Category Archives: Power Market Analysis

US OSW Project Construction Pinch Points

Two weeks ago New York State announced that they were negotiating contracts with two OSW projects totaling 1,696 MW, with 2024 commercial operation dates (COD), a year when additional 1,348 MW is scheduled to enter commercial operation: Ørsted US Offshore Wind’s (Ørsted’s) 1,100 MW Ocean Wind Project and US Wind’s 248 MW Maryland project. With this the US Northeast/Mid-Atlantic has awarded or is anticipated to award this year OSW contracts representing over 6,000 MW. These are shown by their anticipated COD and developer below.

* Ørsted projects are with various partners including Eversource, PSEG and Dominion.

These projects will result in cumulative investment of about $22 billion and about 13,000 direct jobs (FTEs) and a total employment impact of over 42,000 during the construction period. This is a quick start to a major new industry where the supply chain to support it is just beginning to be developed. An obvious question is: can this industry develop at this pace, without significant and costly growing pains? While there are many challenges, work appears to be underway to address some of the largest pinch points. Oft-cited examples include ports, vessels and qualified labor in some trades (ex. metal fabrication and marine services).

States and OSW developers are aware of the port constraints and are seeking to ensure that the necessary investments have been made to enable the construction of these projects at reasonable costs and without undue delays.  Based on our assessment some gaps are that Vineyard Wind appears to need an additional port for its 800 MW contract with the Massachusetts EDCs beyond the New Bedford Marine Commerce Terminal and Equinor is in need of a port for marshalling, but New York State has earmarked $200 million for near term port development. 

Sufficient suitable vessels are another possible constraint. The Jones Act and port infrastructure clearly will shape the vessel spreads that developers will employ. While there are reportedly Jones Act compliant OSW installation vessels under construction, vessels and port restrictions including their size (both laydown area and quayside length), air draft restrictions and available infrastructure present challenges.

With respect to labor force constraints, this level of OSW development would result in about 2,400 fabricated structural metal manufacturing jobs and 1,600 marine services jobs (FTEs) during the construction period and over 500 OSW maintenance jobs. These are three areas with particular needs that could outstrip available resources, without training.  However, numerous investments being made by states and OSW developers to develop the workforce and suggests that this potential constraint is beginning to be addressed.

Some final questions:

  • Our initial analysis indicates that the critical pinch points are being addressed.   However, how do all these programs and investment fit together?
  • Is there unnecessary overlap or areas where additional investment will provide the greatest benefit in terms of avoiding supply constraints and facilitating the desired development of the OSW supply chain in the US?

New York Market Forecast and Renewables Development Consulting Services

Have you submitted an Application for Qualification for a generation project in the ongoing NYSERDA Renewable Energy Standard RFP (RESRFP19-1) or are otherwise looking to advance your renewable project development efforts in New York?

Power Advisory offers a full suite of New York market forecasts and strategy consulting services to support these development efforts. Our services include the essentials to forecast project revenues, understand the major risks and opportunities associated with participating in the New York markets and submitting competitive proposals. Power Advisory’s New York market offerings include:

Electricity Price Forecast (considering zonal and technology weighted NYISO energy revenues)
Capacity Price Forecast (focused on the NYISO spot auctions and locational differences)
NYSERDA Tier 1 REC Forecast (by contract year for the anticipated schedule of RES RFPs)
Carbon Pricing Proposal Analysis (considering the implementation of carbon pricing in the NYISO energy markets)
Policy & Market Backgrounders (covering the key policies and market structures that shape NY generation development)
Proposal Drafting/Strategy (direct support of bid preparation and strategies to maximize your chances for contract award)
Registration/Participation Support (for NYGATS and the NYISO administered markets)

We supported successful proponents in the last NYSERDA solicitation, RESRFP18-1, resulting in executed long-term fixed price REC contracts for our clients. 19 projects totaling 1,364 MW of solar, wind and energy storage were contracted in the 2018 solicitation. The weighted average REC price was $18.52. Since then, New York has upped its renewable and clean energy commitments with targets of 70% renewables by 2030 and 100% carbon-free electricity by 2040 and there have been other significant market changes.

Power Advisory specializes in electricity market analysis and strategy, power procurement, policy development, regulatory and litigation support, market design and project feasibility assessment. Our team has completed work in each of the North American electricity markets including numerous consulting projects in New York State. Power Advisory’s understanding of wholesale electricity markets, energy policy, resource procurement and renewable technologies makes us well qualified to support your generation development efforts.

