Citizens' Task Force on Wind Power - Maine

Program Failure Alert, Maine NEB and RPS Head on Collision

A real battle is ongoing between several NEB project developers and the Maine PUC. The argument is about the treatment of Renewable Energy Credits(RECs) associated with NEB projects that provide "Behind the Meter" Output.

Behind the Meter is simply the amount of solar panel(s) power that is allocated to a customer's electric demand. It is called "Behind the Meter" because it appears unmetered to the utility and "net metering" is the difference between solar panel power that passes through the meter into the grid (power that is above the need of the household) and power retained to the household.

Before explaining the pursuing issue with Renewable Energy Credits and NEB projects in Maine, consider this from ISO-NE, in their 2023 Annual Report which examines this "behind the meter" and attainable RECs:

ISO-NE 2023 Annual Report Page 50-52

"Wind and Solar Units: We estimate the profitability of wind and solar power investments within the ISO-New England (ISO-NE) power market. We describe the economic viability of wind and solar projects in the region, analyzing how state policies and market conditions interact to affect the profitability of these renewable resources. We assume an onshore wind unit generating power consistent with the typical profile of wind generators in New England, and a solar unit matching the profile of solar units across the region. Both units offer 53% of their generation into the day-ahead energy market at their short-run marginal costs."

"Although solar and wind resources have approximately zero marginal costs, which would imply economic offers at $0/MWh, such resources typically have out-of-market arrangements that provide revenues when they generate energy and thus have an incentive to offer their energy into wholesale markets at negative prices. We assume that the units offer into the day-ahead and real-time energy markets at a price equal to negative one times the annual average Renewable Energy Certificates (REC) price and clear the market whenever the LMP at the Hub exceeds their offers. The units do not provide ancillary services. The units also earn FCA revenues in proportion to the qualified capacities assumed in recent offer review trigger price (ORTP) analyses.

Figure 1-17 summarizes the findings:

This chart shows how much money wind and solar receive from RECs (the hashed yellow is solar, the hashed green is wind)

" This analysis does not account for revenue streams from Power Purchase Agreements (PPAs), focusing instead on Renewable Energy Certificates (RECs). For each unit of energy generated in real-time in a given year, the solar unit earns the average Massachusetts Solar I REC Index price in that year, while the wind unit earns the average Massachusetts Class I REC Index price in that year."

"Solar and wind units earn 18.9% and 39.3% respectively of the $/kW-month FCA revenue for each kW capacity."

"The profitability of wind and solar units in the region is intricately linked with state policies, with both resource types generally relying on additional revenue streams to those in the wholesale markets to be economically viable. Between 2021 and 2023, the solar unit would have earned 80% to 90% of its revenues from the sale of renewable energy credits; similarly, 30% to 50% of the wind unit’s revenue would have been attributable to RECs. While these policies help to meet the region’s clean energy targets, their economic impact on market prices and their operational strategies require careful consideration to maintain market efficiency and reliability. For example, energy market prices may be distorted, with negative clearing prices prevailing whenever solar or wind units benefiting from these policies are marginal. " ISO-NE 2023 Annual Report Page 50 - 52

The issue NEB projects have with the PUC is noted in a case pitting Mars Hill Solar Farm LLC vs. Maine PUC in case docket number 2024-00364 March 3,2025:

The lawyers for Mars Hill Solar bring up a statement within the project's request for inclusion of Maine Renewable Portfolio Standards granting RECs.

The PUC has a stipulation to NEB kilowatt-hour credit program:

"To the extent the output of the Facility is … providing kWh credits to customers under Maine’s NEB Kilowatt-Hour Credit Program, the facility owner must retain GIS certificates or otherwise obtain GIS certificates necessary to satisfy Maine’s RPS for that portion of … the load associated with NEB kWh credits."

For 2025, the RPS requires 61% of applicable electricity load in Maine be from purchase of RECs or alternative compliance payments (ACP): ACP is a cap on REC prices. The REC market is a market that follows supply-demand principles. The fewer the RECs available, the more they cost, eventually paid by ratepayers, of course.

There is a lot of money in RECs and Mars Hill Solar wants that money by selling RECS, not retiring RECs with no payment.

The Maine PUC wants all who rely on the grid for electricity to pay NEB costs. In fact, applying 61% of the RECS generated by NEB projects to the Maine RPS at no cost would significantly reduce costs on the entire rate base.

Mars Hill Solar states its case:

"The NEB program structure means that NEB Project RECs generated in Northern Maine are certifiable by the Maine Commission and only the Maine Commission. The Mars Hill Project has no other RPS certification choice and no other market in which to realize the value of its RECs. This situation is unlike Southern Maine and the Versant former Bangor Hydro District (“BHD”) where solar RECs can be certified by other New England states and sold into other New England state RPS compliance markets without Maine RPS certification."

" In the case of NEB projects in Southern Maine or the Versant BHD, whether to seek Maine RPS certification is characterized by the Commission as “voluntary” in the sense that Maine is one of five New England states in which RPS certifications can be sought. An NEB Project in Southern Maine can therefore have RECs certified and go to other states where its RECs can be sold."

Finally, NextAmp, a solar developer, with many community solar projects in Maine has requested their removal from Maine's RPS certification. NextAmp, an out of state solar developer, has removed 18 solar projects sited in Maine from Class I/ClassIA Maine Renewable Portfolio Certification. These are RECs that would have been recorded and assigned to Maine's RPS for compliance. As they will no longer count in Maine's portfolio, they might be sold in other state's RPS and count towards their RPS compliance requirements.

How many RECs are involved from these 18 projects? Over 90,000 annually. As 61% of this generation will no longer be retired in Maine, 54,900 RECs are lost to help Maine ratepayers to the tune of $2.7 million dollars.

The NEB program needs to be abolished. The RECs derived from the RPS program need elimination.

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U.S. Sen Angus King

THE UNTOLD STORY OF RECORD HILL WIND

The Untold Story of Record Hill Wind, continued

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

******** IF LINKS BELOW DON'T WORK, GOOGLE THEM*********

(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 https://www.pinetreewatchdog.org/wind-power-bandwagon-hits-bumps-in-the-road-3/From 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?" https://www.pinetreewatchdog.org/wind-swept-task-force-set-the-rules/From 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.” https://www.pinetreewatchdog.org/flaws-in-bill-like-skating-with-dull-skates/

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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."

https://pinetreewatch.org/wind-power-bandwagon-hits-bumps-in-the-road-3/

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