Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Opportunities Offered by Northeast Electricity
Markets for Canadian Wind Projects

                                       October 2016

                                                      www.poweradvisoryllc.com

Power Advisory LLC 2016. All Rights Reserved.         Prepared for CanWEA
Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Content & Contact

     •   Executive Summary                                  Prepared for CanWEA
     •   Introduction                                              October 2016
     •   Market Basics: ISO-NE
     •   New England Renewable Energy                                John Dalton
         Requirements                                              978-369-2465
     •   Market Basics: NYISO                       jdalton@poweradvisoryllc.com
     •   New York Renewable Energy
         Requirements
                                                              212 Thoreau Street
     •   Economics of Wind in Atlantic
         Canada                                              Concord, MA 01742

     •   Ensuring Opportunities for Wind               www.poweradvisoryllc.com

Power Advisory LLC 2016. All Rights Reserved.   2
Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Introducing Power Advisory

    •   Power Advisory LLC (Power Advisory) is an electricity sector focused management consulting firm. We
        specialize in electricity market analysis and strategy, power procurement, policy development, regulatory and
        litigation support, market design, and project development and feasibility assessment, focusing on North
        American electricity markets.
    •   Our clients include state, provincial and federal governments, public utility regulators, consumer advocates,
        electricity generators (both renewable and conventional), investors, electricity transmission companies, and
        electricity distribution companies.
    •   With offices in Toronto, Metropolitan Boston, and Calgary, a major area of focus is Canadian-US electricity
        trade.
    •   Sample projects include:
            •   Advised the Massachusetts Clean Electricity Partnership, which included HQ Energy Services (U.S.) Inc., on the benefits of
                proposed legislation to import 18.9 TWh per year of clean electricity into New England.
            •   Advised the Atlantic Canada Opportunities Agency on the opportunities offered by the U.S. Northeast for the export of
                clean and renewable energy from Atlantic Canada.
            •   Advising Natural Resources Canada on its Regional Electricity Cooperation and Strategic Infrastructure Initiative, which is
                focused on identifying the most promising regional electricity infrastructure projects with the potential to achieve significant
                greenhouse gas reductions.
            •   Completed for Natural Resources Canada a comprehensive analysis of existing Renewable Portfolio Standard (RPS)
                programs in the US and a broader continental RPS, which would encompass Canada and the US. The study modeled the
                potential for increased renewable energy trade between the Atlantic and New England based on an assessment of which
                renewable resources (Canadian hydro, Canadian wind or New England wind) would be able to most cost effectively satisfy
                forecast RPS demand. After forecasting the relative cost of these resources, the study quantified the level of increases in
                trade, the savings that would be generated and evaluated the proportion of US RPS demand that would be satisfied by
                Canadian renewable energy exports.

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Executive Summary

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Executive Summary
New England has significant requirements for additional
clean energy
    • All six New England states have renewable portfolio standards (RPS). Renewable Energy Credits
      (RECs) are used to ensure compliance with RPS. Class I RECs are among the most valuable and
      wind generation from Quebec and the Maritimes is an eligible Class I resource in each New England
      state.
            •   Of the New England states, only Vermont counts large-scale hydro as a Class I resource.*
            •   Many New England states require that Class I resources be located in adjacent control areas. This precludes
                wind generation from Ontario participating.
            •   There are special requirements for resources that aren’t located in New England.
    • The increase in Class I resource demand in New England from 2015 to 2025 is about 8.8 TWh,
      representing about 2,500 MW of wind.
            •   Rhode Island extended the period over which its Class I RPS requirements increase to 2035 in the most
                recent legislative session. The Massachusetts Legislature considered doubling the rate of increase in its Class
                I RPS, but failed to do so. Some observers expect such action in the next legislative session.
    • Satisfying this Class I demand is becoming increasingly difficult given the distance between
      favorable locations for wind projects and Southern New England load centers and increasing
      transmission congestion where wind projects are being developed.
            •   The New England states are pursuing alternatives to support the funding of required transmission projects to
                deliver this renewable energy to Southern New England load centers. This will increase the cost of these
                projects and help offset a disadvantage to Canadian clean energy resources.

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Executive Summary
Massachusetts recently increased its requirements for
clean energy
    •   In addition, Massachusetts enacted legislation calling for 9.45 TWh per year of clean energy generation. Under this
        legislation clean energy generation includes large scale hydro as well as Class I renewable resources.
            •   This 9.45 TWh of clean energy isn’t necessarily in addition to the 8.8 TWh of Class I resources given that any Class I resources
                used to satisfy the clean energy mandate would also address Massachusetts Class I requirements.
            •   The greater value offered by the RECs produced by Class I renewable resources would be recognized, allowing for a higher price
                for wind generation from Eastern Canada relative to large scale hydro.
    •   The legislation also specifies that preference will be given to proposals that combine new Class I renewable
        portfolio eligible resources and firm hydroelectric generation. This suggests that adding wind generation to
        hydroelectric generation will yield additional value beyond the value of the Class I RECs.
    •   Wind generation would offer additional value relative to hydro given the state’s requirements for an additional 4.4
        TWh of Class I generation. The incremental value of Class I RECs amounts to about US$35 to US$50/MWh.
            •   Current Class I REC prices in New England range from $32 to $38/MWh, but are expected to increase with the loss of the
                Production Tax Credit, which will increase the effective cost of wind generation, the predominant form of new Class I generation
                in New England.
    •   In addition, the New England states as part of The Conference of New England Governors and Eastern Canadian
        Premiers have agreed to cut CO2 emissions to as much as 45% below 1990 levels by 2030. This will require
        additional volumes of clean energy, with the actual volume depending on electricity demand growth and the future
        composition of electricity resources.

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Executive Summary

New York also has ambitious renewable energy goals

         • New York’s State Energy Plan established a goal that 50% of the state’s electricity be
           generated by renewable energy sources by 2030 (“50 by 30” goal)
         • With renewables providing about 26% of the state’s existing electricity requirements,
           this would require an increase in renewable energy of over 30 TWh by 2030.
         • To achieve this aggressive target the state is pursuing a range of programs including:
                 • Creating a requirement for regular Renewable Energy Certificate (REC) procurements.
                   These are forecast to represent an incremental demand for RECs of over 7 TWh per year by
                   2021, the last year for which the Public Service Commission has established a target. With
                   increases beyond this in future years.
                 • The Public Service Commission is currently only proposing to procure RECs, developers will
                   have to bear the risks of the market price for energy or hedge this risk with a third-party.

