A Bad Case of Redaction

By James DeArruda, Graduate Research Assistant

The Commonwealth of Massachusetts’ effort to create and sustain an offshore wind industry in the United States took a step forward with the receipt of bids Dec. 20 by the Massachusetts Department of Energy Resources from the three developers holding leases for parcels in the Massachusetts and the Rhode Island-Massachusetts Wind Energy Areas. The bids are public and have been made available by the Commonwealth.

Those following this process were eager to see the individual bids and the different proposals offered by the three developers, Bay State Wind, Deepwater Wind, and Vineyard Wind. However, each of the bids includes a great amount of redacted information, particularly concerning specifics about the size and number of turbines, contract terms and pricing, potential collaborators, and maintenance routines that explain how often turbines will be offline. Not only that, but dozens of appendices that are provided for DOER are completely redacted in the public versions.

Concerns about competition are justifiable, but can be frustrating for those interested in the process. Here are interesting examples of redactions from each of the developers:

The Commonwealth will have all the information when it analyzes the bids, but the public will not be able to compare electricity prices …

… or maintenance schedules …

… or my favorite, Section 17 from the Vineyard Wind proposal, which concludes the bid publication with a five-page redaction that blacks out even the title of the section.

A deeper dive into the redactions may be of little value as far as sleuthing out secrets. The bidders followed their own formats in response to the RFP so comparison is tricky, but it’s always fun for fans of statistics and data to look around regardless.

To wit, here is a simple chart showing redactions by developer, separated by section. These weren’t exhaustive counts of every single redaction or type of redaction, but of redactions under the labels of the different sections. For example, I counted 12 different types of redactions in the Executive Summary (Section 2) in the Bay State Wind bid. They ran the gamut, from pricing, capacity and number of permanent jobs, to impact on the Commonwealth’s carbon footprint to wind tower specifications. Deepwater Wind’s Executive Summary included redactions of environmental impact, jobs and specs, as well, but the section also saw information about infrastructure and contracts redacted. Vineyard Wind’s bid had redactions of only three types in the first section: pricing, turbine specifications and expansion plans. These disparities and similarities, however, offer very little analytical power because of the uniqueness of each bid, so these charts stick to the section labels.

They show generally that Sections 5, 6, 8, and 15 account for the most redactions. Not much surprise there, as legal and technical topics are most likely to address intellectual property, engineering, finances, and logistics that have an impact on competition among bidders.

Redactions notwithstanding, there is a lot to learn from the bids, particularly in the areas of worksites, benefits to low-income Massachusetts residents, research and collaborations, and energy storage solutions, among other gleanings.

Storage

Renewables like wind and solar, in addition to the relative immaturity of their industries, also present the challenge of intermittency: the sun doesn’t always shine; the wind doesn’t always blow. Each of the bidders has proposed storage solutions that allow for the eventual consumption of the energy generated by their proposed wind farms  when supply outstrips demand.

Two of the bidders propose battery storage systems, and each is unique. Bay State Wind proposes a storage system at the site of the onshore substation (perhaps at the defunct Brayton Point Generation Station in Somerset), with a larger system proposed for the larger of its two bids (800 megawatts MW vs 400 MW). Vineyard Wind proposes spending $15 million to create distributed battery storage, meaning the developer intends to subsidize the purchase of batteries by individual, low-income ratepayers.

Deepwater Wind’s bid proposes storing energy not in batteries but in water, at the Northfield Mountain Pumped Hydro Storage Facility in Turners Falls. Surplus energy will be used to pump water from a lower to an upper reservoir, and will be recovered when demand carries the water down again to spin dam turbines.

Shore Side Facilities

The purpose-built heavy lift facility the Commonwealth constructed in New Bedford—with the express purpose of supporting a new industry in offshore wind—has already attracted interest from each of the three bidders. Each has an office in New Bedford, and each plans to do much of the assembly, staging, and deployment in the construction phase in New Bedford, with some of the staging taking place at other locations, which may include the Port of Providence and Brayton Point, among others. Two of the developers—Bay State Wind and Deepwater Wind—have plans for most or all of the Operations & Maintenance (O&M) phase to be centered in New Bedford as well. Vineyard Wind, as its name suggests, plans to base its O&M in the town of Vineyard Haven.

Benefits to Low-Income Residents

A section of the Commonwealth’s request for proposals requires an accounting of what will be done on the behalf of low-income residents. Bay State Wind proposes to provide $17.5 million over 20 years to the Weatherization Assistance and the Low-Income Heating Assistance programs. Vineyard Wind aims to create a Resiliency and Affordability Fund, seeded with $15 million, that will help install solar and distributed battery systems. Deepwater Wind touts the savings for all ratepayers, noting low-income payers will be especially benefited, but proposes a specific program for low-income high school students to do dual enrollment on the campus of the Massachusetts Maritime Academy in Bourne, with an eye toward income-based tuition support. The Maritime Scholars’ program aims “to help Massachusetts high school students prepare for careers in the growing offshore wind industry,” according to the bid.

