The Clean Peak Standard Starts to Take Shape

Foley Hoag LLP - Environmental Law
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Foley Hoag LLP - Environmental Law

The Massachusetts Department of Energy Resources has released its Clean Peak Standard Straw Proposal, providing its thinking on the implementation of that part of An Act to Advance Clean Energy, from 2018.  As a reminder, the basic idea is that a “Qualified RPS Resource,” installed after January 1, 2019, may obtain “clean peak certificates” for energy generated during seasonal peaks.  Existing Qualified RPS Resources may obtain CPCs if they are paired with battery storage installed after January 1, 2019.

Here is DOER’s current position on some of the important issues to be resolved.

  • If existing Qualified RPS Resources seek to pair with new battery storage, the storage must be at least equal to 25% of the nameplate capacity of the resource.
  • Once qualified, all electricity delivered by the Qualified RPS Resource would be eligible to obtain CPCs
  • DOER has proposed definitions of the peak periods for each season
  • Qualified Resources will generate CPCs based on the average output during the peak period on any particular day
  • There will be multipliers, proposed by DOER at 3X, during summer and winter peaks.
  • DOER is proposing a separate, 15X multiplier, calculated after the fact, based on generation during the prior month’s actual peak hour
  • DOER is considering including a “resilience multiplier,” but none is proposed in the Straw Proposal

There’s a lot more to the proposal than this summary can encapsulate.  Comments are due April 12, 2019.

It certainly seems as though DOER is moving forward to meet its goal of promulgating the Clean Peak Standard by Q1 of 2020.  Just another state policy for ISO-NE to incorporate into the wholesale markets!

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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