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Executive Summary
Both New England and New York have significant
need for additional renewable resources

           • As shown the six New England states are forecast to have                                   2015 to 2025 Incr.
             a need for an additional 8.8 TWh per year of renewable                    State            Class I Demand (TWh)
             energy from 2015 to 2025.                                                 Connecticut                           2.1
                   •   This is largely in addition to the 9.45 TWh per year of clean   Maine                                 0.2
                       energy that Massachusetts electric distribution companies       Massachusetts                         4.4
                       are mandated to procure under recent legislation.               New Hampshire                         0.9
                                                                                       Rhode Island                          1.0
                   •   Class I resources that are used to satisfy the 9.45 TWh of
                       clean energy would also assist Massachusetts in realizing its   Vermont                               0.2
                       4.4 TWh Class I resource target. Therefore, the 9.45 TWh      Total                                   8.8
                       and 8.8 TWh are not necessarily additive.
           • New York has an incremental demand for Tier 1
             resources of about 7.5 TWh per year by 2021 and 30                                       Incr. Tier 1 Demand
             TWh per year by 2030.                                                                   2017 to 2021 By 2030
                                                                                        New York     7.5 TWh     30 TWh
                   •   Tier 1 resources are required to have achieved commercial
                       operation after January 1, 2015.

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Executive Summary
The attractiveness of opportunities for US
Northeast electricity markets vary by province

           • As discussed, increasing requirements for clean energy in both New England and New
             York are creating opportunities for wind projects in Quebec, Atlantic Canada and
             Ontario.
           • Wind projects in Quebec have ready access to either New England or New York given
             Hydro-Quebec TransEnergie interconnections with both.
           • Given transmission interconnections and tariffs, New England represents the primary
             opportunity for wind projects in Atlantic Canada.
                   •   Hydro-Quebec transmission tariff at $Cdn8/MWh is costly for Atlantic Canada projects wheeling
                       to New York.
           • New York is an opportunity for wind projects in Ontario given the interties between
             these two markets. New England REC requirements typically require that projects be in
             adjacent control area, precluding Ontario wind from participating in the New England
             REC market. Access to New England from Ontario is also adversely affected by the
             relatively high cost of transmission access through Quebec and the difficulties of
             wheeling through New York to access New England.

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Opportunities Offered by Northeast Electricity Markets for Canadian Wind Projects - October 2016
Introduction

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Introduction

Overview of Scope of Project

           • Power Advisory engaged by CanWEA to review
             opportunities offered by the US Northeast for Canadian
             wind projects
           • We proposed to undertake a review of three primary issues
                   • Review specific market opportunities in New England and
                     New York for Eastern Canadian wind projects
                   • Evaluate business case for wind project development in
                     Eastern Canada for export into US Northeast
                   • Assess requirements for Eastern Canadian wind projects to
                     participate in US Northeast electricity markets
                   • Identify approaches that could be used to allow Canadian
                     wind projects to participate as consortium members with
                     Canadian hydro suppliers and transmission project
                     developers

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Market Basics: ISO-NE
           Factors Contributing to the Need for Additional Clean Energy

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Market Basics: ISO-NE

Demand forecast

           • New England energy demand is forecasted to decline by 0.2%
             annually, from 128,014 GWh in 2016 to 125,213 GWh in 2025.
           • Peak demand is forecasted to grow 0.2% annually under normal
             weather conditions
           • Energy efficiency and distributed generation will flatten demand
             and slow peak demand growth
                   • Without it, energy and peak demand growth rates would be 1.0% and
                     1.1% respectively
                   • The New England states have ambitious, well funded and highly rated
                     energy efficiency programs
                   • The penetration of rooftop solar is also reducing customer
                     requirements

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Market Basics: ISO-NE
New England’s electricity market is highly reliant on
natural gas
    • Natural gas-fired generation                            2015 ISO-NE Resource Mix
      provided almost 50% of the
                                                Hydro & Other Renewables, 15%
      region’s total generation in                                              Pumped Storage, 1%
      2015
    • Nuclear generation provides
      about 30% of total                           Oil, 2%
      generation and represents                 Coal, 4%
      the largest single source of
      clean energy. However, it is                                              Natural Gas, 49%

      under increasing pressure
                                                             Nuclear, 30%
    • Renewables (including
      hydro) represent about 15%
    • Oil and coal-fired generation
      have declined significantly
      and total about 6%

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Market Basics: ISO-NE

Electricity market driven by natural gas

                                        Percent of Total Electric Energy Production by Fuel Type

                                                                                       49%
                                                                                    44%

                                34%
                             31%   30%
                                                22%
                                                              18%
                                                                                 15%
                                                                                               7% 8% 7%    8% 9% 9%
                                                                    5% 4%
                                                      1% 2%

                               Nuclear                Oil       Coal             Natural Gas    Hydro     Renewables

                                                                2000        2014       2015

         • Natural gas increased from 15% in 2000 to almost 50% in 2015
         • 80% of capacity built since 1997 and more than 60% of new proposed generation (about
           8,200 MW) relies on natural gas
         • Natural-gas-fired generators set real-time electricity prices 75% of the time in 2015
         • The modest increase in renewables is attributable to a decline in energy output of biomass
           units from 2000 to 2014-15, which has been offset by increased production from wind,
           solar and hydro resources

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Market Basics: ISO-NE

Natural gas contributes to electricity price volatility

    •   Natural gas pipelines serving New England
        are constrained throughout much of the
        winter given increasing demands and
        reduced supplies from Atlantic Canada.
    •   With limited pipeline capacity on cold winter
        days gas-fired generators compete with local
        gas distribution companies for natural gas
        supplies. This can lead to very high prices.
    •   A major contributor to the inadequate
        pipeline capacity is the unwillingness of
        natural gas-fired generators to contract for
        firm pipeline supplies.
    •   Recent reductions in oil prices have
        moderated the impact of natural gas prices
        on electricity prices in New England. Two
        factors have contributed to this: (1) dual-
        fuel units with oil burning capability are now
        cost competitive when burning oil; and (2)       Source: ISO-NE

        lower oil prices have also reduced prices in
                                                          Natural gas prices and wholesale electricity prices
        the World LNG market, which has increased
        LNG deliveries to New England and lowered                         are closely linked
        LNG prices.

