Summer Work in Massachusetts

Summer Work in Massachusetts

It has been a busy summer in Massachusetts where at the end of June the state’s utilities issued a request for proposals for offshore wind.

Three wind developers now have their heads down studying the document and figuring out how to position their projects to win.

Massachusetts law calls for the utilities to procure 1,600 MW of offshore wind by 2027, and this RFP requests proposals for the first 400 MW. Something we haven’t seen before is a requirement that the wind project developers must propose an expandable transmission system that is designed to deliver the full 1,600 MW offshore wind requirement. These “Expandable Transmission Proposals” must accommodate all existing and currently planned offshore wind energy generation facilities and must be available to all potential future bidders on a non-discriminatory basis.

This enlightened approach is designed to encourage the wind developers to put as much energy into planning transmission as they put into planning the installation of wind turbines.  If they do, they may find ways to use fewer offshore circuits, save money for ratepayers and reduce environmental impacts.  The distance between the wind energy areas in the ocean south of Martha’s Vineyard and the strong grid points on the mainland in Massachusetts will require circuits of 33 miles or longer.  There are likely ways to combine the circuits needed to serve four 400 MW projects that are better than four individual circuits.  The developer with the most attractive generation and transmission offering should win the competition.

That economies of scale could produce efficiencies is common sense, of course. But what’s more subtle in the RFP is the requirement that any Expandable Transmission facilities should be “open access” or “non-discriminatory” in the sense of being equally available to any offshore wind developer. That would make them a common carrier like the highways or railroads and ensure that preferential access to the transmission grid by one developer cannot be used to block access by a competing developer.

That was a smart call because the general rule under FERC Order 807 is that a generator that builds a generator-specific tie line has a presumptive right to all its transmission capacity, including unused capacity – which includes the right to exclude other generators from accessing the line. So Massachusetts has taken a smart step in support of robust competition, and hopefully lower costs for ratepayers, by insisting that any Expandable Transmission facilities are treated as a public good or common carrier where any shipper or producer of goods – wind energy in this case – has open access to the lines.

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