The ISO working group of No Coal No Gas has been busy, and we’d like to share our latest update.
But first, JARGON ALERT! This list should help you navigate the acronyms:
The New England electrical grid is managed by an entity called the "Independent Systems Operator - New England, " which you'll usually see written as ISO-NE or ISO. There are other ISOs in some other regions of the country.
FERC is the Federal Energy Regulatory Commission and has regulatory/oversight responsibilities for ISO-NE (this means ISO-NE has to run big decisions past FERC). When we ask you to submit a comment, we’re usually asking you to send it to FERC.
In 1971, the New England Power Pool (NEPOOL) was formed to coordinate transmission planning and to achieve economic and reliability benefits through coordinated regional electrical grid management. This means that NEPOOL was actually the predecessor to ISO-NE.
In 2005, after FERC encouraged the creation of Regional Transmission Organizations (RTOs) to formally manage electrical grid operations/markets in multi-state areas, NEPOOL members, state officials and ISO-NE (which was a new organization at the time), turned over control of the regional grid management and market rules to ISO-NE.
Also in 2005: when FERC approved the establishment of ISO-NE as the official RTO for the region, FERC ALSO established NEPOOL as the official independent stakeholder advisory group of ISO-NE. This means that NEPOOL has standing at FERC, and if NEPOOL challenges ISO-NE's decisions, FERC considers the two positions as holding equal weight. We're told this is called the "jump ball" provision. In this way, NEPOOL has quite a bit of power to pressure ISO-NE to make better choices.
NEPOOL has over 500 member groups. As you'd expect, the cast of characters is heavily weighted toward legacy fossil fuel generators, enormous utility companies, and other industry groups that aren't committed to climate justice or energy justice. But consumer advocates, progressive research groups, and other advocacy groups, along with more and more companies trying to push the transition to renewables, efficiency, and storage are also represented.
It costs $500/year to join NEPOOL, and we aren't sure that our best position is within that system, but the No Coal No Gas ISO working group continues to build relationships with NEPOOL advisors and members. These relationships are helping us get access to and analysis of information about how the regional electrical grid is structured (in terms of markets and governance). All of this learning informs our strategic choices about how to move forward in this branch of the campaign.
Your ratepayer dollars fund NEPOOL. This year’s NEPOOL budget is over $3.5 million. You can read more about NEPOOL at nepool.com
With all of that background in mind, here's our latest update:
A number of officials with whom we've been in dialogue encouraged us to submit a comment to NEPOOL in advance of their summer meeting. We were assured that although we are not NEPOOL members, there is genuine interest among those members in what groups like ours have to say. NEPOOL and ISO-NE are at a sort of crossroads – a moment when they are pressed to make some decisions about the future of the regional electrical grid's market structure, which is currently based on market mechanisms in large part.
We had a lot to say, but we decided to narrow our comments in hopes of getting some focused response. We've received a few private messages encouraging us to continue to push, but there has been no official NEPOOL recognition that we even submitted a comment. We'll keep you posted.
June 20, 2022
RE: Pathways Study
By electronic mail: David Cavanaugh, NEPOOL Chair (dcavanaugh@ene.org); Christina Belew, NEPOOL Vice Chair (christina.belew@state.ma.us), Sebastian Lombardi, NEPOOL Counsel (slombardi@daypitney.com), Heather Hunt, NESCOE Executive Director (heatherhunt@nescoe.com), Eric Johnson, ISO Director of External Affairs (ejohnson@iso-ne.com)
The No Coal No Gas campaign (NCNG) appreciates the opportunity to share feedback about the Future Grid Pathways study with NEPOOL. We also appreciate the detailed feedback and questions already submitted by a number of NEPOOL member organizations about the Pathways study.
As a regional grassroots climate justice advocacy group representing over 1600 New England ratepayers, we feel a deep sense of urgency regarding the impacts of climate change on every aspect of our lives. Our feedback reflects the concerns of scores of other grassroots groups across the region who technically qualify as end-user groups, but lack the resources and capacity to join NEPOOL. Although we are not experts in generation, transmission, or market design, over the past several years we have worked to develop our understanding of the basic questions, challenges, and choices before ISO-NE, the states, and NEPOOL members.
We have come to appreciate the complexity of modeling potential pathways, and we believe that the Analysis Group has produced a report that achieves the task that was given to them. We have several concerns we want to raise for your consideration.
The phrase “climate change” is used only once, in the first sentence of the study (and the word “crisis” is never used). Although carbon pricing and decarbonization targets are addressed throughout, the realities of the climate crisis are not mentioned. The omission of an honest, factual description of the context driving this study, and the absence of any data about climate impacts and their social costs, tends to encourage readers to accept a slow, business-as-usual approach to grid management and transition pathways.
We have been told that 2030 would be an ambitious timeline for implementing any future grid pathway. We understand there are many complex factors contributing to a process that moves forward on “regulatory time.” However, the urgency of these times demands that we find ways to move beyond such constraints in order to act more quickly.
Now that the Future Pathways Study has been finalized and released, we are particularly concerned about how NEPOOL, the ISO and NESCOE will proceed with making a decision about which pathway to pursue. So far, our inquiries have left us confused and concerned about the decision-making process. The complexities of the ISO governance and accountability systems are difficult to understand. We want to know specifically how decision-making about grid transition will move forward.
We understand that the New England States will need to engage in consensus-building in order to select a pathway for regional grid transition. And we want to understand how that process will move forward.
We are asking for transparency and accountability in these ways.
For almost three years, the No Coal No Gas campaign has been organizing to shut-down Granite Shore Power’s Merrimack Station in Bow, NH – the last remaining coal-fired power plant in the region. The climate crisis has been the context for our campaign. Therefore, we have, at times, taken action beyond the familiar, comfortable and slow business-as-usual pathways. We are asking you to remember the context of the crisis and dare to consider bold and rapid pathways.
Sincerely,
Steven Botkin, on behalf of the No Coal No Gas campaign
SDBotkin@gmail.com