Recently Enacted Legislation Opens Up New Renewable Generation Development Opportunities in Maine

Since Janet Mills was sworn in as governor in January and the democrats had also secured control of both chambers, the expectation was that 2019 was going to be a big year for climate and clean energy in Maine. This has certainly turned out to be true. As an early action, Governor Mills issued Executive Order 3 FY 19/20 to conclude the Maine Wind Advisory Commission and wind permit moratorium that had been in place since the beginning of 2018. A flurry of legislation was also introduced addressing everything from net metering (re-instituted in March through L.D. 91) to electrification, the renewable portfolio standard, procurement targets and Aqua Ventus floating offshore wind pilot project.

Leading up to the adjournment of the legislative session on June 20th a number of these bills passed and were subsequently signed by the Governor. Most notable to renewable generation development in the state were L.D. 1494 and L.D. 1711, which are reviewed below. These offer direct opportunities for long-term contracts for new projects. Respectively, about 400-800 MW of utility scale renewables and 375 MW of distributed solar by 2024.

An Act To Reform Maine’s Renewable Portfolio Standard (L.D. 1494 / Chapter 477 PL)

L.D. 1494 passed the legislature on June 18th, 2019 and was signed into law by the Governor the following week. It expands Maine’s RPS to 80% by 2030 and to 100% by 2050 from 40% (Class I – New 10% and Class II – Existing Resources 30%) while creating a new class of RPS resources, Class IA, for the incremental renewable generation capacity targeted.

In addition, it calls for the competitive procurement of Class IA resources to the level of 14% of 2018 state retail electricity sales, about 1,500 GWh, through a series of two RFPs to be issued by 2021. Energy storage, mechanical, chemical or thermal, can be awarded contracts if paired with eligible Class IA resources. The first RFP is likely to be issued in late 2019 or early 2020 for approximately 750-1,100 GWh (7-10% of 2018 sales per the legislation). A second RFP will then be issued in late 2020 but no later than Jan 15th, 2021 for 450-750 GWh (14% of 2018 electricity sales minus the generation contracted in the first RFP).

The Maine Public Utilities Commission is responsible for administering the reformed RPS  including the two mandated procurements. In this role, the Commission is to direct the Maine investor-owned transmission and distribution utilities to enter the long-term contracts selected from the RFPs. The state’s two investor owned utilities are Avangrid’s Central Maine Power (CMP) and Emera Maine (Bangor Hydro Electric Co. and Maine Public Service Co.), which is pending sale to ENMAX Corporation. While the Commission will retain significant discretion in the solicitations certain aspects were directed in L.D. 1494.

Overall the estimated near term opportunity resulting from the reformed Maine RPS is 400 MW of  land based wind, 850 MW solar or a combination of the two technologies.This opportunity for new renewable generation resources could be up to 25% lower to the extent that sufficient resources that began commercial operations on or prior to June 30, 2019 are available.

An Act To Promote Solar Energy Projects and Distributed Generation Resources in Maine (L.D. 1711 / Chapter 478 PL)

L.D. 1711 calls for the competitive procurement of distributed generation (DG) resources in sequential blocks for a total of 125 MW commercial or institutional DG (i.e. non-residential customers) and 250 MW of community shared DG by July 1, 2024. The initial procurement must occur on or before July 1, 2020 with the rules for both solicitations to be in place by January. Four additional blocks of DG are then to be used by the PUC to meet the overall procurement goals with stipulations on each block that the contract rate be equal to 97% of the preceding block. For the purposes of these procurements a DG resource means an electric generating facility with a nameplate capacity less than 5 MW that uses an eligible renewable fuel or technology and is located in the service territory of a Maine T&D utility. Solar is understood to be the predominant distributed renewable technology.

There are number of specifics in this law with regards to the competitive procurements and net energy billing which should be reviewed. An earlier version included a 400 MW utility-scale procurement provision with a $35/MWh cap, but that was struck from the enacted version.

Carson Robers, Senior Consultant, Power Advisory LLC

A PDF version of this note is available here.

Review of New Jersey Ocean Wind Project Pricing

This memo updates our review of the New Jersey Board of Public Utilities (BPU) Offshore Wind Renewable Energy Certificates (OREC) award to Ørsted US Offshore Wind’s 1,100 MW Ocean Wind project. The BPU made available its order and this provided additional details, which required that our earlier memo be updated. In this memo, we focus on the Ocean Wind contract pricing.

