David Ismay is an attorney at the Conservation Law Foundation. He wrote a commentary in VTDigger criticizing ISO-NE for making erroneous and overly conservative assumptions, etc.


Mr. Ismay creates the impression the NE electric system can meet all future demand, including electric heat pumps for buildings and charging electric vehicles by:


1) Closing the nuclear, gas, coal, and oil plants (per 100% RE wish list).

2) Keeping the refuse, wood, landfill gas, methane, NE hydro and imports.

3) Expanding wind and solar (their combined output is near zero many hours of the year, per ISO-NE real-time website). See Appendix.

4) Having more battery storage (very expensive @ $400/kWh delivered as AC)

5) Having more energy efficiency (I agree)

6) Having more demand management (I agree, if it does not become rationing/coercion)

7) Using Russian and other foreign liquefied natural gas (LNG) throughout the year and especially during cold spells, as in 2017/2018 (that would be far beyond rational).

ISO-NE, the NE Grid Operator

ISO-NE has vastly more experience operating the NE electric grid than any single engineering consulting firm hired by entities with 100% RE agendas.

ISO-NE is conservative in their assumptions, because their engineers are highly familiar with all the strengths and weaknesses of the NE grid and THEIR reputation is on the line if something goes wrong.

They would be rather safe than sorry. They aim to avoid having several hundred thousand households freezing in the dark, in winter, with a snow and ice on most of the solar panels, and little wind.

Engineering Consultant Second-Guessing ISO-NE

Synapse Energy Economics 


Synapse Energy Economics performed an analysis of the ISO-NE “Operational Fuel Security Analysis”. See URL.


Synapse was paid by an activist group of 100% RE proponents:


- Conservation Law Foundation

- Acadia Center

- New Hampshire Office of the Consumer Advocate

- PowerOptions

- RENEW Northeast

- Vermont Energy Investment Corporation


They did not like the way ISO-NE had made its analysis. All these sponsors are avidly promoting wind, solar, and other measures. Synapse Energy Economics is their go-to consultant to provide them with reports that support their views and objectives.

Synapse made a study that second-guessed ISO-NE, made its own assumptions, and then claimed New England's electricity supply would be just fine, because all New England states have pledged increases in wind and solar and increases in energy efficiency. In particular the consultant claims:

- New England states will continue to meet their existing mandates that require increasingly higher percentages of electricity come from new clean, renewable sources including solar and wind power.

- Energy efficiency savings, increases in solar power, and decreases in demand for electricity will continue as ISO itself has forecast for the next 10 years.

- Existing regional liquefied natural gas (LNG) markets will remain profitable and reliable sources of on-demand winter energy, as they have for the last several years.

Unrealistic Conclusions of CLF’s Consultant


1) Shutting Down Nuclear, Gas, Coal and Oil Plants


The Consultant and CLF do not mention they are opposed to nuclear, gas, coal, and oil plants. They are aiming to shut them down in future years. If they were shut down, about 80% of NE generation would disappear. See below table.


2) Low-Cost Domestic Pipeline Gas versus High-Cost Foreign LNG


The Consultant and CLF are opposed to additional gas lines gas to bring more gas to New England, and are opposed to additional gas storage systems. CLF supports the 100% RE proponents in New York State and Massachusetts, who have blocked pipelines to bring low-cost, domestic natural gas from Pennsylvania's Marcellus shale.


The Consultant and CLF want New England to rely on Russian and other foreign LNG at three times the prices of domestic pipeline gas, to get us through high demand crunches in winter. That LNG would be delivered to a French-owned LNG terminal (owned by ENGIE, a French company), in Boston harbor, by foreign-owned LNG tankers, built in Korea, which would increase our trade deficit.


The Consultant and CLF do not mention New England LNG markets would remain highly profitable and become even more profitable for foreigners, such as Russia, France and Korea.

Pipeline Gas and LNG Wholesale Prices



$/million Btu

US pipeline from Marcellus, PA

 2.5 - 3.0

US LNG from LA to Poland


Russian pipeline to Germany

 4.5 - 5.0

Russian LNG to Boston

 8.0 - 9.0, higher during winter crunches

3) Increased Build-outs of Expensive Wind and Solar


The Consultant and CLF want increased build-outs of heavily subsidized, unreliable, weather-dependent, high-cost, wind and solar, and advocate "batteries". But, as the whole world knows by now, wind and solar in New England are near zero for many hours of the year, due to a lack of wind and a lack of sunshine, as shown by minute-by-minute generation data posted by ISO-NE.


