THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF THE ATTORNEY GENERAL ONE ASHBURTON PLACE BOSTON, MASSACHUSETTS 02108 (617) 727-2200 (617) 727-4765 TTY www.mass.gov/ago February 18, 2020 Marian Swain Energy Policy Analyst Department of Energy Resources 100 Cambridge Street, Suite 1020 Boston, MA 02114 RE: Offshore Wind Transmission Technical Conference Dear Ms. Swain, The Office of the Attorney General (“AGO”) appreciates the opportunity to comment on the Department of Energy Resources’ (“DOER”) January 15, 2020 Request for Comment on Massachusetts Offshore Wind Transmission and Notice of Date for Technical Conference (“Notice”). DOER seeks stakeholder feedback on questions posed regarding the potential for coordinated offshore wind transmission for the region and/or a potential competitive, independent transmission procurement in Massachusetts. The AGO submits these comments recognizing that this comment period is only the first step in stakeholder discussion of offshore wind transmission and that DOER will receive additional feedback at the March 3, 2020 technical session and in potential future comment solicitations. As DOER noted in its May 2019 “Offshore Wind Study,” a competitive, independent transmission procurement, including the benefits to capture, the challenges to overcome, and the mechanics of such a procurement, requires further evaluation. Creative planning and problem- solving is required to maintain the Commonwealth’s role as the nation’s leader in offshore wind development. The AGO agrees and appreciates DOER’s efforts to move the state’s discussion on competitive transmission procurement in the offshore wind industry forward. The AGO looks forward to participating in this proceeding and particularly, having the opportunity to review the evidence and feedback offered by stakeholders. At ISO-NE and the Federal Energy Regulatory Commission, the AGO has been a strong advocate for competitive solicitations for reliability-based transmission projects. The AGO has argued that allowing parties other than electric utilities to bid to build transmission will result in more efficiencies and lower costs for consumers. The AGO appreciates DOER’s efforts to 1 consider the potential for ratepayer savings from competitively procured independent transmission in the new and unique context of the offshore industry. By participating in the DOER process as outlined in the Notice, the AGO seeks to learn from a broad range of stakeholders, including the independent transmission companies, generation developers that build transmission, electric generation supply buyers and/or countersigners, and those involved in the construction trades. The AGO expects that through this process DOER will explore, among other matters: (1) possible financial and construction/project efficiencies; (2) the location of the transmission facilities as related to leaseholds; (3) eligible locations for transmission interconnection; and (4) scale of procurement (i.e., will other states be able to participate). The AGO looks forward to reviewing stakeholder comments, hearing technical session discussions, and welcomes further opportunities to engage with DOER and others on these important issues. Respectfully submitted, MAURA HEALEY ATTORNEY GENERAL /s/ Elizabeth Mahony ____________________ By: Elizabeth Mahony Assistant Attorneys General Office of Ratepayer Advocacy One Ashburton Place Boston, MA 02108 (617) 727-2200 2 faNBARtc' Scaling Renewable Energy February 18,2020 Marian Swain, Energy Policy Analyst Massachusetts Department of Energy Resources 100 Cambridge St., Suite 1020 Boston, MA 02114 Ms. Swain: Anbaric is pleased to submit the attached comments on Massachusetts Offshore Wind Transmission in advance of the Department's March 3'd technical conference . In 2017, Anbaric*' and Ontario Teachers' Pension Plan (OTPP) came together to form Anbaric Development Partners (ADP), a Massachusetts company with its main office in Wakefield that specializes in early stage development of large-scale electric transmission projects with particular focus on submarine electric cables. ADP combines the development and technical expertise of Anbaric - demonstrated by its role in the development of the Neptune and Hudson Transmission Projects in New York - with the solid financial backing of OTTP - one of the world's most successful and irmovative pension plans with more than 5200 billion in assets under management. Anbaric has been active in advancing transmission for offshore wind since 201 I when it introduced the Bay State Offshore Wind Transmission System to the New England ISO and state government agencies. In 2018 the Federal Energy Regulatory Commission (FERC) granted Anbaric authorization to run an open season to charge negotiated rates to users