The Ocean Wind project will be developed in three tranches of 368 MW each with a COD in 2024. The first year all-in OREC price is $98.10 per MWh and this price is realized only by Phase 1 for one-month after which it escalates. The price escalates at 2% per year such that in 2045 the contract price will be $148.68/MWh. This equates to a nominal levelized price of $116.82/MWh, representing a 19% premium relative to the price for the smaller Revolution Wind project secured by Rhode Island, which has a similar COD in 2024. The premium is considerably greater relative to the contract price for the Vineyard Wind project, which is able to realize a higher investment tax credit.

Nominal Levelized Pricing Comparison ($/MWh)

Frankly, we are surprised by the magnitude of this premium, even with the superior wind resource that is available to the Revolution Wind project. Interestingly, the OREC Order provides for an annual OREC allowance, which implies a 50%, capacity factor which is higher than that reported for Revolution Wind. However, Ocean Wind is precluded from selling more ORECs than its annual allowance, so this allowance is likely to be greater than a P50 estimate.

The lack of transparency regarding the evaluation and scoring framework used by the BPU doesn’t help in explaining this outcome. The BPU evaluation criteria were identified as the OREC purchase price, economic impact, ratepayer impact, environmental impact, the strength of guarantees for economic impact, and the likelihood of successful commercial operation. However, the relative weights of these evaluation criteria aren’t specified and the tradeoffs that the BPU made in selecting Ocean Wind cannot be ascertained.

Nonetheless, it does appear that there were tradeoffs with respect to these evaluation criteria. Specifically, the BPU order indicates that the Ocean Wind project “provides the best economic development benefits to the state of any of the applicants.” Further, it notes that “Although other projects presented a lower PVNOC [Present Value of Net OREC Cost], given the Ocean Wind 1,100 MW project’s strength in all of the other evaluation criteria, an award to Ocean Wind is in the best interest of the State of New Jersey and its ratepayers” (BPU Order, p. 19).

A PDF version of this memo is available here.

Three New Wind Energy Leases Offshore Massachusetts: Review of BOEM Auction Results and Competitive Implications

Over the last two days BOEM auctioned three leases offshore Massachusetts to Vineyard Wind, Mayflower Wind, and Equinor Wind. Vineyard Wind is a joint venture of Avangrid Renewables and Copenhagen Infrastructure Partners, with an existing Massachusetts lease and a contract for an 800 MW project with the Massachusetts electric distribution companies (EDCs). Mayflower Wind Energy LLC is an affiliate of Royal Dutch Shell Plc. and EDP Renewables; it is the first position in the US OSW market for both companies.[1] Equinor is a Norwegian energy developer that holds the rights to the only existing BOEM lease offshore New York. This sale attracted historic attention from 19 qualified parties and 11 bidders. At the end of 32 rounds the total acquisition fee was $405.1 million ($135.1 million Vineyard Wind and $135 million for the other two winning parties).

Competitive Implications of ATLW-4A

Overall this should be a positive development for the competitiveness of the New England and broader Northeast OSW market. It introduces two new competitors to the region and strengthens Vineyard Wind’s position as an incumbent developer. Equinor represents a new competitor to the Southern New England OSW market. Equinor wouldn’t have been able to compete effectively in the Southern New England OSW market from its New York lease given the distance of this lease from New England and the associated incremental cost of transmission and the marginally worse wind resource in its New York WEA. While the primary opportunity will be for long-term contracts with the Southern New England EDCs, the projects from these lease areas should be able to compete in future New York procurements (which has a target of 2,400 MW by 2030) and possibly New Jersey (3,500 MW by 2030).

The interest of Equinor and Shell indicates the similarities of offshore wind and oil/gas development, both require significant engineering capability and careful management of project logistics, with significant capital requirements over an extended period of time before production begins.

The pricing relative to previous lease sales is a strong indication of market interest and the promise offered by the Northeastern OSW market. Adding two new competitors to the Southern New England market will enhance the competitiveness of solicitations. However, with one element of the evaluation criteria in the various OSW RFPs the project’s underlying maturity it may take a while for consumers to see the benefits of this increased competition.

Comparison to Atlantic Wind Lease Sales

Prior to ATLW-4A there have been 7 lease sales for 11 areas from North Carolina to Massachusetts. The average acquisition fee was $6.7 million. One of the first Massachusetts lease areas was acquired by OffshoreMW LLC (now Vineyard Wind) for as little as $150,197. The next highest sale after today’s results is the New York lease sale of OCS-A 0512 to Equinor in 2016 for a total acquisition fee of $42.5 million from 33 rounds of bidding by 6 total participants. Even in comparison to the New York sale the result of ATLW-4A is more than seven times greater.

Power Advisory_ATLW4A BOEM MA Lease Sale_2018-12-14

[1] Shell did qualify for the North Carolina lease sale (ATLW-7) in 2017 but did participate in the auction.

