The Clean Peak questionnaire

On this possibly second coldest day of the year (yesterday being the coldest), it is fitting to remember that last year New England burnt oil and coal during its peak cold period (below image). Probably partially motivated by this event, the state of Massachusetts put forth (and eventually passed) plans to clean, and lower the price of, the state’s peak 10% of electricity per year. And the program is dictated to cost less than “0.5¢/kWh in the aggregate for any particular year.”

The Massachusetts Department of Energy Resources (DOER) has scheduled a Stakeholder Questions meeting regarding the Clean Peak Energy Standard (CPS). Along with scheduling the meeting, DOER released a document (pdf) to help drive the conversation by defining key terms, and asking questions that give significant insight into ways DOER is considering meeting the program’s requirements.

The first questions ask whether resources connected to the transmission grid, versus distribution, should be considered. If the answer is yes, this would allow out of state resources to meet the requirement.

Demand response resources are considered, as well as electric vehicles, solar thermal and standard alone energy storage. Energy storage systems are focused on a bit more – including questions regarding how the CPS could affect the 30% ITC if the electricity is required to be used during the Clean Peak.

In the state’s recent SMART tour launching the latest solar construction program, it was noted that SMART incentive money cannot be used to retrofit energy storage projects to SREC solar power installations. However, the DOER is searching for techniques to do so – such as part of the CPS.

In addition to the hardware that can meet the requirement, is also that the CPS periods must be established, and of course there are rules surrounding that:

the daily time windows during any of the 4 annual seasons when the net demand of electricity is the highest; provided however, that a seasonal peak period shall be not less than 1 hour and not longer than 4 hours in any season, as determined by the department.

DOER then guides stakeholders to think about how to define these periods. Of particular note is the 1 to 4 hour window, which very nicely aligns with the standard power to capacity ratios of energy storage products.

The document continues further into the technicalities of tracking certificates, production onsite, techniques to value certificates, time frames of the program, and more.

To start the year, and set a baseline for the Clean Peak Program, the state is required to determine the current percentage of kWh sales from existing clean peak resources during the seasonal peak load hours. The state determined that “approximately 0 MWh are being served by existing clean peak resources during peak load hours as of December 31, 2018”.

If you’d like to subscribe to the various Massachusetts energy-related program notifications, visit DOER’s mailing list page.