These are not solutions to the threat of rolling blackouts in winter when demand for gas for electricity generation and building heating is high. They are merely solutions to satisfy the profit needs of the renewable-industrial complex, including utilities like GMP and financial advisors like Bloomberg, a financial outfit shilling for RE and spouting nonsense to sell financial products, in a rah-rah manner, to its wealthy entities.

Existing and Future Wind and Solar, as Currently Planned


ISO-NE forecasts, with inputs from the states, NE solar will increase from 2390 MW at end 2017 to 5832.9 MW at end 2027.


- During overcast, rainy weather, which could last 5 - 6 days in summer, solar would be minimal.

- During a Northeast snowstorm almost all panels would be covered with snow, solar would be near zero for days. See table.


ISO-NE forecasts with inputs from states, NE wind will increase from 1400 MW at end 2017 to 8600 MW (on- and offshore) in 2027 - 2035.


- During a wind lull, which could last 5 - 6 days in summer as well in winter, wind (on- and offshore) would be near zero


Capital Costs: Implementing planned wind and solar would require a capital cost of about $50 billion. See table.


- To increase solar from 2.78% in 2017 to 5.82% in 2027 would cost $13.2 billion.

- To increase wind from 2.67% in 2017 to 21.1% in 2027 - 2035 would cost $36.2 billion

- Capital costs include transmission systems

- These systems would produce variable, unreliable electricity at much higher wholesale costs.

- NE wholesale prices have been about 5 c/kWh since 2009, courtesy of low-cost nuclear and domestic gas.









Capital Cost

























Wind and Solar Far From Competitive with Fossil in New England: The Conservation Law Foundation claims renewables are competitive with fossil. Nothing could be further from the truth. Here is a list of NE wholesale prices and Power Purchase Agreement, PPA, prices.


NE field-mounted solar is 12 c/kWh; competitively bid

NE rooftop solar is 18 c/kWh, net-metered; GMP adds an administration fee of 3.813 c/kWh, for a total of 21.813 c/kWh

NE wind offshore is at least 18 c/kWh

NE wind ridgeline is at least 9 c/kWh

DOMESTIC pipeline gas is 5 c/kWh

Russian and Middle East imported LNG is at least 9 c/kWh

NE nuclear is 5 c/kWh

NE hydro is 4 c/kWh; 10c/kWh, if Standard Offer in Vermont.

Hydro-Quebec imported hydro is 6 - 7 c/kWh; GMP pays 5.549 c/kWh under a 20-y contract.

NE annual average wholesale prices have been about 5 c/kWh since 2009, courtesy of low-cost nuclear and domestic gas

Shutting Down Nuclear, Gas, Coal and Oil Plants

That is on the wish list of the 100% RE proponents, who likely never designed, analyzed and operated any energy systems. It sounds very good, but would entail huge build-outs of wind and solar, plus a very large capacity of battery storage, at a turnkey capital cost of about $507 billion (not counting any subsidies, financing costs, decommissioning costs of existing plants, etc.) over a period of at least 20 to 30 years.

Per ISO-NE, in 2017, NE generation was 84.7% of the system load, on an annual basis. See table.


 % of NE generation


Natural gas


At less than 5 c/kWh



At less than 5 c/kWh

RE (wind, solar, wood, landfill methane)


 At 10 c/kWh or more

NE hydro










% of NE system load


Total generation






Pumped storage




1) Here is an article about the mediocre wind and solar conditions in New England.


2) Here is an article of a six-day wind and solar lull in New England just a few weeks ago. Increasing wind and solar 15.7 times existing, plus a 780,000 MWh battery, would STILL not be sufficient to have uninterrupted electricity service. The analysis presented in the article is based on the minute-by-minute data of generation by the various energy sources and demand, on a real-time basis, as reported by ISO-NE.

3) Here is and article of the cold snap Dec 24, 2017 - Jan 8, 2018. It would be utterly stupid/economically unwise to rely on Russian and Middle East LNG, shipped in through the ENGIE LNG terminal in Everett, MA (ENGIE is a French company), in French-owned LNG carriers, which were built in South Korea, at 3 times the price of domestic gas, in the middle of winter, as advocated by 100% RE proponents in Massachusetts and New York, including CLF, which opposedesperately needed new gas lines and gas storage systems. 