Review of Atlantic Offshore Wind Procurement Policy and Developments

Over the last year major commitments have been made with respect to the US offshore wind (OSW) market. From only 30 MW operating, approximately 2,000 MW has been contracted and a cumulative +10 GW of installed capacity is now expected by the early 2030s. The growing interest in OSW has been concentrated in the Atlantic, particularly the Northeast which has the strongest state policies for OSW. An indicative schedule of this development by state is presented in the figure below.[1] Power Advisory then provides a high-level review of the procurement processes in New England, New York, and New Jersey as the primary markets, representing about 80% of this total.

New England

As part of the 2016 Act to Promote Energy Diversity, Massachusetts established a procurement target of 1,600 MW of offshore wind by 2030. The first solicitation for OSW proposals, referred to as the 2017 Section 83C RFP, resulted in the selection of 800 MW from Vineyard Wind in May 2018. The contracts for this project are currently before the Massachusetts Department of Public Utilities with a real levelized price for energy and RECs of $64.97 per MWh (2017$).[1]  On July 31st, An Act to Advance Clean Energy was passed, instructing a cost benefit analysis to be completed for an additional 1,600 MW of offshore wind by 2035 and specified that the Department of Energy Resources “may require said additional solicitation and procurements.” Governor Baker, who was recently reelected, signed a pledge to complete this study during the campaign. Given the compelling economics of the long-term contracts secured through the first Massachusetts OSW solicitation we believe that this effectively doubles the Commonwealth’s OSW goal to 3.2 GW by 2035 without the need for additional legislative authority.

In May, Rhode Island selected 400 MW from Deepwater Wind’s Revolution Wind Project.[2] Deepwater Wind has entered into contract negotiations with National Grid. An executed contract for energy and RECs is expected to be filed with the Rhode Island Public Utilities Commission by the end the year.

Connecticut also selected 200 MW from Deepwater Wind’s Revolution Wind Project. The wind farm will be part of the same project selected by Rhode Island, but will deliver electricity directly to the state via a separate export cable. On September 14th, Connecticut closed an RFP for 12 TWh of zero-carbon energy which is said to have received offshore wind proposals. The evaluation phase will be completed in Q4 2018/Q1 2019. Additional opportunities for OSW contracts from Connecticut are uncertain.

The southern New England states have each approached OSW with long-term contracts for bundled energy and RECs, consistent with contracting practice for other clean energy resources in the region. The retention of capacity value by developers provides an incentive for suppliers to maximize that value through efficient operating practices.  The PPA requires the seller to participate in the Forward Capacity Market so that this value can be considered by ISO-NE and ultimately realized by customers.

Evaluation of OSW proposals in New England has focused on economic benefits. For example, the evaluation procedure used in the 2017 Section 83C RFP was based on a 75/25 split between economic benefits and qualitative considerations. Direct economic benefits were assessed based on comparing the proposal price and any required transmission upgrade costs with its direct economic benefits as measured on the basis of the net present value of energy (by LMP) and the value of Class I RECs. Four indirect proposal benefits of wholesale energy price savings, RPS compliance cost savings, incremental greenhouse gas reduction compliance savings, and economic impact of resource winter firmness were also considered. Qualitative considerations included: (1) siting, permitting, and project schedule risks; (2) reliability benefits; (3) other benefits, costs and project risks; (4) environmental impacts from siting; and (5) economic development benefits to the state.

New York

Governor Cuomo established a goal of 2,400 MW of OSW by 2030 in 2017. Offshore wind is a key component of the state’s Clean Energy Standard (CES) of 50% clean energy by 2030. The Long Island Power Authority (LIPA) 2015 South Fork RFP that was open to all resources resulted in the selection of Deepwater’s 97 MW South Fork Wind Farm. This project is expected to come online in 2022 and counts towards the state’s 2.4 GW goal.

NYSERDA released a final RFP to solicit 800 MW or more of offshore wind today (November 8, 2018). Bids are due February 14, 2019. The remainder of the 2,400 MW goal (Phase II) will be procured at a later date. New York has also begun securing stakeholder input on the appropriate transmission development framework for Phase II.

NYSERDA is employing a scoring system that considers price and non-price factors, with each project scored according to a 100-point scale based on three criteria:

  1. Project Viability: 10 points – Non-Price Evaluation
  2. New York Economic Benefits: 20 points – Non-Price Evaluation
  3. Offer Strike Prices: 70 points – Price Evaluation

Project viability is assessed in terms of whether the proposed project can reasonably be expected to be in service on or before the proposed Commercial Operation Date. To maximize the score received, proposers must demonstrate that project development plans are mature, and technically and logistically feasible, that they have sufficient experience, expertise, and financial resources to execute the development plans in a commercially reasonable and timely manner. New York Economic Benefits are measured in terms of three considerations: (1) project-specific spending and job creation in New York State; (2) investment in offshore wind-related supply chain and infrastructure development in New York State; and (3) activities that provide opportunities for the New York offshore wind supply chain, workforce, and research and development.

