Regional stakeholders widely support the New England States Committee on Electricity’s (NESCOE’s) proposed procurement of transmission solutions in Maine and New Hampshire but have differing views on the scope and format of the solicitation, according to public comments published Dec. 2
The proposed transmission solicitation would be the first to emerge from the longer-term transmission planning (LTTP) process, which NESCOE developed in collaboration with ISO-NE and FERC approved in July. (See FERC Approves New Pathway for New England Transmission Projects.)
The process allows NESCOE to identify a transmission need and direct ISO-NE to issue a request for proposals. It also includes a default cost allocation method in which the costs of a selected project would be regionalized by load, while NESCOE also could provide an alternative cost structure or opt to terminate the process.
In October, NESCOE told stakeholders it plans to focus the first LTTP solicitation on increasing the capacity of two interfaces in Maine and New Hampshire, which ISO-NE estimates will be overloaded by the mid-2030s. In a letter to ISO-NE, the states also expressed interest in projects that would help “facilitate the integration of additional generation resources located in northern Maine.” (See New England States Seeking Increase of North-South Tx Capacity.)
NESCOE asked for feedback on how to successfully achieve these goals, and said it still is considering whether it should expand the RFP to include “a requirement for solutions that extend farther north into Maine.”
“While such a requirement would further facilitate the transfer of cost-effective power across these interfaces, NESCOE seeks to avoid an overly prescriptive scope that may hinder the success of a potential RFP,” NESCOE added.
Clean Energy Groups
In joint comments, RENEW Northeast, the American Council on Renewable Energy and American Clean Power said NESCOE’s October memo is “an important first step … that will unlock additional renewable energy sources in Maine and reduce curtailment of existing resources.”
The clean energy groups said the RFP should be structured to encourage competition and be open to a range of technologies, “including the use of grid-enhancing technologies and high-performance conductors, as well as storage that performs a transmission function.”
Because the RFP will not allow partial solutions to the identified needs, “NESCOE should carefully consider the minimum requirements it identifies,” the groups wrote, adding that “allowing for a comprehensive solution to be comprised of discrete segments or sections could provide additional flexibility for meeting transmission needs.”
For future iterations of the LTTP process, the groups recommended ISO-NE and NESCOE adopt “a forward-looking solicitation schedule to provide project developers with longer-term market visibility.”
Advanced Energy United advocated for adequate flexibility to enable non-incumbent transmission developers to meaningfully participate in the process. The trade association said breaking the solicitation into multiple RFPs may enable more participation, but said a multi-RFP format should be pursued only if it does not hurt the timeline or the likelihood of success.
Hydro-Québec said the solicitation will be essential for reducing congestion and wrote that the “resulting transmission solutions will optimize the use of existing and future resources.”
The company touted the potential of its hydro resources to help balance renewables in New England and urged the region to consider “market reforms to complement and optimize future transmission solutions,” including the elimination of exit fees on electricity exported from New England to Québec.
“Market structures should be created and implemented that properly compensate clean and dispatchable resources and long-duration storage to support the integration of significant volumes of renewable generation into the New England system,” Hydro-Québec wrote.
Multi-day energy storage developer Form Energy said its batteries could help address constraints on the interfaces by absorbing energy when the interfaces are constrained and discharging when capacity is available.
Incumbent Transmission Owners
Eversource and Central Maine Power (CMP) both advocated for a defined, clear RFP scope to maximize the likelihood of success.
“A broad RFP seeking large, complex projects may limit the quality of the solutions proposed because bidders may be hesitant to dedicate significant resources to sufficiently developing very large projects,” Eversource wrote. “A targeted RFP is more likely to be successful and would not foreclose the possibility of pursuing a larger transmission expansion program via a sequence of several additional RFPs over time.”
CMP expressed concern that allowing projects to address needs in Northern Maine could overlap with a separate upcoming transmission procurement by the state of Maine and could delay Maine’s solicitation.
National Grid asked for more clarity around how projects will be evaluated and urged the RTO to “adopt and make known a relative weighting of evaluation criteria.”
The company also recommended “that NESCOE define the need to focus on renewable energy deliverability rather than interface limits to give participants greater flexibility in solution development and provide customers with the optimal solution.”
In contrast to CMP and Eversource, Vermont Electric Power Co. (VELCO) and Grid United submitted joint comments advocating for “flexible definitions to encourage a diverse range of innovative responses.”
VELCO and Grid United have proposed a $2.5 billion transmission project connecting New England, Québec and potentially New York, which is intended to increase interregional transmission capacity, reduce congestion and enable the interconnection of new renewables.
“We would respectfully request that NESCOE give strong consideration to this project for its second LTTP solicitation,” the companies wrote.
Non-incumbent Transmission Developers
Non-incumbent transmission developers, including NextEra Energy Transmission (NEET), LS Power and Con Edison Transmission (CET), stressed the need to allow bidders to include upgrades within an existing right of way.
“Allowing bidders to submit transmission solutions that include new or upgraded incumbent-owned transmission facilities and that solve for discrete needs will eliminate unnecessary obstacles to the development of competitive, innovative and cost-effective transmission solutions,” NEET wrote.
To make this RFP a competitive success, it should be clear that the need for new infrastructure defined in the RFP is outside of the [right of first refusal] rights of incumbent transmission owners,” CET wrote.
CET called for “an ample window” for developers to submit proposals, while LS Power advocated for shorter application and evaluation periods. ISO-NE has outlined a six-month application window, followed by a yearlong review process. LS recommended a 60‐ to 90-day application window and a 6-month evaluation period.
Consumer and Environmental Advocates
A coalition of environmental nonprofits said the RFP should explicitly consider potential interconnections of offshore wind upstream of the selected interfaces.
“Focusing solely on the potential integration of 3,000 MW of new onshore generation from northern Maine could result in a lack of grid transfer capacity for offshore wind and other resources that interconnect in Maine,” the coalition wrote.
The groups also stressed the need to move the process as quickly as possible and said NESCOE “should consider the possibility of initiating a second solicitation before the completion of the first.”
The Acadia Center submitted additional comments advocating for flexibility in potential solutions, a priority for using existing rights of way, and consideration of benefits related to increased interregional transmission capacity and offshore wind compatibility.
The Massachusetts Office of the Attorney General and the New Hampshire Office of the Consumer Advocate submitted joint comments advocating for a greater role for consumer advocates in the process.
“The Consumer Advocates seek to enhance our ability to participate more proactively in the LTTP process and to be included in critical discussions at key decision points to assure ratepayer interests are effectively represented and meaningfully considered,” the offices wrote.
Synapse Energy Economics, representing the Maine Office of the Public Advocate and nonprofit energy buying consortium PowerOptions, echoed the calls for a “flexible approach” to maximize competition.
“Synapse encourages NESCOE to include a recommendation that bids utilize alternative transmission technologies and particularly storage options when demonstrated to be cost-effective,” the company wrote.