Massachusetts DOER – RPS Advisory Group

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					               Massachusetts DOER – RPS Advisory Group
                          Thursday, April 27, 2000
           Facilitator: Dr. Jonathan Raab, Raab Associates, Ltd.

                              Meeting # 8: Summary
37 people attended the meeting, which began at 9:15 and concluded at 3:30.

Documents Distributed
Prior to Meeting:
1. Agenda for today’s meeting, Raab Associates, Ltd.
2. Meeting Summary of March 30th meeting, Raab Associates, Ltd.
3. “Massachusetts Renewables Portfolio Standard, Analysis of Costs & Impacts”,
    Douglas C. Smith, et al. (3/21/00)
4. White Paper # 9: “Evaluation Methodology”, Wiser, Ryan et al.

At the Meeting:
Overhead slide presentations:
1.     “Existing Renewable Supply/Demand”, Douglas Smith (La Capra Assoc.)
2.     “Massachusetts RPS Preliminary Design”, Nils Bolgen (DOER)

Administrative Matters

   1.      There was one correction to the March 30th Meeting Summary: p.3, first bullet
           under “Accounting for Losses” – change “contested area” to “congested area.”

Existing Renewable Supply/Demand
Doug Smith from La Capra Associates reviewed draft analysis on the projections of
existing renewable supply vs. demand thru 2020 in New England. He looked at the
demand from the RPS requirements in MA, CT, and ME and also made some projections
regarding additional demands from green marketing. On the supply side he included all
potentially qualifying renewables, including all hydro and biomass. According to La
Capra’s analysis, demand is not projected to exceed supply for approximately 12 years
when estimated green demand is included, and approximately 16 years with all the RPS
requirements but assuming no additional green demand.

[Note: It was discovered during the course of the presentation that some of the supporting
tables were not the ones that matched the graph. Corrected slides were distributed via
email the day after the meeting.]

Group members asked numerous questions, and made some observations and requests for
additional data documented below:

        HQ sales may be higher than shown. Numbers do not appear to include HQ sales
         to NY that are passed thru to New England. Figures need to be checked.
        Imports may be more 8 or 9 million MWh.
        Do the renewable facilities’ licenses last beyond their contract period?
        The Maine Standard for eligible hydro is under 100 MW
        Did you estimate the price premium that might be anticipated over time based on
         your projections of the supply and demand balance over time. [Answer: not yet.]

At the close of the discussion, numerous Group members requested that La Capra run
other scenarios and sensitivities on the data, including:

1.       Alternative hydro assumptions:
            a. Leave out “large” hydro
            b. Leave in only “low impact” hydro
            c. Leave in only hydro that can be considered “daily cycle hydro”
2.       Alternative Biomass assumptions
3.       Do sensitivity analyses on the following 3 variables:
            a. Attrition
            b. Green demand
            c. Going forward operation costs

La Capra agreed to make some additional runs, and try and distribute the output prior to
the next meeting. (Please contact Jonathan Raab immediately if you feel that
anything was left off the list of scenarios and sensitivities.)

DOER’s Preliminary RPS Design
Following opening remarks by Commissioner David O’Conner, Nils Bolgen spent the
rest of the day stepping the Group through DOER’s preliminary RPS design [see handout
for description of DOER’s recommendations]. After each major topic, the Group asked
clarifying questions and then provided DOER with some initial feedback. These
questions and comments are captured below, organized by topic.


        Some of the DISCO’s have standard offer contracts through 2004 or 2005. How
         will they comply, specifically how will DISCO’s stockholders be sheltered from
         any cost increases caused by meeting the RPS?
        Compliance with the RPS will be mandatory for all suppliers, but will be
         voluntary for generators (i.e., generators who want to be eligible for selling RECs
         will need to comply with DOER’s requirements).
        Change “owner of any generation” to “owner, operator, or holder of contract for

      Would it be unfair for munis to be able to sell RECs but not have to buy RECs?
       Perhaps you need to require reciprocity to make sure accounting system clears
       (i.e., RECs are associated with equivalent amount of power sold to non-muni MA


       Existing Renewables:
      DOER probably can’t design standards for existing renewables that adequately
       protects those in need of protection (i.e., the higher priced renewables).
      Maine’s inclusion of existing renewables, at a minimum had a psychological
      If no great cost to consumers, then why not include requirements for existing
      If there’s attrition of existing renewables, let new renewables replace them.
      Even if there’s not a lot of activity related to existing renewables in the short run,
       it would still be useful to have a standard for existing renewables at least to clarify
       the standards (e.g., for biomass).
      If DOER holds off on implementing a standard for existing renewables, it should
       use the questions identified on slide #12 to monitor the market.
      Not implementing a standard for existing renewables now can impact the green
       market, perhaps making it more meaningful and more environmentally beneficial
       by accelerating adoption of new renewables by green marketers.
      DOER shouldn’t give up on trying to design meaningful requirements for existing
      If DOER limits hyrdo eligibility could lead to a more meaningful RPS for existing
      DOER should have the authority to restrict hydro based on market power issues.
       One option would be to not allow any generator to control more than 35% of the
       RECs; 55% for 3 generators; and 75% for top 5 generators. [Others asked whether
       DOER had the authority to address market power issues.]

   Early Start Trigger:
    Will early compliance complicate things for those coming on-line in 2003 by
      reducing the price they could get for their RECs?