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Market Basics: ISO-NE
Natural gas infrastructure inadequacy affects the
fuel mix
    •   During most of the winter, existing pipelines
        in the New England region are running at or
        near maximum capacity
    •   As natural gas demand approaches pipeline
        capacity natural gas prices increase. As
        natural gas prices increase oil-fired
        resources are used to meet demand
            •   Over 30% of ISO-NE’s gas-fired capacity is
                dual-fuel
            •   These conventional resources are older and
                more expensive to run
    •   At lower natural gas prices, natural gas-fired
        generation is typically cheaper than coal-
        fired generation. New England’s coal-fired
        units have higher coal costs given
        transportation costs and environmental
        requirements for low sulphur content.
                                                             Source: ISO-NE
    •   Switching to conventional fossil fuel
        resources is problematic due to increasingly          A comparison of the differences in fuel mix during an average day
        stringent GHG emission requirements                                        and a cold winter day

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Market Basics: ISO-NE
Natural gas pipeline constraints affect natural gas
prices
                                                              Algonquin Citygate Basis to Henry Hub
    • The figure to the right shows the                     ($/MMBtu) versus Pipeline Utilization Rates
      resulting increases in Algonquin basis
      differential (the premium paid by
      customers in New England) as pipeline
      utilization increases.
    • Proposals to expand pipeline capacity
      to New England are receiving
      increasing opposition.
    • The Massachusetts State Supreme
      Court voided a Mass Department of
      Public Utilities decision that allowed
      electric utilities to contract for
      additional natural gas pipeline
      capacity to lower electricity prices.
                                                        Source: ICF
            •   Spectra Pipelines, Eversource and
                National Grid had proposed the
                Access Northeast pipeline expansion          Prices increase at higher pipeline
                project to provide an additional 9.25                 utilization levels
                MMcf/day of capacity.

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Market Basics: ISO-NE
Non-gas capacity retirements are increasing,
exacerbating natural gas constraints
    • Current low natural gas prices are
      driving down wholesale electricity
      prices, displacing higher cost non-
      natural gas-fired resources
            •   Older less efficient plants are often
                unable to recover the costs of
                maintaining their plants and in some
                instances can’t afford the costs of
                environmental compliance
                technologies necessary to meet new
                environmental requirements
    • More than 4,200 MW has or will be
      retiring soon
            •   Another 6,000 MW is at risk
    • ISO-NE estimates that about 30% of
      the region’s generating capacity is at                  Source: ISO-NE
      risk of retiring by 2020
                                                        Most of the retiring capacity will be replaced by new natural gas
                                                          capacity, however, these non-gas resources are necessary
                                                               during the winter when gas resources are limited

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Market Basics: ISO-NE
Low wholesale electricity prices contributing to
nuclear unit closures
           • The Vermont Yankee nuclear plant (620 MW) closed in 2014 and Pilgrim nuclear plant
             (680 MW) is scheduled to close in 2019. These two units provided about 10 TWh of
             carbon-free electricity and about 8% of New England’s total electricity requirements.
                   •   The Massachusetts legislative requirement to procure 9.45 TWh per year of clean energy can be
                       viewed as a response to these closures.
           • New England’s GHG emissions increased in 2015 for the first time in 5 years as a result of
             the closure of Vermont Yankee. The loss of both nuclear units makes it more difficult for
             the region to satisfy its Regional Greenhouse Gas Initiative (RGGI) emission reduction
             targets.
           • RGGI is a cooperative effort to cap and reduce CO2 emissions from the electricity sector.
             Participating states use a cap and trade framework under which all large fossil-fueled
             generators in the participating states have to hold allowances equal to their CO2
             emissions over a three-year period. Allowances can be obtained through quarterly
             auctions or offsetting CO2 emissions outside the electricity sector. The RGGI CO2 cap
             declines 2.5 percent each year from 2015 to 2020.

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Market Basics: ISO-NE

New England Energy Import Capability
                                                     Quebec-New England
                                                          (Phase II):
                                                         1,400 MW*
                               Quebec-New England                                         Maritime - New England:
                                   (Highgate):                                                   1,000 MW
                                    217 MW

    New York - New England
     [8 AC ties]: 1,400MW

                                                                          Cross-Sound Cable :
*Capacity import capability
                                                                               330 MW
Source: Adapted from ISO-NE “Overview and Regional
Update” 2015 Slide 6

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Market Basics: ISO-NE

Imports into New England
                                                 Net Flow over the External Ties (GWh)
                         5000

                             0

                        -5000
                                 -5539
                       -10000
                                                -10142
                       -15000                                   -12648

                       -20000
                                                                                   -18961
                                                                                                -20696      -20997
                       -25000
                                      2010              2011         2012              2013         2014        2015

                                                Total      New Brunswick         Hydro-Quebec   New York
                        Source: ISO-NE

         New England will continue to attract imports given the
         availability of low variable cost energy in Eastern
         Canada, primarily from Hydro-Quebec.

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New England Renewable
           Requirements

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Renewable Energy Requirements

New England State RPS
    •   Renewable Portfolio Standards (RPS) are                              State Class I REC Requirements (in GWh)
        state-determined regulatory mandates that          25,000
        require a minimum percentage of retail
        customer electricity requirements to be            20,000
        served using renewable energy
    •   RPS use Renewable Energy Credits (RECs) for        15,000

        compliance
                                                           10,000
            •   Each REC is equivalent to 1MWh generated
                from a renewable resource
                                                            5,000
    •   The highest value RECs (other than those for
        solar PV) are Class I RECs                             -
                                                                      2015   2016   2017        2018   2019   2020   2021    2022   2023   2024   2025
    •   The demand for Class I RECs is forecast to
                                                                                           CT     ME    MA     NH    RI     VT
        grow by almost 9 TWH by 2025
    •   Satisfying this demand is becoming
        increasingly difficult given the distance
        between favorable locations for wind                        Of the New England states, only Vermont counts large-
        projects (i.e., Maine) and Southern New
        England load centers and increasing
                                                                            scale hydroelectricity in its Class I RPS*
        transmission congestion where wind projects
        are being developed.
            •   Permitting wind projects has always been      * Connecticut allows large-scale hydro projects to satisfy its
                difficult in New England.                     Class I RPS targets if a shortage of Class I RECs is deemed
                                                              to exist.
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Renewable Energy Requirements

Class I Renewables vary by state
                                                                                              Ocean
                                                             Geoth-   Landfill   Anaerobic   Thermal,     Small        Large
        State           Wind       Solar        Fuel Cells                                                                     Biomass
                                                             ermal      Gas      Digestion    Wave,       Hydro        Hydro
                                                                                               Tidal

  Connecticut                                                                                           Certain run-             Low
                          ✓          ✓              ✓          ✓         ✓          ✓           ✓                       X
                                                                                                        of-the-river           emission

  Maine                                                                                                  < 100 MW,
                          ✓          ✓              ✓          ✓         ✓          X           ✓                       X         ✓
                                                                                                        fish passage

