New testimony in the Invenergy hearings currently before the Energy Facilities Siting Board (EFSB) was filed today on whether or not the electricity from the proposed $1 billion racked gas and diesel oil burning power plant aimed at the pristine forests of Burrillville is needed by ISO-NE, the operator of the New England electricity grid.

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See also: Without a power plant, Invenergy is making millions off New England ratepayers

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Conservation Law Foundation (CLF) filed a Memorandum from their expert witness Robert Fagan based on new information that “has become available since February 2018 concerning any purported need for either unit 1 (485 MW) or unit 2 (485 MW) of Invenergy’s proposed Burrillville power plant. These units are sometimes referred to as ‘Turbine One’ and ‘Turbine Two.’”

Fagan (page 1-4) tells a very simple story: the electricity from Invenergy’s proposed power plant is not needed in New England. Fagan bases his analysis on four major points:

• There is a current surplus of generating capacity in New England; while
• Peak load, which drives future demand, is declining; while
• The pace of retirements of existing power plants shows no need for new power plants; while
• Large procurements of new renewables are coming into the New England electricity market.

“The figures from the ISO don’t lie, and those figures show a surplus of generating capacity in New England and huge new renewable procurements adding to the existing surplus,” said CLF Senior Attorney Jerry Elmer. “The bottom line is that the ISO does not need Invenergy and New England doesn’t need more carbon emissions.”

The rest of Fagan’s Memorandum is more technical, providing seven fairly technical data points that support his conclusions, including:

• FERC’s recent approval of the ISO’s newly lowered Dynamic De-List Bid Threshold (pages 4-5);
• the ISO’s newly released 2018 CELT Report showing consistently decreased demand (CELT = Capacity, Energy, Loads and Transmission) (pages 5-6);
• the recently announced retention of Mystic Units 8 and 9 (page 8-9);
• and the recently-announced new procurements of Canadian hydro power and offshore wind by Rhode Island, Massachusetts, and Connecticut (pages 9-11).

“Under the law, the EFSB can only grant a permit to Invenergy if the plant is needed and it won’t cause unacceptable environmental harms,” said Elmer. “Because the plant is clearly not needed, there is no way that it can be legally granted a permit.”

Invenergy’s expert witness, Ryan Hardy, has a different view, of course. In a one thousand page, highly technical and cluttered document, Ryan makes presents his view.

“In summary,” said Hardy, “my findings are consistent with my previous testimonies in that recent market and other developments show that CREC [Clear River Energy Center] is still needed for reliability in the ISO New England market.”

This is the same Ryan Hardy who predicted, in October 2015 and again in January 2016, that Invenergy’s Turbine Two would clear the ISO’s Forward Capacity Auction held in February 2016.

That did not happen.

Later, in 2016, the same Ryan Hardy told the Rhode Island PUC that he was certain that Invenergy’s Turbine Two would clear the ISO’s Forward Capacity Auction held in February 2017.

That did not happen.

Later still, in September 2017, the same Ryan Hardy testified that Invenergy’s Turbine Two would clear the ISO New England auction in February 2018.

Not only did that not happen, Ryan made that prediction the very same month that ISO New England disqualified Turbine Two from even participating in the February 2018 auction.

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