From: kwberthiaume@hotmail.com
To: lowdemandstudy@state.ma.us; meg.lusardi@massmail.state.ma.us
CC: matthew.beaton@mahouse.gov
Subject: Follow-up Comments - December 18th Meeting on the Low Gas Demand Study
Date: Mon, 22 Dec 2014 13:51:09 -0500
Acting Commissioner Lusardi and Members of the Low Demand Study Team, I offer the
following comments:
1. The New England grid capacity is stated at 32, 247 MW’s as referenced by ISO New England in
their 2013-2014 Regional profile [1]. The grid has been running consistently well below capacity,
ranging from 53% to 60% over the past several months. Of the total electricity generation,
hydro has been supplying on average 11% with renewables (as defined by ISO N.E.) an
additional 7 % of actual output during peak hours – as observed daily from the ISO New
England website “real-time data” [2].
The remainder has been NG, Nuclear, Coal and occasionally Oil generation. As the use of
renewable energy generation continues to increase, the aforementioned fossil fuels and
nuclear will continue to be displaced by clean energy that is NOT subjected to world-price
volatility of fossil fuels nor weather forecasts – example cited below:
a) The price of Natural Gas as of November 5th was at $4.06 / MMBTU’s and the nation’s gas
reserves at 3,571 Bcf [3].
b) Note the price volatility of Natural Gas simply based on the weather forecast.
“Prices/Demand/Supply:
Prices rise on colder weather. Natural gas prices rose at most market locations this week, as
New England and some Southern states experienced early winter weather. The Henry Hub spot
price rose 24 cents from $3.56/MMBtu last Wednesday to $3.80/MMBtu yesterday. The
Algonquin Citygate, which serves Boston, began the week at $4.03/MMBtu and rose to
$6.64/MMBtu on Friday on forecasts for a cold, snowy weekend in New England. The price
dropped back to $4.06/MMBtu at the end of the report week as temperatures moderated.”
2. With the existing New England states Renewable Portfolio Standards set to account for
approximately 8,000 MW’s of wind and solar energy to come on-line between now and 2020
[4,5,6,7,8,9],
the low gas demand study appears to have by-passed or discounted this fact, or is not
distinctly discernable within the four spreadsheets provided.
3. Demand Response, pumped storage, and battery storage were “removed” from the study, as
“None of these resources have annual MMBtu savings” as stated in the Synapse December 18th
slides (slide 12). The purpose of this low-demand study was to determine the extent of the
potential “issue” during Winter Peak-Demand hours. Removing these resources, which could
readily (i.e. today) contribute to the reduction of this peak demand increases the possibility of
unwarranted infrastructure, costs that would ultimately be borne by rate-payers.
4. In addition to the cost of the transmission pipeline, the cost of LDC’s additional gas lines to new
consumers (including street to homes/buildings) needs to be factored into the overall cost of
NG. This was commented previously and appears to not have been factored in to this study, or
it is not discernable based on the less than 72 hours of review time available before the
comments deadline.
5. While it may have been discussed briefly, ‘Repairing gas distribution leaks’ was not mentioned
in the October 31st Memorandum.
 It was mentioned in the October 15, 2014 First Stakeholder Meeting on slide 27 titled
Feasibility Analysis.
 The amount cited by CLF[10] is between 8Bcf and 12Bcf annually. Based on U.S. EIA 2009
information[11] , this equates to savings equal to the amount of annual gas consumption for
an additional 93,000 to 140,000 homes.
 Per caveats listed in the December 18th slides (slide 48, 68), the “Study does not take into
consideration…. legislation on gas leaks”, nor the accompanying benefits and basic savings,
but does recommend “that this information be considered in future studies”.
6. The study is based primarily on ISO New England’s CELT forecast which has proven to be highly
optimistic over the past 3 years.
In year 2011, the CELT forecast was 4.7% higher than actual
Net Energy forecast for 2011: 135,455 (2011 CELT report)
actual for 2011: 129,153 GWH (2012 CELT report)
In year 2012, the CELT forecast was 6.2% higher than actual
Net Energy forecasts for 2012: 137,955; 138,195 -- (2011, 2012 CELT reports)
actual for 2012: 128,047 GWH (2013 CELT report)
In year 2013, the CELT forecast was 6.1% higher than actual
Net Energy forecasts for 2013: 139,230; 138,875; 137,045 -- (2011, 2012, 2013 CELT reports)
actual for 2013: 129,367 GWH (2014 CELT report)
In 2014 the CELT forecast is approximately 9.7% higher than what is actually occurring
Net Energy forecasts for 2014: 140,830; 140,520; 138,910; 138,390 -- (2011, 2012, 2013, 2014
CELT reports)
actual for 2014 through November from the net energy and peak load report jan-nov: 116,154;
assuming 11,000 GWH in December would yield 127,154 GWH
7. As noted and discussed in the December 18th meeting (slide 34), not one of the scenarios
modeled in this low-gas demand study complied with GWSA targets. It is apparent that
additional work is in order if Massachusetts is to not only stabilize its energy infrastructure by
reducing its over-reliance on fossil fuels but to also align with GWSA policies.
Thank you for considering these comments.
Regards,
Kenneth W. Berthiaume
Orange, MA
North Quabbin Pipeline Action
Cc: EEA Secretary-Elect Matthew Beaton
References:
[1]
http://www.iso-ne.com/nwsiss/grid_mkts/key_facts/final_regional_profile_2014.pdf
[2]
http://www.iso-ne.com/
[3]
http://www.eia.gov/naturalgas/weekly/archive/2014/11_06/index.cfm
[4]
http://www.iso-ne.com/nwsiss/grid_mkts/key_facts/final_ma_profile_2013-14.pdf
[5]
http://www.iso-ne.com/nwsiss/grid_mkts/key_facts/final_vt_profile_2014.pdf
[6]
http://www.iso-ne.com/nwsiss/grid_mkts/key_facts/final_me_profile_2014.pdf
[7]
http://www.iso-ne.com/nwsiss/grid_mkts/key_facts/final_ct_profile_2013-14.pdf
[8]
http://www.iso-ne.com/nwsiss/grid_mkts/key_facts/final_nh_profile_2014.pdf
[9]
http://www.iso-ne.com/nwsiss/grid_mkts/key_facts/final_ri_profile_2014.pdf
[10]
The Boston University Study’s findings regarding the number of leaks in Boston are in
line with reporting to the Department of Transportation and the Massachusetts
Department of Public Utilities. See D.P.U. 12-38, Petition of Boston Gas Company and
Colonial Gas Company d/b/a National Grid for Review and Approval of its Targeted
Infrastructure Replacement Factor for 2011, NG-WFF-6 at 3 (Reporting 4,285 leaks on
leakprone pipelines in 2011), available at http://www.env.state.ma.us/dpu/docs/gas/1238/5112ngcmpex2.pdf; National Grid
reported 3,772 leaks on its Boston Gas Company mains to the Department of
Transportation. Gas Distribution Annual Form 2011, PHMSA, Form F 7100.1-1.
[11]
http://www.eia.gov/pub/oil_gas/natural_gas/feature_articles/2010/ngtrendsresidcon/ngtrend
sresidcon.pdf