SANTA FE, N.M. — SPP staff are expected to return to the Markets and Operating Policy Committee in April with a proposal for either a small task force or something more expansive in developing a “strategic survey” following numerous occurrences of conservative operations last summer.

Senior Vice President of Operations Bruce Rew said the survey would be used to educate staff and stakeholders on possible issues with a summary report given to the MOPC in October. (See SPP Shortfall Leads to Scarcity Pricing Calls.)

The report generated significant discussion among stakeholders, including calls for scarcity pricing, and a request for additional member feedback from MOPC Chair Holly Carias.

Rew summarized that feedback as being in four subject areas: supply adequacy, pricing, reliability and task force. He said respondents indicated continued support for scarcity pricing and the continued development of market products. That feedback has been turned over to the Market Working Group (MWG).

Members also expressed support to adopt best practices from other RTOs and ISOs in coordinating outages, he said.

“Maybe we need to have this discussion,” Golden Spread Electric Cooperative’s Mike Wise said, complaining about his staff’s recent difficulty in getting generator maintenance outage requests approved. “If you don’t allow these units to go into outages to get this maintenance, that will be trouble for us. I think it’s apparent something has shifted in your staff about not wanting to approve outages.”

Rew said staff have taken a more conservative approach to approving outages.

“When you’re looking at generation outages in the future, what do you consider the load to be at the time? What do you consider for wind?” he said. “We want to ensure we don’t take too many outages. One of the criticisms we got was that we were approving too many outages.”

Staff are evaluating and may revise their practices, Rew said. Currently, staff deny an outage request when they find the unit will be necessary for even just one day during the outage period, he said.

“If you can’t do maintenance, you’re going to have forced outages anyway,” Southwestern Public Service’s Bill Grant said. “Your solution is not acceptable.”

“I agree,” Rew responded. “We need to improve that. We’re moving that needle back to more in the middle.”

Generation shortfalls and sudden drops in wind energy last summer led to SPP calling its first energy emergency alert since becoming a consolidated balancing authority in 2014. The RTO also operated under conservative operations seven times during the summer.

Western RC Services, Market on Track

In what he promised would be his last presentation on SPP’s reliability coordinator services in the Western Interconnection, Rew said the transition from Peak Reliability to SPP has gone well with “no specific concerns.”

The RTO’s RC function went live on Dec. 3 for 16 entities with 100 GW of net energy for load. (See Westward Ho: SPP Now a Western RC Provider.)

SPP is also building its Western Energy Imbalance Service (WEIS) market, scheduled to go live in February 2021. The RTO has executed joint dispatch agreements with WEIS’ seven participants, and an executive committee has approved an operating tariff for the market. SPP’s Board of Directors will take up the tariff for consideration Jan. 28 before it’s sent on to FERC for final approval.

MOPC Nixes Response to FERC Z2 Remand

The committee rejected the Regional Tariff Working Group’s (RTWG) proposed RR376 that allows FERC to reopen transmission customer invoices as part of the commission’s 2019 remand order for Attachment Z2 credit payment obligations. (See FERC Reverses Waiver on SPP’s Z2 Obligations.)

In the order, FERC noted that the SPP Tariff did not contain language that allows the commission to order the reopening of an invoice after it is considered finalized. The RTWG addressed the agency’s concerns with language patterned after the NYISO Tariff referenced in the Z2 remand order. RR376 would have allowed reopening of invoices if there were “extraordinary circumstances” and that “significant injustice would result in the absence of commission action.”

GridLiance High Planes, Lincoln Electric System and Nebraska Public Power District all abstained from the vote.

Members did endorse without discussion the RTWG’s RR393, which establishes a procedure to expedite requests for replacement generating facilities. The change would allow existing facilities to be replaced with new ones without going through the full generator-interconnection study process.

Stakeholder Group Consolidation Waits on Analysis

Nickell, the MOPC’s staff secretary, said the consolidation of stakeholder groups continues, but that SPP still needs a cost-benefit analysis to further support an organizational structure based on functional responsibilities. (See “SPP Stakeholders React to Proposed Working Group Consolidation,” MOPC Briefs: July 16-17, 2019.)