   Eligibility for New Renewables:
    It will be challenging to figure out the renewable content of dual fuels. Maybe
       put onus on owner to demonstrate amount of renewables actually used.
    DOER should also look at capacity expansion (i.e. MW) in addition to increased
       energy production (MWh).

Generator Eligibility:

       Biomass and Landfill Gas:
      What does DOER mean for biomass by “most recent MA air quality permit?”

   How does DOER propose to treat out-of-state biomass plants built between 1997
    and today? Should it apply 1997 or current MA BACT standard? Is this
    differential treatment with in-state facilities?
   Another approach for biomass is to have DEP do a BACT analysis now and put
    numbers in the regulations, given that the Pinetree facility, which was DEP’s last
    biomass BACT analysis is nearly a decade old.
   Pipelines probably won’t take landfill gas, so DOER should only include landfill
    gas that is converted to electricity on-site or is transported by a dedicated pipe to
    an electricity plant nearby.

   Be consistent with transmission tariffs.
   RECs created either at the plant or at the border to New England would need to be
    derated for distance.
   What’s an adequate demonstration that a supplier in MA made a purchase? What
    if anything beyond just buying the credits?
   It could be a chilling problem if every REC from an import needs to show a
    bilateral contract to prove that the power came into New England.
   Interstate commerce could allow restrictions on imports if good policy rationale.
    DOER needs to do a comprehensive legal analysis of the issue.
   DOER should consider issuing credits to generators, only to those states outside
    New England where credits have value (i.e., reciprocity where the other states
    also have an RPS or certificate systems).
   Generators need to demonstrate sales not suppliers.
   At least 2 other states have put some restrictions on imports.
   DOER should just limit imports to contiguous states and provinces.
   Restrict imports to only those places with comparable comprehensive GIS
    (generation information system) [to the one that ISO-NE may eventually have in
    place]. Make sure that exporting state treats energy as null energy once RECs are
   Make sure generators in exporting states can’t resell energy as renewables again
    once sold RECs as a contractual matter.

Customer-Owned Generation:
 Attendees were unanimous in their lack of support for DOER’s recommendation
   that customer-owned generation not be eligible for the RPS. Arguments included:
   1) it would be inefficient; 2) force people to structure strange deals to qualify; 3)
   it’s inconsistent w/state support for DSM; and 4) customer-owned generation
   could be considered a "pre-paid" sale of energy. People felt that DOER was
   reading too much into “retails sales” language in the legislation, and some pointed
   out that will likely be sales to the grid sometimes during the year or day in any

Accounting Systems:

      Suppliers’ use of the RECs should appear on the register to help avoid double use.

Supplier Compliance:

       Product vs. Company and the Disclosure Label:
      Most attendees disagreed with DOER’s preliminary recommendation to require
       compliance on a Company basis rather than a product basis. Some pointed out
       that they were very surprised given the recommendations of the white paper and
       the seeming consensus of the Group on this issue at the session where it was
       discussed. DOER pointed out that they did not feel that they had the authority to
       require product-based compliance. Many disagreed with DOER’s interpretation
       of the law.
      Some attendees were also skeptical about the workability and advisability of
       DOER’s recommendations to change the disclosure label which would effectively
       turn disclosure into a product-based system. Some felt that this would create
       problems w/disclosure in other states and with the GPS.
      The Maine Legislature was convinced to effectively administer the RPS on a
       product basis and amended the law.
      Show customers what resources RPS compliance comes from. Customers may
       also want to see what’s new vs. existing renewables.
      Emission rates need to show up, and would be inconsistent with what DOER is
       recommending for fuel type. This could be a “disconcerting mismatch.”
      Can you change the regional disclosure label to accommodate MA RPS?
      There’s a math error in DOER’s supporting table (slide 46), should be 5 MWh
       MA and CT RPS allocation (not 10 MWh).
      Don’t add a statement regarding compliance w/RPS on the label. If they weren’t
       in compliance they ultimately won’t be selling in MA or have a label.
      DOER should go back to the Legislature, if it feels it need to, to clarify that the
       RPS should be on a product rather than a company basis.
      DTE regulations have some restrictions already about what can be marketed as
       green energy above RPS requirements.
      Use term “EPS” and not “GPS”.

   Flexibility Mechanisms:
    The Group was divided regarding DOER’s recommendation not to include
      banking. Some argued that customers and suppliers could be adversely impacted
      without banking, while others felt that banking wouldn’t work with disclosure.
      Some wondered whether banking would circumvent the letter of the law which
      requires that certain levels be met in certain years.
    Look at symmetry of the flexibility mechanisms.
    Isn’t the penalty set up to deal with shortcomings of supply?
    Can early compliance credits be banked for use in years after 2003?

Sanctions for Non-Compliance:

      Consider accelerating future requirements for those in non-compliance.
      Options for placement of any penalty money: general fund; MTC, or purchasing
       and retiring RECs.
      What about all the penalty details recommended in the Consultants’ white paper,
       is that being dropped? [DOER, we have streamlined the recommendations
      The penalty will act as a de facto cost cap.

Next Steps
Next meeting, on Thursday May 18, will once again be at Foley, Hoag, & Eliot. DOER
will refine its recommendations and prepare a draft of its comprehensive RPS proposal
for discussion at the meeting. La Capra Associates will also be updating its analysis on
supply vs. demand of existing resources and running various alternative scenarios. Both
sets of documents should be circulated prior to the meeting.

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