4) Russia has NO intention to ship LNG to Europe, as it would undermine its marketing position, which is that pipeline gas is much less costly than LNG. That is true in Europe, as well as in the US.

The US is trying to scaremonger the East Europeans into buying US LNG at about 2 times the cost of Russian pipeline gas.

Poland, Ukraine, etc., earn $billions per year in transit fees. After Nord Stream 2 is built (capacity 55 bcm/y), via the Baltic Sea from Russia directly to Germany, their transit flows and fees would be much less. Follow the money.

Per US Jones law, it is not allowed to ship US LNG between US ports, i.e., Louisiana to Everett, MA, which enables the French to do lucrative business at the expense of the NE economy.


Wind and Solar Conditions in New England: New England has highly variable weather and low-medium quality wind and solar conditions. See NREL wind map and NREL solar map.



- Wind electricity is zero about 30% of the hours of the year (it takes a wind speed of about 7 mph to start the rotors)

- Wind is minimal most early mornings and most late afternoons/early evenings (peak demand hours), especially during summer

- Wind often is minimal 5 - 7 days in a row in summer and winter, as proven by ISO-NE real-time generation data.

- About 60% is generated at night, when demand is much less than during the late afternoons/early evenings

- About 60% is generated in winter.

- During winter, the best wind month is up to 2.5 times the worst summer month

- New England has the lowest capacity factor (about 0.262) of any US region, except the US South. See URL.



- Solar electricity is strictly a midday affair.

- It is zero about 65% of the hours of the year, mostly at night.

- It often is minimal 5 - 7 days in a row in summer and in winter, as proven by ISO-NE real-time generation data.

- It is minimal early mornings and late afternoons/early evenings

- It is minimal much of the winter months

- It is minimal for several days with snow and ice on most of the panels.

- It varies with variable cloudiness, which would excessively disturb distribution grids with many solar systems, as happens in southern California and southern Germany on a daily basis.

- During summer, the best solar month is up to 4 times the worst winter month; that ratio is 6 in Germany.

- New England has the lowest capacity factor (about 0.145, under ideal conditions) of any region in the US, except some parts of the US Northwest.


NOTE: Even if the NE grid had large capacity connections with Canada and New York, any major NE wind lull and any major NE snowfall likely would affect the entire US northeast, i.e., relying on neighboring grids to "help-out" likely would not be feasible. 


Wind Plus Solar:

- Wind plus solar production could be minimal for 5 - 7 days in summer and in winter, with snow and ice on most of the panels, as frequently happens during December, January and February, as proven by ISO-NE real-time generation data.


If we were to rely on wind and solar for most of our electricity, massive energy storage systems (GWh-scale for Vermont, TWh-scale for NE) would be required to cover multi-day wind lulls, multi-day overcast/snowy periods, and seasonal variations. See URLs.


LNG Deliveries to Everett, MA, During 2017/2018 Gas Shortage

Delivering the LNG: The Christophe de Margerie, a Russian-owned icebreaking tanker, named after the deceased former CEO of Total, motored into Isle de Grain, UK, on Dec. 28, according to market information provider ICIS. It unloaded LNG from the new Yamal gas/oil plant in Russia. See URLs and Note.

The Gaselys, a French-owned tanker, arrived at Isle de Grain, UK, which is a large LNG storage facility in the UK that receives gas from many sources, including the Netherlands, Norway, Middle East, Russia, etc.

It took on a cargo of commingled LNG, including LNG from the Christophe de Margerie. See Note.

It left the port on Jan. 7 

It arrived at the ENGIE terminal (owned by a French company) in Everett, Mass., three weeks later and delivered its payload.

Both tankers were built in Korea.

Everett LNG storage is 3.4 bcf, peak delivery 1 bcf, maximum continuous delivery 0.715 bcf.

LNG density = 450 kg/m3

GDF Suez Gaz NA, a French company, owns the LNG plants in Trinidad and Tobago that supply most of the LNG to Everett.

It is amazing how much of the LNG infrastructure, and LNG storage plants, and LNG fleets are built and owned by foreigners! See URL.


NOTE: Shipments of Russian oil and gas are not subject to sanctions, but “US persons and those in the US” are prohibited from financing Novatek, the lead company in the construction of Yamal LNG. The French, our friendly trading partner, took advantage of that.


- Yamal LNG; operated by Yamal LNG company; owned by Russian independent gas producer Novatek (50.1%), Total, a French company (20%), CNPC (20%) and Silk Road Fund (9.9%); capital cost $27 billion; capacity 16.5 million mt LNG, 3 trains.