  Massachusetts                                                                                          New,
Renewable Energy Requirements
Wind generation represents majority of new renewables
in ISO-NE
   • Currently over 800 MW of wind capacity
     and 4,200 MW of proposed wind
     capacity
                                                   New England Proposed Generation
           •   Approximately 13,000 MW total
               proposed generation in the ISO-NE                 6%
               Generation Interconnection Queue
   • Wind resources are far from demand                   30%
     centers, therefore increased wind
     generation will require significant
                                                                         64%

     transmission upgrades
   • ISO-NE market structure has required              Natural Gas    Wind     Other
     that wind project developers pay for
     most required transmission upgrades.
     Difficult to get wind project developers
     to band together to support such
     upgrades
                                                     Of the approximate 4,200 MW of proposed wind capacity in the
   • Tri-State Clean Energy RFP provided a            ISO-NE interconnection queue, about 3,600 MW is located in
     mechanism to allow for the                       Maine. However, Maine’s transmission system is increasingly
     consideration of necessary transmission           congested, and will require upgrades to accommodate this
                                                                      additional wind generation.
     developments

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Renewable Energy Requirements
Large hydro doesn’t qualify as a Class I resource for most
New England States
   • The Class I RPS
     eligibility criteria are
     shown in the table to
     the right.
   • Many states limit the
     size of hydro projects
     to no more than 30
     MW.
   • Hydro projects would
     realize a higher
     capacity value and
     corresponding capacity
     payments and those
     with storage capability
     can target output to
     higher priced periods.

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Renewable Energy Requirements

Massachusetts Energy Bill
       •   Passed MA Legislature July 31, 2016
       •   Calls for the procurement of 1.6 GW of offshore wind by 2027 and 9.45 TWh/year of clean energy
           generation by 2022
               •   Clean energy generation includes:
                       •   Firm service hydroelectric generation
                       •   New Class I RPS eligible resources firmed up with firm service hydroelectric generation
                       •   New Class I RPS eligible resources

       •   Competitive solicitation process to be used to select proposals. Allows multiple solicitations, but Power
           Advisory expects state to issue one solicitation for clean energy generation to enhance competitive pressure
       •   The following criteria to be used when procuring clean energy:
               •   Enhance electricity reliability
               •   Help reduce winter electricity price spikes and guarantee energy delivery in the winter months
               •   Be cost effective to ratepayers, including economic & environmental benefits
               •   Mitigate transmission costs; any overruns are not borne by ratepayers
               •   Demonstrate project viability in a commercially reasonable timeframe
               •   Allow resources to be paired with energy storage systems
               •   Mitigate environmental impacts and promote economic development in Massachusetts, if possible
       •   The legislation also indicates that preference will be given to proposals that combine new Class I renewable
           portfolio eligible resources and firm hydroelectric generation. This suggests that adding wind generation to
           hydroelectric generation will yield additional value beyond the value of the Class I RECs.

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Market Basics: NYISO
           NYISO is responsible for administering the organized electricity
           markets that operate in New York State

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Market Basics: NYISO

Demand Forecast
                                           Electric Energy Usage Trends in New York State: 2000-2026

                             Source: NYISO Power Trends 2016

         • Electricity demand is forecasted to decline by 0.16% annually over the next
           decade due to energy efficiency and distributed energy resources
         • Peak demand is forecasted to grow 0.21% annually

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Market Basics: NYISO
New York’s electricity market is also highly reliant
on natural gas
                                                             2015 NYISO Resource Mix
       • Natural gas (including
                                                                               Natural Gas,
         dual fuel) make up                                                        7%
         44% of the state’s                      Hydro &

         energy production                         Other
                                                Renewables,
         and 69% of the                            24%

         downstate region’s                                                        Natural
         energy production                                                         Gas/ Oil,
                                                                                     37%
       • Natural gas-fired
         projects represent                        Oil, 1%
                                                   Coal, 1%
         about 65% of all
                                                                    Nuclear,
         proposed generating                                         31%
         capacity in New York

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Market Basics: NYISO
New York electricity market in flux given low wholesale
electricity prices and resulting retirements
          • Due to recent low natural gas prices, wholesales electricity prices hit a 15-year low in
            2015
                  •    About 2,300 MW of New York’s generation capacity is planning to retire or suspend operation
                       between 2016 and 2018. This includes 1,435 MW of nuclear capacity, which is located Upstate
                           •   New York has developed a Clean Energy Standard to promote the development of additional clean
                               energy and to support the state’s nuclear generating units
                  •    The electricity market’s ability to respond to these changes is hampered by transmission
                       constraints
          • Increasingly stringent environmental quality goals, such as the Clean Energy Standard
            and stayed federal Clean Power Plan, represent new challenges to existing generation
                  •    NYISO estimates that 75 – 80% of the system’s generating capacity will be affected by new and
                       proposed environmental regulations including the Clean Power Plan and a diverse set of
                       environmental regulations such as control technology requirements for nitrogen oxides (NOx),
                       mercury from coal plant emissions, interstate transportation of air emissions
                           •   The impacts of these requirements will vary and are likely to result in additional capital expenditures for
                               affected units and higher operating costs. These requirements aren’t likely to result in a significant
                               increase in renewables beyond that already called for.

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Market Basics: NYISO

Transmission is a challenge as well as an opportunity

      • About 58% of the State’s electricity is used downstate (New York City, Long Island, Lower
        Hudson Valley) while only 40% of the generating capacity is located downstate
              •   The disconnect between where generation and demand are located causes many existing transmission
                  facilities to be heavily loaded
      • 80% of NYISO’s 11,124 miles of transmission lines went into service before 1980, meaning
        about 4,700 miles will require replacement or upgrades within the next 30 years
      • Increasing transmission capability across the state can also help enable clean energy
              •   All of New York’s existing and proposed wind projects and its major hydro resources are located far
                  from demand centers in the northern and western regions of the state
              •   The interties that Canadian resources access are also far from the high demand regions
              •   Transmission congestion in Western New York is contributed to by increasing imports from Ontario
      • Several merchant transmission projects have been proposed to address transmission
        constraints and develop additional clean energy downstate
              •   The Champlain Hudson Power Express is the most developed and has the vast majority of its required
                  permits. It has stalled given low natural gas prices which have depressed the price differentials that drive
                  such projects.
                      •   Champlain Hudson Power Express is a high voltage direct current transmission that would deliver 1,000 MW into
                          New York metropolitan area from Quebec.