Offer strike prices are assessed in terms of a: (1) an Index OREC price and; (2) a Fixed OREC price. The Index OREC price will vary monthly based on the value of Index OREC Strike Price specified minus the monthly Reference Energy Price and the monthly Reference Capacity Price. The Fixed OREC price is based on the fixed price specified by the proposer. In essence, the Index OREC price is a contract for difference that considers relevant energy and capacity prices, thereby providing a market price hedge that should support more attractive financing terms than the Fixed OREC.[3]  The Index OREC price will be given a weight of 0.9 and the fixed OREC price a weight of 0.1 to establish the weighted strike price for each proposal.  Either OREC strike price option can be chosen at NYSERDA’s discretion. NYSERDA’s decision will be based upon its projection of the relative costs of the Fixed ORECs and Index ORECs compared to the relative price risks of the Fixed ORECs and Index ORECs over the life of the contract.

If the Fixed OREC price option is chosen, the OREC price will remain for the entirety of the contact length, 20 to 25 years. If the Index OREC is chosen, the OREC will remain for the entirety of the contract unless the Index OREC price is invalidated.

New Jersey

The Offshore Wind Economic Development Act authorized the New Jersey Board of Public Utilities (BPU) to establish an OREC program in 2010. After almost eight years of stalled implementation and development under the previous administration, newly sworn in Governor Murphy signed Executive Order #8 (EO8) on January 31st, 2018. E08 directed all New Jersey agencies with responsibilities under the OWEDA to fully implement it in order to meet a goal of obtaining 3,500 MW from OSW by 2030.

On September 20, 2018 New Jersey opened its first “application” for 1,100 MW of OSW. This will be the nation’s largest OSW solicitation to date. The application window will close on December 28, 2018, with the BPU required to act on the proposals by July 1st, 2019. The goal of the compressed procurement timeline is to maximize the ability of developers to capture the expiring federal ITC and increase the attendant economic benefits that can be realized by the state from the development of the regional industry. Governor Murphy has also directed a target of 2020 and 2022 for two additional BPU solicitations of 1,200 MW to reach the overall goal of 3,500 MW. Identifying these second and third large, near-term procurements is also intended to induce the OSW supply chain to locate in New Jersey.

Separately, EDF Renewables and Fisherman’s Energy have submitted an OREC application to the BPU for approval of the 24 MW Nautilus OSW farm with a planned COD in 2020.

The OREC structure in New Jersey differs from the typical Renewable Portfolio Standard (RPS) programs (ex. RECs, SRECs), which provide an additional source of revenue beyond energy and capacity. The BPU’s OREC Funding Mechanism is largely based on the procurement of a bundled energy, environmental attribute and capacity product. The use of an OREC ultimately adds complexity with respect to the administration of the ORECs and risk to OSW developers (e.g., variances between actual and forecast OSW output) and in Power Advisory’s opinion could be more simply administered with stronger performance incentives with a PPA that procured energy and environmental attributes. However, this is the framework that was legislatively directed and is expected to be used for all three upcoming procurements.

Rather that issue a formal request for proposals the New Jersey BPU issued Guidelines for applications for the sale of ORECs.[4] These guidelines identify the requirements for applications and outline the six criteria that the BPU will use to rank proposals.  These six criteria are:

(1)   OREC Purchase Price, which can be fixed or escalating;

(2)   Economic impacts, which includes, the number of jobs created, increases in wages, taxes receipts and state gross product for each MW of capacity constructed;

(3)   Ratepayer impacts, which considers the average increase in residential and commercial customer bills along with the timing of any rate impacts;

(4)   Environmental impacts, which includes the net reductions of pollutants for each MWh generated and the feasibility and strength of the applicant’s plan to minimize environmental impacts created by project construction and operation;

(5)   The strength of guarantees for economic impacts, which considers all measures proposed to assure that claimed benefits will materialize as well as plans for maximizing revenue from the sales of energy, capacity and ancillary services; and

(6)    Likelihood of successful commercial operation, which includes feasibility of project timelines, permitting plans, equipment and labor supply plans and the current progress displayed in achieving these plans.

