New Hampshire accepts Liberty Utilities integrated resource plan

New Hampshire state regulators on Jan. 27 accepted the 2012 Least Cost Integrated Resource Plan (LCIRP) filed in December 2012 by Granite State Electric d/b/a Liberty Utilities and ordered the company to file its next plan by Dec. 1.

The state Public Utilities Commission (PUC) conducted a hearing on the merits last November.

In its Dec. 3, 2012 filing, Liberty described the process it uses to ensure that its transmission and distribution systems are maintained to meet state and federal requirements; the energy markets currently administered by ISO New England (ISO-NE) and how the markets are being structured to procure adequate supply and demand resources to meet reliability objectives at the lowest cost; the transmission and distribution planning processes that Liberty has adopted to ensure reliable operations of the electric grid; the role of demand response and distributed generation resources in the electric markets and how Liberty incorporates such resources into its transmission and distribution planning processes; and Liberty’s participation in the state’s CORE energy efficiency programs and how they interrelate to Liberty’s resource planning.

Liberty’s obligations to meet the power supply needs of its customers who do not directly contract with competitive suppliers are met by third-party energy suppliers through a solicitation process and, as a result, Liberty does not own any generating assets that could meet the power supply needs of those default service customers. On that basis, the PUC added, Liberty requested a waiver of the requirement that it file materials related to the Clean Air Act Amendments of 1990 and the National Energy Policy Act of 1992.

The PUC approved that request.

At the November 2013 hearing, PUC staff expressed its support for the PUC’s acceptance of the current LCIRP filing as adequate under the relevant statutory standards, with the expectation that the next LCIRP filing would include certain enhancements, the PUC said.

Staff recommendations include that Liberty, within its next LCIRP filing, detail how it intends to develop distribution planning performed in the past by National Grid USA.

A National Grid spokesperson told TransmissionHub on Jan. 28 that the company sold its New Hampshire business to Liberty in June 2012 and now provides limited operations support only.

“[New Hampshire] accounted for just 2% of our U.S. business,” the spokesperson said. “The company wanted to concentrate on opportunities in other components of our U.S. operations.”

National Grid is a subsidiary of National Grid plc.

The PUC said that staff also recommended that Liberty better integrate its actual enterprise planning with its LCIRP process and provide, as part of its next LCIRP filing, a business process model that indicates the Liberty personnel responsible for each stage of distribution planning, the inputs involved in each stage, the outputs produced, and the time commitment for each stage.

Furthermore, Liberty should provide more details regarding how demand-side and supply-side options are integrated into the LCIRP, and how environmental, economic, and to some degree, health-related impacts inform Liberty’s planning and decision-making processes.

“[G]iven that Liberty has provided its reasoned perspective on each analysis element required by the LCIRP statute, we will accept the 2012 Liberty LCIRP filing as adequate,” the PUC said, adding that it agrees with staff that a more robust approach to the next LCIRP filing by Liberty, now that Liberty will be in full control of its development, is warranted.

The PUC ordered Liberty to follow the staff’s recommendations as part of its next LCIRP filing, as well as to provide a more comprehensive discussion of how Liberty assesses non-wires alternatives in its distribution planning, and explain, in greater detail, how demand- and supply-side options for distribution planning are integrated by Liberty as part of its planning process.

2012 LCIRP 

In its 2012 filing, Liberty said it is a transmission customer of National Grid as it does not own any transmission facilities. It is Liberty’s responsibility, the company said, to provide National Grid with the electrical system information necessary to allow National Grid to fulfill its transmission owner service requirements.

The information provided to National Grid typically includes electric distribution system peak and off peak loads and the actual or estimated impact of distributed generation and demand-side management efforts.

Due to the interconnected nature of the regional transmission system, National Grid’s transmission system planning process requires extensive interaction and communication with the other transmission owners within the region, Liberty added, noting that that coordination is done through ISO-NE processes that ensure review and input from all appropriate stakeholders.

Liberty said that as a distribution-only utility, it monitors the development of market rules and any proposed changes to the New England market structure to determine how they will affect the company’s customers.

Liberty contracts for electric power for its default service customers in quarterly, short-term commitments through competitive solicitations consistent with PUC orders and regulations. As a result, the company said, it is actively monitoring the wholesale energy markets to ensure it provides its customers with a reliable and least-cost supply of electric power.

Energy market prices in New England closely track movement in natural gas market costs since the marginal unit setting the energy market clearing price is most often a natural gas-fired generator.

Liberty also noted that New England’s Forward Capacity Market (FCM) has procured sufficient capacity in six forward capacity auctions (FCA) to satisfy the region’s installed capacity requirement and assure resource adequacy through the capacity commitment period ending May 31, 2016.

ISO-NE has reported those auctions to have been competitive, producing the expected results given the surplus of existing capacity resources remaining. Liberty also noted that ISO-NE is considering some enhancements to the FCM as part of its strategic planning initiative, which was launched to address risks facing the New England wholesale markets and bulk power system.

Risks include an increased reliance on natural gas-fired capacity, retirement of generators and the integration of a greater level of variable resources.

Liberty added that ISO-NE is considering potential changes to the FCM to better define the core capacity product and create appropriate incentives and consequences for failure to perform; identify system operational needs and translate those into capacity product specifications and delivery incentives/consequences; and better specify system location requirements and market constructs to induce location responses.

ISO-NE is working to provide the proper market incentives for generators to procure firm gas, as well as on advancing the day ahead electric market to better align with trading deadlines in the gas market, the company said.

On the distribution planning process, Liberty said that reflecting the current National Grid process, it will continue to conduct an annual capacity planning process that is intended to identify thermal capacity constraints, ensure adequate delivery voltage and assess the capability of the network to respond to contingencies that might occur. The capacity planning process includes such tasks as reviewing historic loading on each sub-transmission line, substation transformer and distribution feeder.

Among other things, the company also noted that guidelines have been developed for the consideration of non-wires alternatives in the distribution planning process, with the goal being to seek the combination of wires and non-wires alternatives that solves capacity deficiencies in a cost-effective manner considering the net potential benefits and risks.

Non-wire alternatives are screened for initial feasibility, Liberty said, adding that the screening criteria includes that the wires solution, based on engineering judgment, will likely be more than $1m.

About Corina Rivera-Linares 3286 Articles
Corina Rivera-Linares was TransmissionHub’s chief editor until August 2021, as well as part of the team that established TransmissionHub in 2011. Before joining TransmissionHub, Corina covered renewable energy and environmental issues, as well as transmission, generation, regulation, legislation and ISO/RTO matters at SNL Financial from 2005 to 2011. She has also covered such topics as health, politics, and education for weekly newspapers and national magazines.