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Market Basics: NYISO

Nuclear decommissioning in New York’s future
                                                      New York State Nuclear Generation Plants
                             Plant Name              Location        Nameplate         Operating                      Notes
                                                                      Capacity          License
                                                                       (MW)            Expiration
                       Indian Point, Unit 2       Buchanan NY            1,032          9/28/2013      Operating under “timely renewal”
                                                                                                       until NRC makes final ruling on
                                                                                                       license renewal application
                       Indian Point, Unit 3       Buchanan NY            1,051         12/12/2015      Same as Indian Point Unit 2
                       James A. FitzPatrick       Scriba NY               838          10/17/2034      Was set to cease operation
                                                                                                       January 2017, but sale to Exelon
                                                                                                       appears to be moving forward.
                                                                                                       However, sale depends on CES
                                                                                                       being adopted and final terms
                       Nine Mile Point, Unit 1    Scriba NY               621           8/22/2029      Exelon Corp. has discussed
                                                                                                       financial struggles, mentioning
                                                                                                       need for support, though it has
                                                                                                       not discussed early
                                                                                                       decommissioning formally
                       Nine Mile Point, Unit 2    Scriba NY              1,140         10/31/2046      Same as Nine Mile Point Unit 1
                       R.E. Ginna                 Ontario NY              610          9/18/2029       Operating under reliability
                                                                                                       support services agreement with
                                                                                                       NY PSC, in effect until April 2017

                      Source: Information Digest 2015 – 2016, US Nuclear Regulatory Commission, Appendix A

         •   All 6 of New York’s operating nuclear plants are facing financial– and some, regulatory– struggles
         •   The potential retirement of the two nuclear plants at Indian Point Energy Center are a particular reliability concern, as their
             loss would require 500 MW of new capacity to be built in the demand-heavy region of Southeast New York
                 •   Having passed their license expiration dates, the plants are currently operating under “timely renewal”, though due to numerous
                     safety and environmental concerns, license non-renewal is possible.

Power Advisory LLC 2016. All Rights Reserved.                                34
New York State Renewable
           Requirements
           The Clean Energy Standard

Power Advisory LLC 2016. All Rights Reserved.   35
Clean Energy Standard
New York mandates ambitious renewable energy goals
through the Clean Energy Standard (CES)

         • Following the expiration of New York’s Renewable Portfolio Standard in 2015, the
           Department of Public Service (DPS) was directed to develop a standard that
           mandates the State Energy Plan (SEP) goal that 50% of the state’s electricity is
           generated by renewable energy sources by 2030 (“50 by 30” goal)
                 • This is a strategy to reach the broader goal of reducing statewide greenhouse gas
                   emissions by 40% by 2030
         • The Clean Energy Standard was adopted on August 1, 2016 with the following goals:
                 • Encourage consumer-initiated clean energy purchases or investments through program
                   and market structures
                 • Obligate load serving entities (LSEs) to financially support new renewable generation
                   resources to serve their retail customers
                 • Create a requirement for regular REC procurement solicitations
                 • Obligate distribution utilities on behalf of all retail customers to continue to financially
                   support the maintenance of certain existing at-risk small hydro, wind and biomass
                   generation facilities
                 • Obligate LSEs to financially support the preservation of existing zero-emissions at-risk
                   nuclear facilities to serve their retail customers

Power Advisory LLC 2016. All Rights Reserved.                 36
Clean Energy Standard

CES will require significant changes

           • To fulfill this goal, it is estimated that New York will need to
             increase energy from renewable resources by 33,700 GWh from
             current levels
                   • NYISO equates this to about 25,000 MW of solar PV, 15,000 MW of wind,
                     or 4,000 MW of hydropower
           • The Department of Public Service (DPS) Staff CES Cost Study,
             released in May, found material internal transmission constraints
             in Ontario and thus concluded that much of the supply from
             northern and western Ontario, especially if located within or
             blocked from getting through the Toronto area, was inaccessible
             to New York without additional transmission capacity.
             Furthermore, currently, all interties carrying energy from Quebec
             to New York are fully utilized in most hours.

Power Advisory LLC 2016. All Rights Reserved.       37
Clean Energy Standard

The CES builds on existing initiatives
           • The CES builds on the regulatory and retail market changes
             that are already being pursued under the state’s Reforming
             the Energy Vision (REV) initiative
                   • Through REV, New York has formed various initiatives that
                     work to reduce the soft costs and other market barriers facing
                     renewable energy, support energy efficiency in buildings, help
                     finance distributed energy, integrate advanced storage and
                     load control technologies into the electricity system and more.
           • Whereas REV will continue to support distributed resources
             and their integration into the grid, the CES will provide the
             broader scale and certainty necessary to ensure that markets
             are created that have the scale and scope necessary to
             attract investment and reduces costs

Power Advisory LLC 2016. All Rights Reserved.   38
Clean Energy Standard

CES mechanisms

           • As a fully restructured state, New York has historically met
             its clean energy goals through a system which treated the
             compliance obligation as a delivery function of the
             distribution utility with RECs centrally-procured for utilities
             by NYSERDA under long-term contracts, intended to
             provide greater certainty to generators and lower REC costs
             for customers.
           • The CES retains the benefit of New York’s unique central
             procurement system but shifts the compliance obligation
             from the distribution utility to the retail commodity supplier
             LSE.

Power Advisory LLC 2016. All Rights Reserved.   39
Clean Energy Standard: Renewable Energy Standard
The CES is divided into a Renewable Energy Standard
and a Zero-Emissions Credit (ZEC) requirement

    Renewable Energy Standard
            • Tier 1: New Renewable Resources
                    • Requires all LSEs to procure new renewable resources (with RECs as evidence) at
                      increasing rates (see Table A on following page)
                            •   Specific goals are established for 2017 to 2021, with subsequent goals established in triennial reviews

                    • Table B on following page shows the projected statewide output from new
                      renewable resources due to these requirements
                    • LSEs can meet their obligations by purchasing RECs from NYSERDA, purchasing
                      qualified RECs from other sources or by making Alternative Compliance
                      Payments to NYSERDA
                            •   Resources must have come into operation after Jan 1, 2015 in order to be eligible

                    • This order requires NYSERDA to conduct regularly scheduled solicitations for
                      long-term procurement of RECs to achieve the following minimum result (see
                      Table D on following page)
                            •   Expected procurements of new large-scale renewable generation is approximately 1,869.4 GWh per
                                year, which is twice the level of RPS procurements during 2011 to 2015

                    • ZECs are discussed in a subsequent slide

Power Advisory LLC 2016. All Rights Reserved.                         40
Clean Energy Standard: Renewable Energy Standard

CES RES: Tier 1 tables
Table A. Required Procurement Table B. Expected Statewide Yield (MWhs)
                    % of LSE                              Distribution                                          Direct        Statewide
      Year                                      Year                               LIPA           NYPA
                   total load                           Utilities & ESCOs                                     Customers         Total
      2017            0.6%
                                                2017          705,595             120,244        139,225        8,936          974,000
      2018            1.1%
                                                2018        1,261,429             214,967        248,900       15,975         1,741,270
      2019            2.0%                      2019        2,263,192             385,682        446,563       28,662         3,124,100
      2020            3.4%                      2020        3,841,197             654,599        757,928       48,647         5,302,371
      2021            4.8%                      2021        5,455,424             929,688        1,076,440     69,090         7,530,642

