Accomplishing Good Things Quietly: CLF On New England's Electricity Grid | Conservation Law Foundation

Accomplishing Good Things Quietly: CLF On New England’s Electricity Grid

Jerry Elmer

As New England’s leading environmental organization, CLF has more than 60 staff people who work every day for healthy communities, clean water, and to reduce carbon emissions that cause climate change.

Sometimes we win big victories that make headlines, like when my colleague, Shanna Cleveland, won a major victory in federal court that required the permanent shuttering of the Salem Harbor coal-fired power plant. You can see more about Shanna’s victory here; and you can learn more about CLF’s coal-free New England program, here.

Other times, CLF’s work is much quieter, and behind the scenes, in obscure forums that no one has ever heard of. And CLF sometimes accomplishes good things very quietly.

I recently participated in one of these quiet victories. CLF is an active, voting participant in the New England Independent System Operator (ISO-NE), the operator of the regional electricity system. You can read more about CLF’s work with ISO-NE here. Very few environmental organizations participate in this important forum and, of the few that do, CLF is by far the most active.

One of the things that the ISO is most concerned about is the “system reliability” of New England’s electricity grid. System reliability basically means that when you or I turn a light switch, the lights actually go on. No one wants to see power outages or blackouts, and the ISO’s concern with system reliability is sensible.

One of the things the ISO has been doing of late to improve New England’s “system reliability” is to encourage the owners of gas-powered electricity-generating plants to install dual-fuel capability that would allow those plants to burn oil during periods of natural gas shortage – that is, allow those plants to be more reliable. Part of the ISO’s plan was to make sure that, when such a gas shortage arose, these power-plant owners could and would get compensated properly for burning oil, which costs much more than natural gas.

Of course, burning oil to make electricity is also much, much more polluting than burning natural gas. And the way the ISO was going to structure this new system would have provided no reason for generators to burn gas when gas was actually available – because those generators would be fully compensated regardless of which fuel they burned.

CLF reluctantly accepts that some of these generators will burn oil on those very, very rare occasions (at most a few times a year) when cleaner fuels truly are not available. (Of course, an even better idea is to reduce demand by efforts like turning down electricity use in places like factories and large stores; and CLF has long worked to promote programs that pay for and encourage such “demand response” efforts.) And such burning of oil is always limited by the air-pollution permits (under the Clean Air Act) of the generators. At the same time, CLF wanted to make sure that ISO rules would never allow compensation to an electricity generator for burning a dirtier fuel when a much cleaner fuel actually is available (which is nearly always).

None of the ISO experts realized the potential danger of the ISO’s proposed rule change at the time it was being discussed. None of the electricity generators pushed to prevent the originally proposed rule change from going through. Why would they? They were going to get fully compensated for burning a dirty fuel even when a cleaner fuel was available!

But CLF noticed the problem, and was willing to push for a change. As of this writing, I am cautiously optimistic that our proposed change will be approved by the ISO (and later by the Federal Energy Regulatory Commission, or FERC, that oversees and must approve ISO rule changes). The change that CLF pushed for would allow electricity generators to get compensated for burning a higher-priced, dirtier fuel only on those very rare occasions when cleaner, cheaper fuel is truly not available.

Ratepayers benefit because we are assuring the use of the lower-cost fuel whenever possible. And the environment benefits because we are assuring the use of the cleaner fuel whenever possible.

As I say: this was certainly a small victory. But if we are going to be able to address the threat of climate change successfully, it will take hundreds of victories in a variety of forums. Some of those will be big wins, like Shanna’s federal court victory in the Salem Harbor case. And others will be small, incremental steps in obscure forums like the ISO.

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