelming the Planning Advisory Committee’s phone line and forcing the RTO to open another connection with greater capacity.
The RTO on June 8 surprised many stakeholders — and elicited a swift legal challenge — when it announced that it had narrowed the 36 responses to its first competitive request for proposals under FERC Order 1000 to a single finalist, a $49 million project by incumbent utilities National Grid and Eversource Energy. (See National Grid, Eversource Finalist for Boston Tx Plan.)
ISO-NE Vice President of System Planning Robert Ethier prefaced the review with a defense of the RTO’s evaluation process.
“While the results of this process may be different than some people had hoped or maybe even expected, arriving at the least-cost solution that requires no transmission siting and very little permitting is, to me, a clear success,” he said.
Director of Transmission Planning Brent Oberlin “and his team did not operate in a vacuum,” Ethier said. “ISO management was kept well informed of the progress as we went along, having regular meetings with Brent and his team and certainly vetting each of the significant decisions along the way.”
Questions on Results, Methods
Seeking to extend its Mystic Generating Station cost-of-service contract for an additional year, Exelon on June 10 filed a complaint with FERC accusing the RTO of violating its Tariff by shortcutting its transmission security review and prematurely culling bids received in response to the solicitation. (See Exelon Challenges ISO-NE RFP in Bid to Extend Mystic.)
During the PAC meeting, stakeholders also questioned why certain proposals were rejected.
“I guess I was a little surprised, looking through this presentation, at how many of the proposals were eliminated just because of the right-of-way provision, and not meeting the reactive capability requirement,” said Abigail Krich, president of Boreas Renewables. “Both of those struck me as things that should have been pretty clear in the process, and the project proponents should have known whether their projects met the requirements.
“Given how many were screened out because they didn’t meet those, it raised the question in my mind whether this was confusion on their part; maybe these requirements weren’t made as clear as they could have been,” she continued. “Do you think a number of proposals that were submitted … that even though they didn’t meet the criteria, that they might still be able to move forward?”
“I can’t speak to what others were doing, but while we did have a number of proposals that tripped up on things, there were also some that did not,” Oberlin said. “As far as the instructions, we talked about the need for a dynamic reactive device at the PAC meeting; we provided it in the report; it was pretty clear what needed to be done at the POI [point of interconnection]. I don’t know why people didn’t do that.”
Among eight qualified transmission project sponsors that submitted bids for the RFP was Anbaric Development Partners, which made two submissions. The first was an AC project that would move 900 MW of electricity on two tri-core cables between the former Pilgrim station area in Plymouth, Mass., to the Mystic substation in Everett. The second was a proposal for a 1,200-MW HVDC cable bundle between the same two points.
The RTO disqualified Anbaric’s AC proposal for missing a required step-up transformer to accompany its static synchronous compensator (STATCOM).
“For the STATCOM, if the transformer is included in the proposal and not the model — and in my experience the majority of STATCOMs in the Eastern Interconnection are modeled without the transformer — it seems to me that this would be an easy question for a deficiency cure,” said Phil Tatro of EN Engineering, which worked with Anbaric on the proposal.
Tatro noted that the STATCOM was included in both the project’s one-line diagram and the switching station layout, both of which were a part of Anbaric’s publicly posted bid.
“This is a feasibility assessment at this stage, and even if you wanted a transformer modeled, it doesn’t seem necessary in a feasibility assessment,” Tatro said.
Oberlin replied that ISO-NE’s goal was to determine whether or not a proposal met the need identified and specified in the RFP’s addendum report.
The RTO found a number of proposals that included the necessary transformer or other equipment but nonetheless weren’t able to meet the requirement, he said.
“Additionally, we did look through the proposals, and there were a number of files that were supposed to be attached that describe all of the electrical equipment … and also we had a section on transformers, and the [transformer] wasn’t described there,” Oberlin said.
Technical and Legal Challenges
The RTO also disqualified proposals, including Anbaric’s, for planning to interconnect using the Mystic 8 terminal, saying that facility is engaged through May 31, 2024.
Regarding the use of the Mystic 8 terminal, Adam Hickman of transmission developer Transource New England suggested that the RTO might consider using a planned outage to accommodate a transmission solution.
“We do encourage the ISO to go back and look at those property and [transmission owner] facility use provisions,” said Theodore Paradise, Anbaric senior vice president for transmission strategy. “We do think that how the ISO came out conflicts with both section 2.05 of the TOA [Transmission Operating Agreement], which requires interconnection of facilities and in fact good-faith negotiations to be engaged in by any signatories to the TOA, but also Section 210 of the Federal Power Act.
“Twenty-two of 35 projects were disqualified on that basis, and it’s just hard to believe that, with all the successful, sophisticated bidders who have won projects across the country, so many got it wrong,” Paradise said. The $49 million proposal from the incumbents is “probably not the least expensive project for consumers when you look at things like avoided transmission upgrades, or impacts on the energy market. One of our projects is less than 30 cents/month on a retail bill for a project that does a lot to bring in zero-priced renewable energy and also to avoid over $600 million in additional system upgrades for state policies.”
Michael Macrae, energy analytics manager at Harvard University, referred to the “the absence of any sort of an environmental impact” being included in the RTO’s evaluation criteria. He quoted from a June 5 letter from Massachusetts’ two U.S. senators “that highlights this concern and raises the question about how the outcome here aligns with New England state goals.”
In their letter, Sens. Ed Markey and Elizabeth Warren, both Democrats, criticized the RTO’s planning process for listing “environmental impact” in the lowest priority category for the evaluation and noted that “public health impacts are not called out at all.” (See Mass. Senators to ISO-NE: Think Clean on Boston RFP.)
“As we laid out in the RFP itself that was issued in December 2019, we proposed a tiered approach to the evaluation of the proposals,” Oberlin said. “The environmental impacts would be considered as we got through evaluating each of the proposals; assuming that they had met the needs and were all cost competitive with each other, we were going to use that to separate the proposals.”
Several stakeholders asked about whether the RTO’s recommended project utilized a usually prohibited remedial action scheme — or special protection system (SPS).
Oberlin explained that the $49 million project did use an SPS as defined by the Northeast Power Coordinating Council, but that he expected that definition to change in the future. Asked whether any of the other reliability projects use such a scheme, he responded that they do not.
Steve Kerr of Exelon asked whether the proposed solution would meet the system needs and allow Exelon to retire Mystic if the New England Clean Energy Connect (NECEC) project designed to carry 1,200 MW of Canadian hydropower to Massachusetts is not built. ISO-NE counsel Kevin Flynn interrupted and directed Oberlin not to answer, saying the RTO “would not speculate.”
Paradise also noted that the ISO-NE final needs assessment from June 2019 shows additional needs without the NECEC line and said it was not speculation that the proposed solution does not meet the needs without that project moving forward. A public referendum on the NECEC project is planned in Maine in November.
ISO-NE requested that PAC members complete their review of the Phase One proposals report and send their comments to pacmatters@iso-ne.com by July 2. The RTO plans to post the final listing of qualifying Phase One proposals on or before July 17, Oberlin said.