Table C. Expected Renewable Resources                           Table D. Long-term Procurement of RECs
                      Renewable                 % Renewable                   Anticipated Procurement        Minimum Procurement
                                                                  Year
                   Resource (MWhs)               Resources                          Target (MWh)                 Target (MWh)
    Baseline            41,296,000                 25.71%         2017               1,966,449                    1,769,804
     2017               42,270,000                 26.32%
                                                                  2018               2,022,004                    1,819,804
     2018               43,037,270                 26.81%
                                                                  2019               2,077,560                    1,869,804
     2019               44,420,100                 27.69%
                                                                  2020               2,133,116                    1,919,804
     2020               46,598,371                 29.08%
     2021               48,826,642                 30.54%         2021               2,188,671                    1,969,804

Power Advisory LLC 2016. All Rights Reserved.                            41
Clean Energy Standard: Renewable Energy Standard
Fixed-price RECs will be procured consistent with past
practice

    • Staff had argued for the procurement of a
      bundled (RECs and energy) product
            • Commission determined that larger procurement
              volumes and elimination of budget cap will attract
              more developers, than past NYSERDA processes
                    • Ensuring success of REC-only procurement
            • Effectiveness of REC-only procurement will be
              evaluated in the triennial review
            • Net effect is that renewable project developers must
              manage energy price risks
Power Advisory LLC 2016. All Rights Reserved.             42
Clean Energy Standard: Renewable Energy Standard

CES RES: Tier 2
        Renewable Energy Standard
                • Tier 2: Maintenance
                        • Does not include the support payments for existing
                          renewable generation as recommended in the Staff White
                          Paper
                                • Noted that REC support payments in White Paper were either
                                  premature, unnecessary, or already provided for under the current
                                  maintenance program
                        • Consists of a maintenance program virtually identical to the
                          one that existed under the existing RPS
                • Offshore Wind
                        • NYSERDA to identify appropriate mechanisms to achieve
                          goal of developing offshore wind

Power Advisory LLC 2016. All Rights Reserved.               43
Clean Energy Standard: Zero-Emission Credits

CES Tier 3: Existing nuclear facilities

       • NYSERDA will offer qualifying nuclear facilities multi-year contracts for the
         purchase of Zero-Emission Credits (ZECs)
               • For contracts awarded prior to April 1, 2017, contract period will run until March 31,
                 2029
                       •   ZEC: $17.48/ MWh for the first two year tranche (Tranche 1)
                               •   Price adjusted every two years for Tranches 2 – 6, based on social cost of carbon and changes in Zone A
                                   energy and capacity prices

       • Each LSE serving end-use customers will be required, beginning April 1, 2017,
         to purchase a number of ZECs relative to the portion of the electric energy
         load served by the LSE
               • Costs will be recovered from ratepayers through commodity charges
       • The Order formally supports New York State’s upstate nuclear plants
               • These upstate plants realize lower locational marginal prices than downstate nuclear
                 plants (e.g., Indian Point).

Power Advisory LLC 2016. All Rights Reserved.                            44
Clean Energy Standard: Eligibility

CES: resource eligibility proposed rules
   • The NYS RPS program did not have geographic limitations until 2013 when the
     PSC approved NYSERDA’s request that out-of-state resources could no longer be
     considered for the main tier of the state RPS due to energy security issues and the
     displacement of economic benefits.
   • In the NY Department of Public Service (DPS) Staff White Paper on the CES, Staff
     recommended that a geographic eligibility provision be added to the CES to
     expand supply options to include out-of-state resources, which would enhance
     competition and supply stability and reduce costs.
           • Recommended that out-of-state generation be eligible if located in an adjacent control
             area to the NYISO control area, and if generation is accompanied by documentation of
             a contract path between the generator and the in-state purchaser, including
             transmission rights
           • Also requires delivery of the underlying energy for consumption in New York between
             the generator and either the New York Spot Market administered by the NYISO or an
             LSE in New York
           • DPS staff noted that because the CES would apply to all LSEs, restricting LSEs to in-
             state resources would conflict with the Commerce Clause of the Constitution.

Power Advisory LLC 2016. All Rights Reserved.        45
Clean Energy Standard: Eligibility

CES: adopted resource eligibility

           • CES eligibility rules for Tier 1 mirror those currently
             used in the Main Tier of the RPS with the exception
             that 30 MW limit on low-impact run-of-river hydro
             facilities is eliminated
                   • Large hydro is eligible, but only if it determined to be a
                     low-impact run-of-river facility and this requires that
                     there be no new storage impoundments, which excludes
                     most large hydro projects
                           • Recall that Tier 1 resources also have a vintage requirement
                             that mandates new resources
                   • Eligible resources: biogas, biomass, liquid biofuels, fuel
                     cells, hydro, solar, tidal/ocean, and wind
                   • However, no new storage impoundment will be
                     permitted for any eligible hydro facility

Power Advisory LLC 2016. All Rights Reserved.         46
Clean Energy Standard: Eligibility

Out-of-state resource participation adopted in the CES

          DPS Staff’s proposed geographic eligibility was adopted, allowing
          facilities located out-of-state in adjacent control areas to participate
          in NY CES Tier 1 solicitations.

          For imported electricity to be eligible, it must be demonstrated that
          it was:
                  • Scheduled into a market administered by NYISO for end-use in NY
                  • Delivered through a wholesale meter under the control of a utility, public
                    authority or municipal electric company such that it can be measured and
                    such that consumption within NY can be tracked and verified
                  • Delivered through a facility dedicated generation meter approved by the DPS
                    or its designee, to a customer in NY whose electricity was obtained through
                    the NYISO system
                           • All costs associated with measurement, tracking and verification must be borne by
                             the facility owner
Power Advisory LLC 2016. All Rights Reserved.                 47
Clean Energy Standard: Eligibility
Specifications for out-of-state intermittent renewable generators
that participate in CES Tier 1 solicitations

       • May sell and transmit energy as it is generated into the spot market
         of the control area of its location without simultaneous transmission
         into the NY Control Area, as long as an equal quantity of energy is
         transmitted out of the affected spot market into the NY Control Area
         for end-use during the same hour as the renewable generation is
         produced.
       • Contractual deliveries for out-of-state resources much be recognized
         in each hour as the lesser of actual hourly metered energy production
         by the renewable generator, or actual hourly energy delivered to the
         electric energy purchaser in the NY Control Area for end-use.
       • If the control area of origin has an attributes accounting and tracking
         system or an environmental disclosure program, it is required that
         such programs recognize hourly matched transactions without
         double counting the attributes in any jurisdiction.