þroducers or consumers of electricity) of common transmission systems for an offshore electric grid.r Today, Anbaric is filing with ISO-NE to connect 1,200 MWs of offshore wind to individual interconnection points at Brayton Point in Somerset and greater Boston where the Mystic power plant's retirement creates an unprecedented opportunity to corìnect the Boston area directly to the wind lease area off the south coast. These two interconnections in Massachusetts are elements of Anbaric's Southern New England Ocean Grid that it proposed to the Bureau of Ocean Energy Management in November of 2019. Fully developed the Southem New England Ocean Grid could deliver up to 16,000 MWs of offshore wind energy to interconnection points in Massachusetts, Connecticut, and Rhode Island. A recent Brattle/Northeast Clean Energy Center/Ml Strategies summit on how to achieve Governor Baker's decarbonization goals indicated Massachusetts would need not one or two 800MW offshore wind procurements but many more. Best practices are emerging in Europe and other US states that incorporate separately owned and carefully planned transmission systems as the key to enabling the large-scale development of this remarkable resource. I hope our comments are useful to the Department and we look forward to participating on March 3'd N Founder & CEO | (See, Anbaric De'¡,elopment Partners, LLC, Order Granting Application for Authorization to Charge Negotiated Rates, Subject to Condition, and Granting Waivers, 162 FERC f 61,097 (2018) in Docket No. ERl3-435-000). 40'1 EdgewaterPlace, Suite680lWakefìeld, M401880lT:781-683-0711 [email protected] lanbaric.com Scaling Renewable Energy Anbaric provides the following comments to questions posted by Department of Energy Resources on January 15, 2020. 1) What are some of the benefits, challenges, and risks of pursuing independent offshore wind (OSW) transmission, whether supported through a separate transmission procurement or not, and what are the highest priority concerns or issues? How do these benefits, challenges, and risks change with the scale of OSW generation development? Offshore wind promises to be one of the primary resources enabling the Commonwealth to meet its decarbonization goals and cut greenhouse gas emissions by at least 80% by 2050 – a goal shared by the five other New England states. A recent study by The Brattle Group 1 finds that to reach this goal as much as two to three thousand megawatts of offshore wind will need to be added each year – or at least 60,000 MW by 2050. It will not be possible to reach this goal without planned, open-access transmission that will create a cost- effective, environmentally responsible, and community-friendly means of bringing thousands of megawatts of wind power onto the terrestrial grid along the coastline of the Commonwealth. The status quo, that is one-at-a-time procurements of 800MW, brought to shore by generators to the closest, lowest cost interconnection point, in an unplanned manner, will soon exhaust the best points of interconnection, easiest routes to shore, and the optimal paths through densely settled coastal communities to the nearest substations. Once these first projects are built without planned, open-access transmission, the remaining projects will face formidable permitting, feasibility, and constructability challenges, likely be much more costly than the earlier projects and difficult to complete, and thus threaten the future of the offshore wind industry in Massachusetts. Without planned, open-access transmission, the potential of offshore wind will not be realized, the industry will grow in fits and starts, if at all, and only a relatively small number of projects will be built, with a few generation companies controlling access to market, laying the foundation for an oligopoly of suppliers, instead of a competitive market. This scenario is already underway, as the first two projects selected will connect to the onshore grid on Cape Cod, within a few miles of each other, and Connecticut selected a project that will connect to the grid in virtually the same location electrically. Anbaric believes the Commonwealth should follow the best practices in offshore wind development in leading European countries, where planned, open-access transmission is the foundation for a competitive, long term offshore wind procurement program. The Commonwealth should develop a long-term, offshore wind transmission strategy that creates a platform for maximum development of offshore wind’s potential, and for maximum competition between generators. The development of transmission independent of generation is the norm in the onshore electricity industry and has been recognized in other states as well as internationally as the best way to connect 1 The Brattle