There’s very little transparency regarding the evaluation process and how tradeoffs regarding these six criteria will be assessed.  The Guidelines indicate that “ranking and weighting of the six criteria by the BPU will reflect the goals of the solicitation especially as stated in the Governor’s Executive Order No. 8.” Based on our experience we believe that this lack of detail regarding how these criteria as well as tradeoffs among these criteria will be assessed, may hamper the ability of proponents to craft proposals that best satisfy New Jersey’s objectives.

Power Advisory would welcome the opportunity to assist clients in understanding the opportunities presented by the emerging US offshore wind industry.

 

A PDF of this update is available here.

[1] Note the schedule represents anticipated commercial operation date versus when the capacity is expected to be solicited. For Massachusetts, Vineyard Wind was originally proposed as two 400 MW phases coming into service in late 2021 and 2022, but in its Supplemental Draft Environmental Impact Report Vineyard Wind announced that it would construct the full 800 MW simultaneously and commission the project in mid-2022.

[1] This price escalates at 2.5% per annum and the project owner retains revenues from ISO-NE’s Forward Capacity market.

[2] On October 8th Ørsted announced that it was acquiring Deepwater Wind and its portfolio of 5 PPAs representing 810 MW for $510 million.

[3] An assumption must be made regarding the UCAP Production Factor so that the project nameplate capacity can be converted to UCAP.  NYSERDA allows a proponent to use a default UCAP Production Factor of 38% consistent with the NYISO’s Installed Capacity Manual or to specify a project-specific value. These values will be constant throughout the contract term. The ability to specify an alternative UCAP Production Factor presents an opportunity for proponents to change the risk/reward profile and as such warrants analysis.

[4] Guidelines for Application Submission for Proposed Offshore Wind Facilities

 

Review of NYSERDA Renewable Energy Standard RFP 1 Results

On June 2, 2017 the New York State Energy Research and Development Authority (NYSERDA) issued the 2017 Renewable Energy Standard Request for Proposals (RESRFP17-1). The RFP was the first issued under the state’s Clean Energy Standard. The Clean Energy Standard requires that 50% of the state’s electricity come from renewable sources by 2030, representing about a doubling of the state’s renewable energy requirements. The standard puts an obligation on retail electricity suppliers to purchase increasing amounts of renewable energy to supply their customers. To assists these retailers in meeting their obligations, NYSERDA is required to support the development of large-scale renewable projects by issuing periodic requests for proposals (RFPs) to enter into long-term contracts (i.e., up to 20 years) with renewable energy developers. These RFPs provide for the purchase of renewable energy credits (RECs), rather than bundled energy and RECs.

The 2017 Renewable Energy Request for Proposals resulted in agreements to develop 26 new large-scale renewable projects. Of the 26 projects selected, 22 are solar, 3 are wind, and one is a hydroelectric project. In addition, one of the selected wind farms will include an energy storage component. The 26 projects will add 1,383 MW of capacity and generate 3.2 TWh per year, providing about 2% of the 50% 2030 target. The weighted average price for the Tier 1 RECs purchased was reported as $21.71. A map of the selected projects is included below:

Exelon’s Proposed Retirement of its Mystic Plant: Ensuring the Attention of ISO-New England

April 3, 2018

Last Thursday, Exelon Generation (Exelon) announced that it had filed with ISO-New England to retire the Mystic Generating Station’s Units 7, 8, 9, and the Jet unit on June 1, 2022.  Exelon noted “absent any regulatory reforms to properly value reliability and regional fuel security, these units will not participate in the Forward Capacity Auction scheduled for February 2019.”  Mystic offers over 2,000 MW of capacity, making it the largest generating station in Massachusetts and one of the largest in New England.   ISO-New England reported that Exelon submitted delisted bids in the Forward Capacity Auction that was conducted in February.

On March 17th at a New England Restructuring Roundtable Meeting, Gordon Van Weile, President & CEO of ISO-New England, opened the door to such regulatory reforms when discussing the fuel security analysis that the ISO had completed.  His presentation noted that the “The ISO can take action through its market design and tariff to procure ‘insurance’ to alleviate, but not eliminate, fuel-security risk.”  More specific references to possible changes were offered in his formal remarks.  In its Press Release announcing the proposed retirement, Exelon indicated that “ISO-NE recently stated that it may propose interim and long-term market rule changes to address system resiliency in light of significant reliability risks identified in ISO-NE’s January 2018 fuel security report.”