Power Advisory LLC 2016. All Rights Reserved.   48
Clean Energy Standard: Renewable Energy Standard
Eligibility requirements preclude renewable generation
from Atlantic Canada
    • Given existing transmission tariffs, most renewable generation from Atlantic
      Canada is unlikely to be cost-effective in New York or alternatively New York
      would be viewed as a less attractive market
    • Commission indicated that evaluation framework to be based on price and
      economic development unless this shown to be ineffective
            • This could disadvantage Canadian wind projects given their economic development
              benefits will be lower than those for New York projects
    • Commission indicated that the following additional factors will be considered:
            • Viability of the project;
            • Time frame for bid acceptance to operation;
            • Diversity of resources of the overall portfolio;
            • Diversity of owners [not further defined];
            • Alignment with REV goals specified in procurement solicitations;
            • Project developer experience; and
            • Non-cost economic benefits.

Power Advisory LLC 2016. All Rights Reserved.              49
Economics of Wind in Quebec
           and Atlantic Canada
           Ability of Wind from Quebec and Atlantic Canada to compete in US
           Northeast

Power Advisory LLC 2016. All Rights Reserved.   50
Economics
Similar underlying assumptions used for US and
Canadian wind costs
     • Used US Energy Information Administration’s Assumptions to the
       Annual Energy Outlook as the source for wind project capital and fixed
       O&M costs
             • Adjusted these to reflect expected cost differences in the US Northeast and Eastern
               Canada
                     • These included regional cost differences (e.g., higher construction costs in New England
                       given project siting on ridge tops) and foreign exchange (Fx) effects
                     • Analysis assumed that significant portion of Canadian projects wouldn’t be affected by Fx,
                       with manufacturing infrastructure located in Canada
             • Provincial cost differences were viewed as relatively minor and beyond the scope of
               this analysis
     • Analysis also accounted for differences in expected capacity factors in
       these two regions
             • Eastern Canada was viewed as offering higher capacity factors than the US Northeast
                     • Here as well differences in provincial wind regimes weren’t considered

     • These assumptions are shown on a subsequent page

Power Advisory LLC 2016. All Rights Reserved.                51
Economics
Historically, US wind projects had a competitive
advantage from the PTC

           •   US wind projects have benefited from the US Production Tax Credit (PTC)
                   •   A 2.3 cent/kWh tax credit that was paid for all output over the first 10 years of a project’s life.
           •   The PTC is scheduled to be phased out by 2020.
                   •   However, by expending 5% of a projects costs in a year a developer is able to claim that it began construction in
                       that year. This “continuity safe harbor” provision allows a developer to extend the benefits of the PTC for up to
                       four years assuming that the developer is able to demonstrate that it has made continuous progress towards
                       completion.
                   •   This raises a question as to whether developers will share this benefit with buyers by reflecting it in its offered
                       pricing or whether they will elect to retain the benefit in terms of a higher return. We expect that market
                       dynamics will determine the answer to this question and where there are believed to be fewer competitors that
                       have this benefit the seller will seek to retain this benefit for itself.
           •   If this occurs Canadian wind will be on a much more level playing field.
           •   The PTC is scheduled to drop to 80% by 2017, 60% by 2018 and 40% by 2019.
                   •   Projects are required to initiate construction by the end of the year to lock in the respective PTC rate. The
                       threshold for initiating construction is relatively low and includes incurring 5% of eligible project costs by the
                       deadline.
                   •   Proponents then have four years to complete construction.

Power Advisory LLC 2016. All Rights Reserved.                               52
Economics
The busbar costs of Canadian wind projects are
projected to be lower than US projects
                                                   Source Data     NE US Projects    CAN Projects
                                                  2013 US$/kW      2020 US$/kW      2020 CAD$/kW
                        Capital Costs
                                                          $1,980           $2,359           $2,504
                        ($/kW)
                        Fixed O&M Costs
                                                          $39.53           $45.41           $47.68
                        ($/kW-year)
                        Capacity Factor (%)                                  38%              40%
                        Busbar Cost
                                                                           $83.9            $76.1
                        ($/MWh)

                                        When Canadian wind project costs converted to
                                                    US$ - $60.9/MWh

                   • Costs shown are central case estimates
                           • +/- 15% reflects the high/low estimates
                   • Northeast US project busbar cost estimates assume expiration of the PTC
                   • The generation produced by Canadian projects must be delivered to the US
                     for it to compete
                           • The costs associated with delivering this energy must be considered

Power Advisory LLC 2016. All Rights Reserved.                53
Economics
Canadian wind generation must incur
transmission costs for Northeast
                                                              Provincial Transmission Charges
    • The transmission charges that would
      be incurred in each Province are                                            $/MWh       Losses
      shown to the right                                     New Brunswick           $5.18         3.3%
    • In addition, losses are assigned                       PEI                     $5.19         2.8%
      according to the loss factors shown                    Nova Scotia             $8.55         2.0%
            •   In Ontario, losses vary by location
                                                             Quebec                  $8.20         5.4%
    • Provinces that aren’t directly
                                                             Ontario                 $1.85         Vary
      interconnected to the US Northeast
      need to pay multiple transmission
                                                              Cumulative Transmission Charges*
      charges, one for each province they
      wheel through this is shown in terms                                        $/MWh       Losses
      of the Cumulative Transmission
                                                             PEI                    $10.36         6.0%
      Charges
                                                             Nova Scotia            $13.73         5.2%
    • Even with these additional
      transmission charges, wind generation
      from Quebec and Atlantic Canada                    These transmission costs reduce the
      appears to be competitive with wind             competitive advantage offered by Canadian
      generation from the US Northeast                             wind generation
                                                       * Cumulative Transmission Charges reflect
                                                       the addition of PEI and Nova Scotia
                                                       charges, respectively with New Brunswick
Power Advisory LLC 2016. All Rights Reserved.           54
Economics
Northeast wind projects experiencing increasing
transmission costs

          • As discussed above, in New England wind generation is clustered in Maine and this
            is leading to increasing levels of transmission congestion.
                  • Transmission congestion reduces the value of this wind generation from Maine as it has a
                    reduced locational value (Locational Marginal Price)
          • Therefore, increasingly new wind projects require transmission investment to
            deliver the energy to Southern New England load centres
          • The Tri-State Clean Energy RFP issued by Massachusetts, Connecticut and Rhode
            Island recognized this and allowed new transmission investments to be bundled
            with generation as well as to be considered separately.
          • A number of transmission projects were submitted in response to the Tri-State RFP.
            Power Advisory expects that one or more of these transmission projects to be
            successful.
          • These different projects are forecast to have significantly different costs and to
            deliver different types of energy.
                  • With the economic assessment considering the underlying value of energy delivered,
                    higher cost projects may be more cost-effective.

