Comments Regarding Maine’s Draft Assessment of Storage Procurement Mechanisms and Cost-Effectiveness

The Clean Energy States Alliance submitted comments to the Maine Governor’s Energy Office (GEO) in response to their Opportunity for Comment Regarding Draft Assessment of Storage Procurement Mechanisms and Cost-effectiveness. CESA generally supports the Maine GEO’s findings and recommendations, including the proposed use of combined up-front and performance incentives for energy storage developers. CESA also supports Maine’s use of the Societal Cost Test (SCT) in combination with the Utility Cost Test (UCT) for assessing the cost-effectiveness of energy storage procurement; this is because the SCT considers societal benefits, such as reduced greenhouse gas emissions, that are not measured by the UCT. CESA encourages the Maine GEO to consider additional societal and environmental benefits of replacing aging peaker plants with energy storage, including equity benefits to host communities, and the reduction of local air emissions that can negatively impact the environment and human health. CESA’s comments were submitted in response to a request from the Maine GEO preliminary to its development of a 200 MW utility-scale energy storage procurement program.