- Yamal LNG 2: operated by Yamal LNG company; owned by Novatek (60%), Total (20%); Others (20%); capital cost $25.5 billion; capacity 19.8 million mt LNG, 3 trains.


Wind and Solar Electricity is Minuscule After 20 years of Subsidies: Wind and solar (before and after the meter) were 2.7 and 1.97 percent of all electricity on the NE grid in 2017, per ISO-NE. Total RE electricity was 10.17 percent (including before and after the meter solar), after about 20 years of subsidies.


- Past RE development has been very slow even with subsidies.

- Federal investment tax credit subsidies for wind and solar are scheduled to decrease.

- NE will need traditional generators for decades.


NOTE: The realities of life are it took decades to increase:

- Natural gas from a few percent of the US electricity mix to over 30% in 2017

- Nuclear from zero percent of the US electricity mix to about 20% in 2017

- Wind and solar from near zero of the US electricity mix to 6.4% and 1.9%, respectively in 2017, and it would take decades more to have 30% to 40% of the US electricity mix from wind and solar, plus electricity generation uses only about 40% of all US primary energy. Converting that other 60% to renewables would be a Herculean task and very expensive, as shown in this article.



Future Wind and Solar and Serving the NE Load: Based on ISO-NE projections (with inputs from states) wind would be about 21.1%, in about 2035 and solar about 5.82%, in about 2027. Such a large presence of variable intermittent electricity on the NE grid would require peaking, filling-in and balancing, 24/7/365, mostly by a large capacity of gas turbine plants, as is presently the case.


Because the sum of wind and solar is near-zero many hours of the year, especially during the December - February period (as proven by minute-by-minute NE grid operating data for at least the past 10 years), these gas turbine plants*, along with some minor sources, such as refuse, wood, landfill gas, methane, and hydro (NE + imports), and some battery and other storage, would have to be READY, STAFFED AND FUELED TO SERVE THE ENTIRE NE LOAD, 24/7/365, at a minimum reliability of 99.97%. Any electricity passing through storage would have up to a 20% loss on an AC-to-AC basis, which has to be made up with additional generation. See Appendix 1.


Assuming oil, coal and nuclear plants would have been forced into retirement, the following would be required:


-  A much larger capacity of gas turbine plants to replace their electricity (remember wind and solar could be near-zero), and the gas turbine plants would need to be READY, STAFFED AND FUELED.

- Additional gas lines would be needed to provide an increased supply of LOW-COST, DOMESTIC natural gas, or an increased supply of VERY EXPENSIVE (at least 3x domestic prices), RUSSIAN/MIDDLE EAST liquefied natural gas, LNG.


RE proponents and legislatures in Massachusetts and New York State are obstructing any new gas lines to provide increased DOMESTIC natural gas, because that would be “building out fossil infrastructure”, so they want to “temporarily” use (likely for several decades) increased IMPORTED LNG that is at least 3x more expensive. Are these people nuts, subversive or what? Do they have any sense of economics? See Appendix.


RE proponents often repeat the wholesale prices of wind and solar have decreased to about 5 c/kWh or less during the past 10 years and are now competitive with coal and gas at about 5 c/kWh. However, that is only true:


- Because of high subsidies for wind and solar

- In the most windy areas, such as the Great Plains and Texas, and most sunny areas, such as the US Southwest

- The shifting of various wind and solar costs to ratepayers and taxpayers, and to federal and state debts.

In 2017, the wind and solar share was 53% in Denmark, 26% in Germany, and 23% in California. Denmark and Germany have the first and second highest household electric rates in Europe, but France, 75% nuclear, has one of the lowest household rates.


Wind and Solar are Cripples: Wind and solar are cripples that cannot exist on the grid by themselves without huge energy storage systems to cover daily, weekly, monthly and seasonal variations after the “dirty/dangerous” nuclear, coal and gas plants are closed, as demanded by 100% RE proponents.


They cannot be compared with wind and solar, because they require the support of nuclear, coal, gas and hydro plants, that are instantly ready to perform peaking, filling-in and balancing services when wind and solar are insufficient to provide electrical service at a 99.97% reliability, 24/7/365, year after year.


Wind and Solar Lose Market Value at Higher Percent Penetrations: Germany, California, and Denmark are selling highly subsidized wind and solar electricity at near zero and negative wholesale prices to neighboring nations or states when they are producing too much of it during windy and sunny periods.


