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Harnessing Order 1000 to improve planning and markets in New England

Harnessing Order 1000 to improve planning and markets in New England. Conservation Law Foundation February 28, 2012. Recent Public Comments from FERC Commissioner Cheryl LaFleur provide the frame.

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Harnessing Order 1000 to improve planning and markets in New England

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  1. Harnessing Order 1000 to improve planning and markets in New England Conservation Law Foundation February 28, 2012

  2. Recent Public Comments from FERC Commissioner Cheryl LaFleur provide the frame “Order 1000 is an opportunity for New England to look at what’s working, what’s not working and how the process can be tweaked, not only to take in the public policy projects expressly, but to perhaps improve what you’re already doing” Order 1000 provides us with a chance to do several things: • Put best practices into tariff (see 1/12/2012 Synapse presentation) • Provide opportunity to articulate Public Policies that must be considered in planning as required by Order 1000 with states in leading role but with all stakeholders heard in deciding which Policies and how implemented • Expand opportunities for stakeholders (including states) to engage problem identification around issues like reliability earlier in process • Create planning platform for granular & localized markets, allowing market solutions to emerge, making transmission truly a backstop solution • Identify projects that have system-wide reliability value AND have value in meeting public policy requirements and cue up cost allocation

  3. Identifying Public Policy Mandates that must be considered in planning and applying those mandates to planning “[P]rocedures must allow stakeholders an opportunity to provide input, and offer proposals regarding the transmission needs they believe are driven by Public Policy Requirements” Order 1000 ¶ 207 FERC “strongly encourage states to participate actively in the identification of transmission needs driven by Public Policy Requirements” ftne 189 but the process of identifying policies and projects must be open and process must ensure that “requests to include transmission needs are reviewed in a fair and non-discriminatory manner” Order 1000 ¶ 209 Process must be open to multiple voices of States and all stakeholders Ultimate touchstone: Public Policy requirements must be “enacted statutes (i.e., passed by the legislature and signed by the executive) and regulations promulgated by a relevant jurisdiction” Order 1000 ¶ 2

  4. Specific Observation in Response to NESCOE Proposal on Identifying Public Policy Mandates and applying those Mandates States must and should play a leading role but the process of identifying the Mandates to be considered must be open and ultimate decision can not be delegated to the states – ISO-NE has obligation under Order 1000 to hear and consider all stakeholder voices and give them opportunity through the Stakeholder process to shape such decisions Likewise, States must have key and leading role in applying those mandates to identification of transmission needs and application to larger planning and review of specific projects but all voices must be heard and the ultimate decisions must flow through the normal NEPOOL and ISO-NE processes with all stakeholders, including the States, shaping the decisions

  5. Improving Early Involvement in Problem Identification • Order 1000 offers an opportunity to revise system planning to ensure that the States and other critical stakeholders are deeply involved at the earliest possible moment in the identification of problems and needs • This process of problem/need identification can flow from a number of sources: • Identification of developing reliability issues, like ones due to retirements • Need to connect specific zero emissions renewable resources with load in order to meet RPS and emissions reductions mandates

  6. Planning providing input to zonal markets, defining zone and nature and quantity of commodity to be purchased Timing is key: Pressure to solve reliability & meet policy requirements vs. need for lead time for both transmission & market resources This construct uses Order 1000 compliance to help align markets and planning

  7. Straw Implementation of NESCOE Hybrid: Cost Allocation of project that has both reliability and “public policy” value

  8. Straw Implementation of NESCOE Hybrid: Example We are not pretending these steps are simple or easy

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