Onshore Substation Connection

Generating companies will have to bring the electricity to shore. Bay State Wind has set its eyes on the Brayton Point plant. Deepwater Wind redacted much of their discussion of decisions regarding the shore side connection, but does note the benefits of using that former industrial area and its heavy-duty infrastructure to bring ashore up to 1,000 MW, and, in the case of expansion up to as much as 600 MW, Deepwater notes the availability of the existing Davisville substation in North Kingstown, RI, which services their Block Island Wind Farm, which has been operating since December 2017.

Vineyard Wind proposes to bring the cable ashore near Yarmouth and Barnstable. The location of the farm, at the northeast end of the green Wind Energy Area in the illustration below, and its proximity to Martha’s Vineyard makes its Cape-based landfall seem obvious; the distance from Vineyard Wind’s proposed offshore substation to Brayton point is 10 to 15 miles farther than the distance to the Cape site.

The parcels leased by the other two bidders are both closer to Somerset’s Brayton Point than to Cape Cod.

Economic Development

Part of the application process is the bidder’s explanation of economic development and job training goals, with an obvious emphasis on local benefits. Bay State Wind promises to train and hire locally as much as is practicable, considering the lack of specialized workers in this imported, exotic (for us) industry. It has already secured commitments from vendors willing to move “significant new manufacturing facilities” to Massachusetts. It has also signed a memorandum of understanding with Bristol Community College specifically for offshore wind workforce development, and one with Mass. Maritime.

Vineyard Wind proposes a program called the Wind Accelerator, a four-pronged approach to help the Commonwealth take advantage of its position as an early mover in offshore wind. The training prong presents Vineyard Wind’s commitment to the development of a local workforce in concert with supply chain real estate and recruitment policies.

Deepwater Wind’s scholar program with the MMA appears to be the extent of its training programs, though as many as 80 high school students might eventually benefit from the scholar program. Deepwater Wind’s bid is replete with expressions of its commitment to the local workforce, promising to follow its example on the Block Island Wind Farm on local hiring and trades decisions.

Jones Act Vessels

The Merchant Marine Act of 1920, commonly referred to as the Jones Act, requires any goods transported from one U.S. port to another U.S. port be transported by U.S.-flagged vessels. The vessels needed in this new industry are large, expensive, and purpose built. Deepwater Wind constructed a five-turbine farm with workarounds that, logistically, would likely be insufficient for full-scale deployment. Bay State Wind stated in their bid that they’re working to see that Jones Act-compliant vessels are constructed, and Vineyard Wind’s attention to the item has had a great deal redacted, including interpretation of the law, implications on the projects, and Vineyard Wind’s proposed solution. Deepwater makes no mention of the Jones Act in its bid.

The Path Ahead

Reading between the lines is a challenge when so many are covered with black, but there is plenty more available in the thousands of pages submitted to the state. A state-designated Evaluation Team—including the state Department of Energy Resources, electric distribution companies, and a technical consultant—will evaluate the bids in three stages to determine eligibility and to rank the bids on the price competitiveness and economic and environmental impacts of each bid. Selections of the winning bidder or bidders will be made in April 2018, with the aim of submitting long-term contracts to the state Department of Public Utilities at the end of July.

The Sections

If your thirst for minutiae remains unsatisfied, here’s a list of the 17 sections contained in the DOER’s Request for Proposals:

Section 1: Certification, Project, and Pricing Data

Section 2: Executive Summary of the Proposal

Section 3: Operation Parameters

Section 4: Energy Resource and Delivery Plan

Section 5: Financial/Legal

Section 6: Siting, Interconnection, and Deliverability

Section 7: Environmental Assessment, Permit Acquisition Plan, and New Class IRPS Classification

Section 8: Engineering and Technology; Commercial Access to Equipment

Section 9: Project Schedule

Section 10: Construction and Logistics

Section 11: Operation and Maintenance

Section 12: Project Management/Experience

Section 13: Emissions

Section 14: Contribution to Employment and Economic Development and Other Direct and Indirect Benefits

Section 15: Additional Information Required for Transmission Projects (and All System Upgrades Associated with Proposed Transmission Projects)

Section 16: Exceptions to Form PPAs

Section 17: Response to Transmission Tariff/Contract Requirements

Disclosure

The UMass Dartmouth Public Policy Center was a contractor for the portion of the Vineyard Wind bid involving job creation, Section 14. The PPC is expected to be used by Vineyard Wind to track economic development metrics if that bidder wins an award from the Commonwealth.