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PURA Files Request For Comments In Proposed Amendment Of Power Procurement Plan
From Notice:
[ *** ] To facilitate the Authority’s development of a procurement plan amendment, the Authority requests that docket participants and interested stakeholders file written comments on or before 4:00 p.m. on September 19, 2025, addressing the topics below.
The Authority seeks stakeholder comments on the following topics. Please provide an explanation and relevant supporting evidence in responses wherever possible.
Dynamic Market Purchases: Process
- Target Level of Dynamic Market Purchases. Discuss whether the standard service procurement plan amendment should set a non-binding target percentage for dynamic market purchases for a given time period (e.g., annually, for each six-month procurement period, etc.). If such a target is recommended, discuss how a target percentage would be established.
- Tranche Sizes. Discuss any potential concerns with the mathematical discrepancy between the minimum level of dynamic market purchase capability as specified in Public Act No. 25-173, § 31(a)(1) (i.e., capability to serve 25% of standard service load at minimum) and current standard service procurement tranche sizes (10%).
- Proxy Price Development. Describe how proxy prices can be developed for the portion of standard service procured through dynamic market purchases. Include a description of potential data sources, calculation methodologies, and potential tradeoffs in different approaches to proxy price calculation with a particular focus on customer migration and under / over collection in the General Service Charge (GSC). Quantitative analysis is not required for this response, which seeks to capture tradeoffs at a high level. However, if quantitative analysis is helpful to illustrate tradeoffs, respondents are encouraged to describe methodologies used and provide workpapers in unlocked Excel format with formulas intact.
- Dynamic Market Purchase Decision Timeline and Supporting Analysis. Discuss an appropriate time in the standard service procurement process and / or set of criteria to decide whether to designate one or multiple tranches for dynamic market purchases. Describe any analyses that would be necessary to determine the potential costs of dynamic market purchases compared to submitted full requirements bids or other procurement tools. Quantitative analysis is not required for this response, which seeks to capture the decision timeline and criteria for using dynamic market purchases. However, if quantitative analysis or real or representative data is helpful to illustrative potential approaches, respondents are encouraged to describe methodologies used and provide workpapers in unlocked Excel format with formulas intact.
- Interaction with Nuclear PPAs. Discuss whether the decision to procure a portion of standard service load through dynamic market purchases should impact or depend upon a decision to use energy, capacity, or other products from an eligible nuclear power generator to serve a portion of standard service load, as authorized in Public Act 25-173 § 30.
- Environmental Attribute Purchases. Discuss considerations for environmental attribute purchases corresponding to the portion of standard service load procured through dynamic market purchases.
Dynamic Market Purchases: Risk Management & Evaluation
- Risk Mitigation Plan. Discuss what potential risk mitigation practices should be put in place to protect standard service customers from price risk or price volatility in dynamic market purchases. Specifically, discuss the following: a. Would it be appropriate to complement spot purchases with forward purchases and/or other hedging products? b. Alternatively, does filling the remaining tranches with load-following, full service requirements contracts provide sufficient risk mitigation? c. If wholesale market prices greatly exceed proxy prices within a service term, what options could EDCs pursue to limit standard service customers’ exposure?
- Capacity Market Reforms. Discuss the impacts of ISO New England’s capacity market reforms — including transitioning from a forward to prompt auction and from annual to seasonal commitment periods, set to go into effect on June 1, 2028 — on the need for capacity-related hedging products to complement dynamic market purchases.
- Customer Migration Risk. Discuss potential impacts of dynamic market purchases on the risk of customer migration for standard service full requirements contract bidders.
10.Evaluation. Discuss how the efficacy of dynamic market purchases should be evaluated. Address (1) potential methods to evaluate the short-term determination of how much of standard service load to serve with dynamic market purchases, (2) potential methods to evaluate the longer-term efficacy of the dynamic market purchases process within the standard service power procurement plan, and (3) any other evaluation considerations for the use of dynamic market purchases to serve standard service load.
Other Procurement Practices
11.Standard Service Contract Duration. Discuss any anticipated advantages to procuring contracts for longer than six-month service periods or conducting competitive solicitations earlier than one year before the service term. Specifically, respondents may focus comments on any changes to their positions expressed during Docket No. 17-12-03RE10, PURA Investigation into Distribution System Planning of the Electric Distribution Companies – Building Blocks of Resource Adequacy and Clean Electric Supply.
12.Full-Service Procurement Alternatives. Discuss any anticipated advantages to procuring fixed price energy supply and/or capacity contracts rather than fullservice requirements contracts.
Notice (9/05/2025)
12-06-02RE04 (07/09/2025)
(PURA Review Of Power Procurement Plan – Amendment Pursuant To Public Act 25-173)
