Granite Shore Power Maintains Unique Position Despite Complex Regulatory and Financial Challenges

(Or, Ways we know this coal plant is on its way out)

According to an anonymous source with direct knowledge of Granite Shore Power (GSP) operations, Merrimack Station, the last coal-fired power plant in New England, is at risk of imminent closure. The source reports that, “the corporate board is having an emergency meeting very soon to figure out what to do,” adding that GSP “can't get the boiler to work.”

The boiler in question is part of GSP Merrimack’s MK1 generating unit, which is credited with 108 megawatts of generating capacity. Though it is unclear exactly how long GSP has been unable to reliably operate MK1, the power plant failed a mandatory stack test in February of 2023. Failure of such a test indicates excessive toxic emissions, an inability to run at 95% capacity, or both. According to the New Hampshire Department of Environmental Services, Merrimack Station has proceeded to illegally operate MK1 and the larger MK2 for a combined 505.5 hours in the year since the failed stack test. During this period, GSP planned a follow-up test on four different occasions, but abruptly cancelled each test on or just before the scheduled date.

“Deferred maintenance is kind of the name of the game at Merrimack Station,” stated a second source with direct knowledge of plant operations, who asked not to be named for fear of reprisal. “Nobody should be acting shocked that MK1 has deteriorated past the point of repair. This station hasn’t operated at full capacity for years, and since MK1 is the smaller generator, it basically never has to run. A stack test only has to be passed every three years if you stay compliant. Around Merrimack Station, a lot of things are falling apart, even the equipment that is used fairly regularly. So it’s been a long time since MK1’s been what I’d call properly functional.” However, in the year since failing the stack test, GSP has still received over $13 million in ratepayer-funded capacity payments intended to ensure that the plant’s full capacity is available during times of peak demand.

Now, however, Merrimack Station will be required to pass a stack test every quarter. The New Hampshire Department of Environmental Services (NHDES) sent sent Granite Shore Power an Administrative order on February 7, 2024, ordering a written narrative of the measures Granite Shore Power has taken since the first failed stack test, and requiring them to complete a stack test within 45 days. If the boiler remains inoperable, Merrimack Station will be unable to fire up to 95% capacity, as required to pass a stack test. This would subject the company to significant fines from NHDES.

This string of failures is something of a final straw for NHDES. For the past three years, Merrimack Station has been consistently out of compliance with both the Clean Air Act and the Clean Water Act. According to EPA data, three high priority violations (HPVs) of the Clean Air Act are presently unresolved. These are a mercury HPV first identified 8/12/2021, a visible emissions HPV first identified 5/5/2022, and a particulate matter HPV first identified 10/20/2023. EPA data on the Clean Water Act indicates that violations were found at Merrimack Station in 10 of the past 12 quarters, with discharge water pH levels too high or too low to meet the standards.

However, permit violations and test failures are far from the only indicators that coal is on its way out in Bow. Yet another anonymous source informed No Coal No Gas that Granite Shore Power is preemptively selling off major power plant equipment, in anticipation of closure. For example, GSP has already found a purchaser for its $450 million scrubber, which was installed in 2011. Nevertheless, New Hampshire ratepayers will continue to pay for this piece of equipment through 2027 via the “stranded cost recovery charge” in the distribution portion of their electric bills.

Despite shoring up their finances by offloading equipment costs onto ratepayers and acquiring  capacity contracts they cannot fulfill, GSP is also on rocky financial footing. Merrimack Station failed to secure forward capacity payments at ISO-NE’s Forward Capacity Auction 17, meaning it will not receive forward capacity payments to stay on the grid for the 2026-2027 season. While GSP could have chosen to re-enter Merrimack in the next Forward Capacity Auction, ISO-NE’s CEO Gordon Van Welie has indicated that this is not the case. At a public meeting in December, van Welie stated that “the coal facility has opted out of the capacity market going forward.” 

When Merrimack Station failed the forward capacity auction in 2023, multiple lawsuits were also pending—one over its water permit and another from their coal supplier. The lawsuit over water permits alleged that Merrimack Station regularly released high-temperature water into the Merrimack River, violating its permit. In the latter lawsuit, coal supplier Javelin Global Commodities sued Granite Shore Power for $8 million. Javelin claimed that GSP had accepted delivery of a large shipment of coal and then refused to pay. In the court documents, Javelin stated concern that Granite Shore Power was “financially insolvent” and incapable of providing payment.

As the lists of permit violations and indications of financial insolvency continue to grow, community pressure to shut down the coal plant also builds. The No Coal No Gas campaign has shown up at the plant, in the surrounding community, and at energy regulatory meetings, determined to shut down the polluting coal plant. “This is the story of a coal plant that is long past its expiration date,” said Preesha Chatterjee, a student at Bow High School. “Not only does Merrimack Station need to cease operations immediately, but they must be held responsible for the damage they’ve caused the community while violating clean air and water standards. If I went and dumped a bunch of trash into the Merrimack River, I’d have to pay a ticket for littering at minimum. So what consequences must Merrimack Station face for putting dangerous temperature and pH levels into the river? Or for putting more mercury into our air?”

“As a New England ratepayer, I’m determined to see a better future for Merrimack Station“ added Nastasia Lawton-Sticklor, a Fellow with the Climate Disobedience Center. “Each of these recent incidents makes it blatantly obvious that capacity payments are being used to prop up a failed, dangerous industry and to block the transition our electric grid needs. As the harms caused by Merrimack Station come to light, it’s my hope that Granite Shore Power will do what’s both right and reasonable – rapidly transitioning the site to solar or geothermal power with battery storage. In the meantime, the ratepayers of New England will continue building power to ensure a just transition – both in Bow and around the region. Merrimack Station is just the beginning. To prevent the failures we’ve seen in Bow from happening again, we need to transform the way our region’s energy markets are managed, starting with ISO New England’s forward capacity market.”

ABOUT

The No Coal No Gas Campaign formed in 2019 as a regional coalition of affinity groups, partner organizations, and individuals. We are a direct action campaign dedicated to ending the burning of fossil fuels in New England, beginning with coal. In 2022, we identified and elected 12 people to serve as the Coordinating Committee of the ISO New England Consumer Liaison Group. This mix of state consumer advocates, activists, and others are working hard to ensure ratepayers in the region receive accessible and accurate information about electricity markets and that their voices are heard. We build community in order to build power to ensure a just, democratic transition to the energy future New England needs.