According to a recent study, on the European grid:


- The economic value of wind decreases about 40%, at about 30% annual penetration on the grid.

- The economic value of solar decreases about 50%, at about 15% annual penetration on the grid.


Here is an example of a Synapse-Energy study.;

From VTDigger article:

"SunCommon Co-President James Moore said the report, commissioned by SunCommon and prepared by Boston-based Synapse Energy Economics, confirmed their suspicion that solar helps lower peak demand during heat waves."

Solar is a midday affair, but peak demands occur in late afternoon/early evening, when solar is minimal (per ISO-NE real time demand data). So any savings also would be minimal.


Synapse ignored costs.

GMP's cost of net metering is 21.793 c/kWh of which 18 c/kWh is paid to solar system owners.

GMP could have bought that MIDDAY electricity, at wholesale prices of about 6 - 7 c/kWh at that demand (see graph of LMP data in study).

Because net-metered is generated close to the user, there are other savings which amount to about 3 c/kWh, as evaluated to GMP.

So the REAL value of solar to GMP is about 10 c/kWh.


That leaves an 11.793 c/kWh difference, which is rolled into rate schedules, and which every ratepayer gets to pay one way or another.

The more net-metered solar, the more other ratepayers pay. 

I am sure it far exceeds any savings calculated in the study.

Also, the more solar, the more other generators have to reduce their outputs.

Such cycling is less efficient (more Btu/kWh, more CO2/kWh)

That inefficiency works its way into upward wholesale prices.


The study is NOT a representation of the real situation.

If fact, it is a gross deception perpetrated on an unsuspecting, unknowing, ignorant, naive lay public.

It deserves a special place.... in the garbage can.




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Comment by Willem Post on July 23, 2018 at 10:26am
Comment by Eskutassis on July 23, 2018 at 8:54am

How can we continue to elect such ignorant politicians that create unscientific dreams that will not serve our energy needs in the future. We have had some of the mot economic and reliable energy production until the misguided RE people started their Pollyanna approach to provide us with power. It is more expensive, is based on an unreliable source, can NEVER be counted on when you really need it like storms and unusually hot or cold periods, and STILL to this date after 40 years of trying has not crossed the 10% contribution line nationwide except in a few very other misguided states.

There has to be a stop to this!!!


Maine as Third World Country:

CMP Transmission Rate Skyrockets 19.6% Due to Wind Power


Click here to read how the Maine ratepayer has been sold down the river by the Angus King cabal.

Maine Center For Public Interest Reporting – Three Part Series: A CRITICAL LOOK AT MAINE’S WIND ACT


(excerpts) From Part 1 – On Maine’s Wind Law “Once the committee passed the wind energy bill on to the full House and Senate, lawmakers there didn’t even debate it. They passed it unanimously and with no discussion. House Majority Leader Hannah Pingree, a Democrat from North Haven, says legislators probably didn’t know how many turbines would be constructed in Maine if the law’s goals were met." . – Maine Center for Public Interest Reporting, August 2010 Part 2 – On Wind and Oil Yet using wind energy doesn’t lower dependence on imported foreign oil. That’s because the majority of imported oil in Maine is used for heating and transportation. And switching our dependence from foreign oil to Maine-produced electricity isn’t likely to happen very soon, says Bartlett. “Right now, people can’t switch to electric cars and heating – if they did, we’d be in trouble.” So was one of the fundamental premises of the task force false, or at least misleading?" Part 3 – On Wind-Required New Transmission Lines Finally, the building of enormous, high-voltage transmission lines that the regional electricity system operator says are required to move substantial amounts of wind power to markets south of Maine was never even discussed by the task force – an omission that Mills said will come to haunt the state.“If you try to put 2,500 or 3,000 megawatts in northern or eastern Maine – oh, my god, try to build the transmission!” said Mills. “It’s not just the towers, it’s the lines – that’s when I begin to think that the goal is a little farfetched.”

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Hannah Pingree on the Maine expedited wind law

Hannah Pingree - Director of Maine's Office of Innovation and the Future

"Once the committee passed the wind energy bill on to the full House and Senate, lawmakers there didn’t even debate it. They passed it unanimously and with no discussion. House Majority Leader Hannah Pingree, a Democrat from North Haven, says legislators probably didn’t know how many turbines would be constructed in Maine."

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