Power Advisory LLC 2016. All Rights Reserved.              55
Economics
The estimated costs of different transmission projects vary
significantly
                                                               Length           Transfer
                         Project                                                                    TWh                Generation               $/MWh
                                                               (miles)         Capability
   Clean Energy Connect                                                25                 600           2.1     Wind & Hydro                           $3
   Maine Clean Power Connection                                        66                 550           1.9     Wind                                   $5
   Maine Renewable Energy Interconnect                               150                1200            4.1     Wind                                   $11
   NextEra Maine                                                     114                  561           1.8     Wind, Solar & Battery                  $12
   Northern Pass                                                     192                1090            8.8     Hydro                                  $19
   Vermont Greenline                                                   60                 400           3.2     Wind & Hydro                           $20

         •   $/MWh costs are Power Advisory estimate of the capital costs for the project amortized over the generation that would be utilizing the
             transmission facility.
         •   Higher cost projects that deliver lower cost or higher value energy may be successful in the Tri-State RFP.
         •   In general, transmission projects that would be delivering wind generation offer the higher value of Class I RECs.
         •   Whereas, a project such as Northern Pass is likely to offer access to energy that would receive the ISO-NE market price. Specifically,
             Northern Pass participated in the Tri-State RFP as a delivery commitment project where the proponent was just seeking cost recovery for
             transmissions based on the total amount of clean energy delivered. There would be no commitment to purchase a fixed quantity of
             energy.
         •   Recall that Class I REC requirements for New England are forecast to increase by about 8 TWh from 2016 to 2025.

Power Advisory LLC 2016. All Rights Reserved.                                  56
Economics
The value of Class I RECs varies depending on
market conditions
    •   Pricing for Class I RECs is shown in the figure to
                                                                            New England Class I REC Prices
        the right.
    •   Economic theory suggests that the value of Class I
        RECs will be determined by the incremental cost of
        the marginal renewable resource. If a wind project
        in New England costs $90/MWh ($84/MWh busbar
        cost plus $6/MWh for transmission) and the value
        of energy in New England is $44/MWh in 2020,
        then the value of a Class I REC would be about
        $46/MWh before consideration of any discounts
        for a long-term contract.
            •   Current Class I REC prices range from about $32 to
                $38/MWh. We expect that the loss of the PTC will
                result in increases in Class I REC prices in New
                England.
            •   Current forward contracts for 2020 for the ISO-NE
                Mass Hub are about $44/MWh and $53/MWh for
                2025.
            •   This analysis assumes no capacity value taken for
                wind given ISO-NE pay-for-performance program.
    •   States have Alternative Compliance Payments,
        which represent the ceiling price for a Class I REC.         Source: US Department of Energy
        These alternative compliance payments generally
        escalate with inflation and for Massachusetts are
        about $64/MWh.
Power Advisory LLC 2016. All Rights Reserved.                        57
Economics
There is little long-term forward market liquidity
for Class I RECs
           • Renewable Portfolio Standards (RPS) are product of legislation and state
             regulations. Therefore, there’s considerable change-in-law risks associated
             with these RPS.
                   • For example, Connecticut has changed the definition of qualifying Class I resources
                     several times and this has affected the price of Class I RECs in Connecticut.
           • The net result is that there’s limited trading of Class RECs several years
             before the compliance year. This has required that sellers have long-term
             contracts to secure reasonable value for Class I RECs.
                   • The market value of RECs several years before the compliance year is typically at a
                     considerable discount to nearer term market prices reflecting these change-in-law
                     risks.
           • Requirements for such long-term contracting are generally established
             legislatively and these requirements are considerably less than the total
             Class I resource requirements of these states.
                   • Tri-State RFP could consume much of the legislative mandates for long-term
                     contracts, other than required by the recent Massachusetts legislation.

Power Advisory LLC 2016. All Rights Reserved.             58
Economics
The value of Canadian hydroelectric projects
varies by state

           • For example, Massachusetts has mandated the purchase of 9.45
             TWh per year of clean energy and large Canadian hydroelectric
             projects would qualify for such purchases.
                   • Absent this purchase requirement, the value of Canadian hydroelectric power
                     would be the value of the energy plus its capacity value.
                   • Using current ISO-NE futures prices this would represent about US$54/MWh
                     in 2020 and about US$65/MWh in 2025.
                           •   In 2020 baseload energy at the Mass Hub has a value of about $43.8/MWh (based on current
                               futures prices) and capacity about $10.5/MWh (assuming once again a baseload output profile).

           • Large Canadian hydroelectric projects don’t qualify for Class I
             RECs. However, as non-carbon emitting resources they can assist
             states achieve any potential Clean Power Plan emission reduction
             obligations.

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Economics
Incremental value of wind generation relative to
Canadian hydroelectric projects needs to consider
           • The incremental value of Class I renewable resources (or the value
             of Class I RECs) versus differences in the output profile of the two
             resources and the greater capacity value of hydroelectric output.
                   • There could also be an integration costs associated with wind (excluding
                     transmission costs which would be incurred by both resource types).
                   • For the purposes of this assessment we are assuming that hydroelectric
                     output is delivered around-the-clock.
           • Differences in the value of the wind output relative to hydro vary
             by market. For the purposes of this comparison, we believe it is
             reasonable to assume that the discount associated with wind
             output value relative to hydroelectric power is close to the
             capacity value of wind resources.
           • Therefore, one can assume that any discount in the energy value
             of wind from a higher proportion of output in off-peak periods is
             offset by wind’s capacity value.
                   • This is an approximation, but is reasonable in most electricity markets.
Power Advisory LLC 2016. All Rights Reserved.            60
Economics
Incremental value of wind generation relative to
Canadian hydroelectric projects needs to consider
           • This suggests that the difference in value for wind versus baseload
             hydro is largely reflected by the value of the Class I RECs
             associated with the wind resource. The value of Class I RECs vary
             depending on market conditions. When there is a shortage or
             Class I RECs they tend to trade just below the Alternative
             Compliance Payment (ACP) which in Massachusetts, Rhode Island
             and New Hampshire is about $67/MWh.
           • In a market where sufficient renewable energy can be built to
             meet RPS requirements, economic theory suggests that the
             pricing for RECs should be about $36 to $46/MWh, with the low-
             end of the range assuming a discount of about $10/MWh to
             secure a long-term REC contract or using the low end of the range
             for wind project costs.

Power Advisory LLC 2016. All Rights Reserved.   61
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