“We need to ensure the groups don’t just have technical and policy backgrounds, but the talent, expertise and skill sets to develop business practices, Tariff language or criteria language,” Nickell said.

“The costs associated with working groups is pennies, compared to the other costs of SPP participation,” Lincoln Electric System’s Dennis Florom said. “I would be more concerned about losing stakeholder participation in the process. We’ve built up a member-driven organization, and that’s what sets us apart.”

The Balancing Authority Operating Committee and Operating Reliability Working Group are already well underway with their consolidation into a single group. The MOPC’s approval of the consent agenda endorsed RTWG RR386, which facilitates their merger by eliminating the requirement for alternate members.

Members Pass 12 Revision Requests

The MOPC unanimously approved an MWG revision request (RR 382) intended to minimize potential gaming opportunities identified by the Market Monitoring Unit. The change allows market-committed resources that have a minimum run time extending beyond initial reliability unit commitment or day-ahead commitment periods to be eligible for make-whole payments after their initial commitment period.

RR382 replaces RR306, which was passed in 2018 by both the MOPC and the board. However, when SPP’s legal department drafted the FERC filing, it found that the Tariff conflicted with RR306, requiring a redo of some of the change’s sections.

The MOPC approved the withdrawal of RR306, which was on the consent agenda.

Members also unanimously approved the Supply Adequacy Working Group’s recommendation to provide a testing exception for derated generating units (RR389). Resources that were out of service or derated because of a forced outage during the preceding peak season can satisfy an operational test requirement after repairs are complete.

The consent agenda included 10 RRs and a sponsored upgrade for a 115-kV project in southern Nebraska. EDF Renewable Energy proposed the re-conductor and rebuild of the transmission lines, which staff’s study estimated will be in service by 2023 at a cost of $12 million.

The approved RRs were:

• BPWG RR369: Updates the notification-to-construct (NTC) business practice’s (BP 7060) guidance to allow all future cost-allocated upgrades greater than 100 kV, and with estimates of $20 million or more, to be reviewed using the same methodology and decision structure as those currently defined as “applicable,” whether or not SPP issues an NTC. “Applicable” projects currently include any SPP-directed legacy construction projects meeting those voltage and cost thresholds.
• ESWG RR388: Sets up specific modeling criteria for modeling internal and external resources plans and phase-shifting transformers. Also standardizes items for Integrated Transmission Planning (ITP) scope items consistent over multiple studies.
• ESWG RR396: Removes certain sensitivity analyses during the ITP assessment of the recommended portfolio, providing more time to perform more informative sensitivities relevant to futures assumptions.
• MWG RR380: Allows for a more appropriate and accurate calculation of the out-of-merit energy (OOME) instruction’s financial impact for a resource by adding logic to ensure evaluation of both the OOME basepoint and the resource’s response.
• MWG RR387: Modifies protocol and Tariff language to allow flexibility in the real-time balancing market’s execution and modifies intra-day reliability unit commitment language for planned and unplanned outages.
• MWG RR397: Corrects bill determinant names identified within the calculations for RR266, which proposes to allow any resource to elect to be a “combined ownership resource” through a modeling option.
• MWG RR398: Corrects the contingency reserve deployment test flag to ensure it is only applied to specific intervals instead of the entire commitment.
• RTWG RR386: Facilitates the consolidation of the Balancing Authority Operating Committee with the Operating Reliability Working Group by eliminating the requirement for alternate members.
• RTWG RR394: Separates Attachment AO of the Tariff into two separate agreements: (1) for pseudo-ties between SPP and an external BA when there is a joint operating agreement or another agreement with provisions for pseudo-tie coordination; and (2) an agreement for pseudo-ties between SPP and an external BA when there are no provisions for pseudo-tie coordination.
• TWG RR392: Provides clarity and adds additional language to support NERC compliance related to TPL-001-4 (Transmission System Planning Performance Requirements) and MOD-032-1 (Data for Power System Modeling and Analysis) standards.

— Tom Kleckner