BONUS: The Capacity Auction Duct-Taping Has Started
The Planned Economy, Part 3a: What a failed Capacity Auction Reform might look like
In the middle of June, ISO-NE opened the new capacity submission review for the Interim Reconfiguration Auction Qualification Process. They released FAQs on this process in April 2025. These reconfiguration auctions are miniature capacity auctions held between the main Forward Capacity Market and the Capacity Commitment Period (CCP) that these capacity resources promise to be ready for. The reconfiguration auctions are meant to adjust prices and capacity commitments by small amounts, or—in some cases—for new power plants to sneak into an earlier Capacity Commitment Period if they’re available for it.
If a fresh-built power plant wanted to join that party in 2025, their opportunity to apply is now. But in 2025, ISO-NE considered it necessary to clarify that qualifying for the interim reconfiguration auction does not qualify a power plant for the 19th Forward Capacity Auction—the one that will be rebuilt by the incoming Capacity Auction Reforms, hopefully in time for 1 June 2028.1 This means that the new capacity qualification process applies exclusively for power plants (and other capacity-providing resources) that will come online between now and 1 June 2028. Whom does that even apply to?
Blessedly, the ISO-NE Interconnection Request Tracking Tool (IRTT) offers that exact information. I opened up the public viewer tool, exported the readout to Excel, and filtered the queue for projects that:
Have a projected operation date before 1 June 2028
Have a Net MW greater than zero2
Have a system impact study either “In Progress” or “Document Posted”
Have a Project Status either “Under Study” or “Under Construction.”
These filters return eleven projects:
Six battery systems totaling 1,110 MW
One 250MW solar system
2,100 MW of offshore wind:
Vineyard Wind 1, totaling 800 MW
An 827 MW request titled “Offshore Wind”
An 18 Net MW (with a Winter/Summer MW of 856 MW?) request titled “Offshore Wind Inc (QP700)”
A 187 Net MW (with a Summer/Summer MW of 1314 MW?) request titled “Offshore Wind Inc (Q806)”
Those three unmarked wind requests could refer either to New England Wind or to Revolution Wind. Note that Revolution Wind is already under construction.
The Duct Tape Solutions Are Already Here
I have no idea if any of these projects have already cleared in a Forward Capacity Market—I think that information is confidential. I don’t know if any of these projects will apply in this year’s Interim Reconfiguration Auction as a new resource. But these eleven projects are very likely (HIGHLY PROBABLE 80-95%) the only ones in New England that would even consider asking these “frequently asked” questions about applying for the Interim Reconfiguration Auction in anticipation of the Capacity Auction Reforms that seek to run faster than and thus completely replace these interim options.
In 2025, the mere concept of the Interim Reconfiguration Auction is a vestigial construct, a mid-flight adjustment mechanism for a market structure that ISO-NE has committed to killing. But if ISO-NE’s Capacity Auction Reforms fail to go live in time for 1 June 2028, expect these Interim Capacity Auctions to outlive their stated end date.
I’ll keep tabs on how this reconfiguration auction works. If ISO-NE’s new reforms get delayed like I think they will (PROBABLE 55-80%), then this will be the most-likely duct-tape solution that ISO-NE will deploy to keep capacity payments alive.
And to repeat myself from Monday, this is a critical weak point for ISO-NE and the utility business models they represent:
No one is at the helm. ISO-NE is vulnerable. And failure here puts them at the mercy of whomever becomes President in 2029.
If you—whether you’re Alex Epstein or Bill McKibben or the DER Task Force—want to drive a knife into the Wokest RTO/ISO in the Nation, then deliver them a legal challenge in the next six months. Take ISO-NE to FERC, sink their Capacity Auction Reforms, let their backstop half-measures collapse during the next Presidential election, and point to the tattered duct tape and twine above the wreckage.
“See this? It’s not just. It’s not reasonable. Rescind FERC Order 888.”
I am not interested in killing the existing structure of utilities—first, because it employs me, and second, because someone else will more gleefully wield that knife.
If you, the reader, want to wield that knife, now’s the time. Call some lawyers, file a complaint to FERC, cite the Federal Power Act’s Section 206 (16 U.S.C. § 824e). Twenty grand in legal fees is enough to cause serious damage. I, personally, will hold you responsible for any bodies found in the Christmas Brownout of 2028, but maybe that weighs less on your conscience than on mine.
This post and the information presented are intended for informational purposes only.The views expressed herein are the author’s alone and do not reflect those of their current or previous employers or any elected officials. The author makes no recommendations toward any electric utility, regulatory body, or other organization. While certain information contained herein has been obtained from sources believed to be reliable, the author has not independently verified this information, and its accuracy and completeness cannot be guaranteed. Accordingly, no representation or warranty, express or implied, is made as to, and no reliance should be placed on, the fairness, accuracy, timeliness or completeness of this information. The author assumes no liability for this information and no obligation to update the information or analysis contained herein in the future.
lol, lmao even
A surprisingly necessary filter