Despite the hype, New England does not need Invenergy plant

We have been hearing a lot this winter and spring about warnings from the ISO, the operator of New England’s electricity grid, of the possible future risk (during the winter of 2024-2025) of rolling blackouts if we do not build more fossil fuel infrastructure. For example, in an April 18, 2018, lead editorial supporting the construction of the Invenergy power plant, the Providence Journal said:

“ . . . the energy experts at Independent System Operator New England, the nonprofit organization that makes sure the electric grid gets enough power, warn that our region faces serious challenges, including the prospect of dangerous rolling blackouts in the coming years.”

Another Journal editorial on February 8 made reference to the same bugaboo of rolling black-outs, as did two separate Op-Ed pieces that the Journal published in February: one on February 9 by Karen Harbert, President of the United States Chamber of Commerce Global Energy Institute, which promotes increased use of coal, oil, and natural gas; and another on February 13 by David Spigelman, the president of a natural gas trade association.

This is a lot of talk in a short period of time about rolling black-outs. What’s going on? Do we need more natural gas pipeline? Do we need the Invenergy plant in order to avoid rolling blackouts?

Let’s start with what is going on. The ISO is, in fact, the non-profit operator of the New England electricity grid. And on January 17, 2018, the ISO released a preliminary draft of the results of its Operational Fuel Security Analysis (OFSA Report). And, yes, this preliminary draft of the OFSA Report did raise the possibility of rolling blackouts in New England during the winter of 2024-2025. The fear-mongers got that much right. But let’s look a bit deeper.

The first big issue is that the Providence Journal’s April 18 editorial conflated two separate, distinguishable issues. The ISO’s fuel security study was – as the name clearly states – an analysis of fuel security, that is, whether or not New England’s power plants will have enough fuel to burn to make enough electricity to meet demand. The dominant fuel for making electricity in New England is natural gas. Today, burning natural gas provides about 49 percent of the electricity we produce and use here in New England, or about as much as all other fuels (nuclear, Canadian hydro, other renewables, coal, and oil) put together. That is up from about 15 percent in 2000.

Fuel security is a completely different issue from system reliability, which is whether we have enough power plants to produce enough electricity to meet demand.

For environmentalists, both fuel security and system reliability are important issues to address, because both matters have important implications for our use of carbon-emitting fossil fuels. But they are separate issues. The ISO’s fuel security study looked at whether we have enough natural gas pipelines into New England. System reliability looks at whether we have enough power plants or other generators like renewables. The first big mistake that the Journal’s editorial made is that it confused two separate issues. The Journal cited an ISO study on fuel security in order to make its (inaccurate) argument about system reliability. This is an apples-and-oranges problem, and the short of it is that the “evidence” cited by the Journal does not even address the question of whether or not Invenergy is needed.

But there are bigger problems with the ISO’s OFSA Report.

In order to produce its OFSA Report, the ISO created a detailed computer model to look at whether New England would have enough fuel to generate enough electricity in 2024-2025. The ISO model used a wide range of inputs. When the ISO ran its computer model it found that New England could have 14 hours of rolling blackouts over six different days during the winter of 2024-2025 in a basic “reference case.” Depending on a variety of variables, the ISO model showed risk of even more hours and days of rolling blackouts in other scenarios. That’s pretty scary.

But the in-puts that the ISO used in its model were badly flawed. Here are the huge, glaring mistakes in the ISO’s model in-puts:

  • The ISO assumed increasing load (demand for electricity) in every year between now and 2024, when the ISO’s own CELT (Capacity, Energy, Loads and Transmission) report shows decreased load in every year between now and 2024;
  • The ISO assumed increased residential consumer demand for natural gas (which gets served preferentially over power plants during hours of scarcity), when the trend for years had been decreased demand;
  • The ISO completely ignored existing laws on the books of every New England state pertaining to mandatory procurement of renewable energy;
  • The ISO assumed less Liquefied Natural Gas (LNG) imports into New England than there are today, when in fact LNG imports may (or may not) go up, but can almost certainly not go down (because the LNG infrastructure is already there); and
  • The ISO’s model also assumed maximal polar vortex winter conditions for all three winter months, something that has never happened in the history of weather records.

Every one of these ISO assumptions is counter-factual (that is, inaccurate and wrong). In this context, it is not surprising that the results of the ISO’s computer modelling were wrong. Garbage in, garbage out.

As a result of these egregious errors, several members of the New England Power Pool (NEPOOL) asked the ISO to re-run its computer simulations using the same computer-model program but with more realistic in-puts. (NEPOOL is the entity that created the ISO in 1996, and retains a legal relationship with the ISO today.) These “Joint Requesters” included environmental organizations like Conservation Law Foundation (CLF), Natural Resources Defense Council and Union of Concerned Scientists; and also statutory consumer advocates including the New Hampshire Office of Consumer Advocate and the Massachusetts Attorney General’s Office.

The Joint Requesters put together a set of in-puts that it called a Business As Usual (BAU) case that replaced the ISO’s badly flawed, counter-factual in-puts with what is actually happening in the real world today. We used actual trends in electricity demand as reflected in the ISO’s own CELT Reports, actual trends in residential use of natural gas, existing LNG capacity in New England, existing laws in the New England states pertaining to renewable energy procurement. The reason that the Joint Requesters called this a Business As Usual case is, well, it reflected actual, real-world, present-day conditions – that is, business as usual.

When the ISO ran its computer model using these BAU in-puts the results were starkly different: zero days of rolling blackouts, and zero hours of rolling blackouts.

There were additional findings, too, when the ISO re-ran its model using our BAU in-puts:

  • Grid reliability increased the more renewables are deployed;
  • Grid reliability increased with additional energy efficiency (both gas and electric); and
  • Grid reliability decreased as our reliance on gas-fired power plants increased.

That last bullet is really important, and it brings us back to where we started, with the Providence Journal’s badly flawed editorial about Invenergy. That last bullet point means that building Invenergy actually decreases system reliability. It is important to understand why this is true. I mentioned above that since 2000, New England’s electricity fuel mix has gone from 15 percent gas to 49 percent gas. Both ISO-NE and the Rhode Island Office of Energy Resources have said for a long time that New England’s over-reliance on a single fuel (natural gas) is dangerous. Building additional gas plants like Invenergy increases New England’s reliance on a single fuel and decreases system reliability.

That is, building Invenergy would be bad for New England’s electricity grid.

On May 3, 2018, on behalf of several of the Joint Requesters (including CLF and the New Hampshire Office of Consumer Advocate) Synapse Energy Economics published a report entitled “Understanding ISO-New England’s Operational Fuel Security Analysis.”  You can see the complete Synapse Report on CLF’s website, here.  The Synapse Report is fairly technical, but it explains in some detail the issues I have discussed here, specifically, the problems with the ISO’s original OFSA and how much better things really look for New England as a result of our deployments of non-fossil alternatives:  energy efficiency, small local renewable deployments, and large-scale renewable energy projects.

Oh, yes, and one more thing:  reading the Synapse Report really shows clearly that we do not need Invenergy.

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About Jerry Elmer 5 Articles
Jerry Elmer is a Senior Attorney in the Rhode Island Office of Conservation Law Foundation and the President of the Environment Council of Rhode Island. He is CLF’s lead attorney in the litigation against Invenergy in the R.I. Energy Facility Siting Board.

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