Massachusetts AG Filed Comments on State’s Clean Peak Energy Portfolio Standard

OCTOBER 30, 2019

Massachusetts Attorney General Maura Healey filed comments with the Massachusetts Department of Energy Resources (DOER) outlining several suggestions to improve DOER’s proposed draft regulations to establish the state’s first-in-the-nation Clean Peak Energy Portfolio Standard (CPS). In particular, AG Healey recommended clarifying the conditions under which energy storage systems can qualify as clean peak resources, and emphasized that “[c]harging storage during periods of generally high renewables output does not ensure that the battery itself is charged from a low-carbon resource or that it is charging from the grid at a time of day when ISO-NE system emissions (marginal) are lower than typical.” AG Healey also suggested that DOER reduce the initial CPS annual rate increase from 1.5 percent to 0.75 percent or less, because while “an accelerated increase may be warranted” after future review of the program’s efficacy, adopting “a ‘look before you leap’ strategy would ensure that ratepayer funds are used prudently.”