The significance of these retirements is exacerbated by the unique reliability attributes of these units.  First, they are located in the Northeast Massachusetts-Boston area, which has been found to be an import-constrained zone in the past and would likely be determined to be again with the retirement of this capacity.   Second while Mystic 8 and 9 are natural gas-fired, they are not connected to the interstate natural gas transmission pipeline network that serves New England. They are directly connected to the Everett LNG terminal.  Therefore, these two CCGTs are not subject to the same natural gas supply constraints that affect the rest of ISO-New England’s natural gas fleet.  This fact was recognized in ISO-NE’s fuel security analysis.

Interestingly, at this same time Exelon also disclosed that it would be purchasing the LNG terminal from ENGIE North America.  The ISO-New England fuel security analysis demonstrated the importance of the continued operation of the Everett LNG terminal to New England electricity supply reliability.  With a sustainable sendout of about .4 Bcf per day, after the volumes delivered to Mystic 8 and 9 are netted out, the Everett LNG terminal can provide about 9% of New England’s interstate delivery capability (excluding the output of the local LNG and propane storage facilities operated by the region’s gas distribution utilities.)

While one might question why Exelon would purchase the LNG terminal if it planned to retire two generating units that utilize about 30 to 40% of its throughput, with the purchase of the LNG terminal Exelon has purchased a natural gas fuel price hedge.[1] The purchase of the Everett LNG Terminal enables Exelon to secure the world-wide price for LNG for natural gas supplies for Mystic 8 and 9.  This will be beneficial during winter high demand periods, but could result in higher fuel prices in other periods unless Exelon is able to secure contracts with LNG suppliers that are based on an Algonquin City Gate (New England natural gas pricing point) netback price.  Conceivably, Exelon has elected to forgo the modest operating margins in many of these other hours to lock in greater margins during winter peak periods.[2]

Also contributing to the significance of the loss of this capacity is that Mystic 7 is dual-fueled (natural gas and residual oil) with a winter capacity rating of 560 MW.  The importance of dual-fuel capability to maintaining reliability was highlighted this winter, where in a two-week period New England oil-fired generation regularly represented upwards of 35% of the regional fuel mix.

ISO-NE will need to evaluate the reliability impacts of these proposed retirements, but cannot prevent the units from retiring.  This announcement would add to the growing list of retirements, which by the early 2020s would represent (with the addition of this 2,000 MW) about 23% New England’s generation capacity.

[1] The current price of natural gas for Mystic 8 and 9 is reported be pegged to the Algonquin City Gate price so that these units are generally ensured access to natural gas, but at a market price.

[2] Reported prices for LNG deliveries to the Everett Terminal in 2017 ranged from $3.03/MMBtu to $4.00/MMBtu from April to October 2017. US DOE, LNG Monthly, January 2018

Integration of Variable Output Renewable Energy Sources – The Importance of Essential Reliability Services

Power Advisory prepared a report (available here) on the importance of Essential Reliability Services (ERS) in the integration of variable output renewable energy resources for Natural Resources Canada with direction and input provided by Canada’s Federal Provincial Territorial Electricity Working Group. The paper was presented by NRCan in August 2017 at the Energy and Mines Minister’s Conference in New Brunswick.

BOEM Massachusetts Offshore Wind Lease Opportunity Review

John Dalton, President & Michael Ernst, Executive Advisor, Power Advisory LLC

The Bureau of Ocean Energy Management (BOEM) has indicated that it will be conducting auctions for two additional lease areas for the Massachusetts Wind Energy Area (WEA) in 2018.  The auction of the two lease areas, an aggregate of 388,569 acres (248,015 and 140,554 acres, respectively) with a maximum development potential of 4,717 MW, is in response to unsolicited lease applications from Statoil Wind US LLC and PNE Wind USA Inc. from December 2016 (See Figure 1 below). These Norwegian and German affiliated developers have announced plans for multiple +400MW projects, but since both expressed interest in the same lease area BOEM must hold a lease auction in which all qualified parties may participate.   Lease Areas OCS-A 0502 and 0503 make up the remaining Massachusetts WEA.

Figure 1: MA and RI Offshore Wind Project Areas

Source: BOEM

The interest in these two additional lease areas is expected to be strong given that lease holders will be able to participate in subsequent rounds of the Massachusetts offshore wind RFPs for 20-year power contracts issued to allow the Commonwealth to realize its legislated objective of 1,600 MW of offshore wind by 2027.[1]  The total area to be leased is over four times the size of the New York lease area. This memo reviews the anticipated form of auction to be employed by BOEM and opportunities for interested parties to begin to prepare to participate successfully in such a process.

