MA-NY: Double counting of Renewable Energy

William P. Short III and Lisa Linowes|November 13, 2018
MassachusettsNew YorkEnergy Policy

This memo submitted to the Massachusetts Department of Energy Resources (DOER), the agency responsible for managing the Commonwealth's renewable energy policy, examines the possible double counting of renewable resources between the NYISO Control Area and Massachusetts in violation of DOER regulations. The memo presents recommendations for addressing the issue. The findings section of the memo is provided below. The full document can be downloaded from this page.


1. There are 1,846 MW of Capacity Resources listed in the NYISO Gold Book that are qualified as Class I and/or Class II under the Massachusetts RPS. Of that capacity, more than 95% (1,765 MW9) is also recorded in the Gold Book as Capacity Resources for the NYISO Control Area. This capacity is also cited in the NYISO’s 2018 Reliability Needs Assessment (“RNA”) report. (NYISO 2018b,

2. An overlap of capacity resources is prohibited under Massachusetts DOER regulations 225 CMR 14.05(1)(e)(1) and 15.05(1)(e)(1) and potentially signals a double-count of renewable energy between the NYISO Control Area and DOER.

3. The NEPOOL GIS shows that in 2017, nearly 1,800 GWh of unit-specific renewable energy was generated in NYISO from these resources, and delivered into New England, in order to satisfy various New England RPS requirements. (NEPOOL GIS) For 2017, unit-specific renewable energy exports to ISO-NE from NYISO accounted for 41% of all imports from NYISO to ISO-NE across the Northern New York interface with New England. (ISO-NE 2017)

4. It appears that none of 1,800 GWh of unit-specific renewable energy located in New York has been subtracted from New York’s 2017 generation totals, nor is there any indication that the NYISO recognizes this energy as being exported to ISO-NE for the purposes of satisfying various New England-based RPS programs. (NYISO 2018a) 

5. A review of NYISO-sourced FCM resources for January through May 2018 (FCA#8) shows that just six Massachusetts RPS-qualified facilities secured CSOs.10 For FCA#9, the number of unit-specific resources in New York with CSOs dropped to just one facility. Massachusetts Class I and Class II qualified resources that are located outside the ISO-NE control area and are non-intermittent are required to have individual CSOs. (MA REG 2014) (MA REG 2016) Given the lack of public data on FCM re-configuration auctions, it is not possible to determine if other non-intermittent Class I or Class II qualified resources outside of New England have obtained individual CSOs tied to their respective units.


Short Linowes Ma Ny Double Count Memo 2018 11 13 Final

November 1, 2022

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