Auction Format

BOEM has typically employed a multiple-factor auction format, under which BOEM considers a combination of monetary and nonmonetary factors.  Non-monetary factors are considered by a panel which determines whether the bidder has earned non-monetary credits and the percentage that the credit may be worth.  The previous Auction for North and South Rhode Island and Massachusetts lease areas provided for a credit of up to 25% of a monetary bid for a Power Purchase Agreement or Joint Development Agreement.

The auction is based on ascending bidding, i.e., ascending clock auction, over multiple rounds.  To enhance competition BOEM shares information with bidders on the number of bidders for each Lease Area for each round.  At the start of each round BOEM specifies an asking price for each Lease Area.  A bidder must submit a bid for the full asking price for at least one lease area to participate in the next round of the auction.  A bidder may submit an intra-round bid, which is greater than the last round’s price, but less than the current round.  In essence, the bidder may elect to bid less than the BOEM asking price as a final exit bid.  When there are multiple lease areas activity rules are employed that allow bidders to switch lease areas that they bid on, but require minimum levels of participation.  A bid deposit must cover each bid, and will be deducted from the winning bid price or refunded if the bid is not successful. Bid deposits have been $450,000 for the most recent BOEM lease auctions.[2]

To participate in the auction, the bidder must first be qualified by BOEM and become an eligible bidder.  Qualification requirements focus on legal, technical and financial capability as specified in 30 CFR 585.106 and 585.107.[3]  Eligible bidders must complete a Bidders Financial Form, which provides details of accounts from which funds will be provided and to where refunds will be directed and individuals authorized to bid and submit bid deposits generally two weeks prior to the date of the auction.  At this time, bidders would also provide a non-Monetary package if they were applying for a credit for community benefits based on an executed agreement with a qualified community organization or municipality.

Evaluating Participation in the Massachusetts WEA Lease Auction

In assessing whether to participate in the BOEM auction, prospective bidders will want to assess the opportunity offered by these two lease areas to ensure that they offer a reasonable prospect of competing successfully with the three existing leaseholders.   Specifically, these two lease areas will require a greater transmission investment.   However, the four Massachusetts WEAs were delineated to provide roughly equivalent water depths, and thus similar costs for foundations for the initial several hundred megawatts of capacity.  Offsetting the greater required transmission investment are greater wind speeds in WEAs 0502 and 0503.   Interestingly, the average wind speed in Lease Area 0502 is the highest of the four WEAs according to analysis performed by NREL.  More importantly, the lowest depths in Lease Areas 0502 and 0503 are associated with higher wind speeds. This suggests that these lease areas could have lower foundation costs and higher overall output levels. This combination could allow them to compete effectively with other leaseholders in the Massachusetts RFP even with higher transmission costs.  Figure 2 reviews the water depths of these lease areas and Figure 3 reviews the wind speeds of these different lease areas, relative to the cost of participating in the auction and the Power Advisory estimates.

Figure 2: Massachusetts Offshore Wind Speeds

Source: NREL

Figure 3: Massachusetts Offshore Water Depths

Source: NREL

BOEM has issued an Environmental Assessment of the entire Massachusetts WEA and issued a Finding of No Significant Impact.[4] Lease Areas 0502 and 0503 are also located over 20 miles from Nantucket and Martha’s Vineyard reducing visibility of the turbines from shore which has been a significant obstacle to earlier proposed offshore wind farms such as Cape Wind off of Massachusetts.

To assess the potential economic value of the higher output offered by Lease Areas 0502 and 0503, we used the increased annual energy output estimated by NREL for each WEA for a 500 MW OSW project configuration and projected the incremental value of the WEA assuming a 20-year PPA term and a PPA price of $110/MWh.  The incremental value was considerably below the estimated incremental cost of transmission interconnection.  This suggests that additional cost savings from lower water depths would be required.

In sum, based on this high-level analysis Lease Areas 0502 and 0503 warrant more detailed analysis.  On October 4, 2017, the Director of the Office of Renewable Energy Programs for BOEM announced plans to issue the Proposed Sale Notice for these lease areas by the end of 2017 with the auction during the summer of 2018.

Power Advisory would welcome the opportunity to assist clients in assessing opportunities in the US offshore wind market, especially the upcoming BOEM Massachusetts and NY lease sale auctions, submission of comments on the 83C RFP, and participation in subsequent solicitations.

[1] See Power Advisory’s May 12, 2017 memo that reviewed past BOEM WEA leases.

[2] The most recent BOEM lease auction was for New York in December 2016. See  https://www.boem.gov/NY-FSN/.

[3] Power Advisory has assisted clients with complying with these requirements.

[4] The EA and FONSI are located here: https://www.boem.gov/Revised-MA-EA-2014/.

A PDF version of the report is available here.