By Rich Heidorn Jr.

CARY, N.C. — PJM CEO Andy Ott said last week the RTO will look for ways to incorporate “resilience” in its markets and system operations, providing hints at a white paper it will release later this month on the issue.

Speaking at the RTO Insider/SAS ISO Summit last week, Ott said the initiative was sparked by fuel security concerns — the risks of sabotage or cyberattacks on grid assets or gas pipelines — and a desire to recognize the reliability value of baseload nuclear and coal plants struggling to compete in the PJM market. Later in the panel discussion, former FERC Commissioner Tony Clark — participating via phone after snow canceled his flight from D.C. — forecast how the commission and the courts may rule on zero-emission credits that provide additional revenues to nuclear plants.

Ott said one possible shift in PJM would be changing contingency plans from replacing the largest single generator to ones that consider the loss of a gas pipeline supplying multiple generators.

“All the generation connected in a certain section of that pipeline could go off very quickly if it loses pressure because of an explosion or some event. Maybe we should be operating to the loss of that and look at that operational risk inside the market and price that in so the units that didn’t have that kind of fuel security risk would be worth more money,” Ott said. “That would help, of course, the resources that are less dependent on just-in-time fuel” such as nuclear and coal. Ott also said PJM will seek to become more “dynamic” in its management of operations.

Concern over Pipelines, Transmission Corridor

“One obvious [example] is to look at the way we deploy synchronized reserves or operating reserves and expand the contingency set that you’re looking at to include pipeline contingencies. … Or if you have a transmission corridor that you’re very worried about — potentially include that as part of your constraint set. So when you’re dispatching generation or deploying demand response, you’re essentially recognizing that double contingency or triple contingency as part of operations in certain circumstances. Not 8,760 hours [per year] but when you think that vulnerability exists, you can price it in.”

It also could mean system restoration plans becoming less dependent on individual transmission lines or fuel sources, Ott said.

Ott did not offer details on how fuel security would be priced into the markets. The RTO has already taken steps to address reliability concerns with its Capacity Performance rules, which increased penalties for nonperformance and rewards for overproduction during emergencies.

Coal Group Petitions PJM, MISO

On Friday, meanwhile, the American Coalition for Clean Coal Electricity (ACCCE) sent Ott a letter calling on PJM to take steps to prevent further retirements of coal-fired generation and “take into account the likelihood of changes to federal environmental policies.”

“We are confident the new administration will withdraw or rewrite environmental regulations that are causing, or could cause, more coal retirements,” ACCCE CEO Paul Bailey wrote. “These rules include the Clean Power Plan, Coal Combustion Residuals, Effluent Limitations Guidelines, Cross State Air Pollution Rule and Regional Haze.”

Bailey said the Capacity Performance rules were helpful but insufficient. “We do not think these changes go far enough in recognizing the advantages of baseload coal-fired generation. In particular, the changes have not led to higher capacity prices that are necessary to keep coal plants from prematurely retiring,” he wrote.

ACCCE says 121 coal-fired generators totaling 20.1 GW have retired in PJM, most because of environmental regulations, and another 28 plants (8.9 GW) have announced plans to shut down.

The group also sent a letter to MISO CEO John Bear asking the RTO to change rules “to ensure the reliability attributes of coal-fired generation … are properly valued.” MISO has lost 103 coal-fired generators (8 GW), with another 45 retirements (10.5 GW) pending.

Former Commissioner: FERC May Reject ZECs

Former Commissioner Clark, now a senior adviser at Wilkinson Barker Knauer, said zero-emission credits approved for nuclear plants in New York and Illinois — and under consideration in Connecticut and other states — may be rejected by FERC or the courts because of their impact on wholesale market prices. (See related story, Connecticut Moves Closer to Equating Nuclear with Renewables.)

Clark called ZECs the third iteration of states’ efforts to build or preserve generation within their borders. Last April, the Supreme Court rejected Maryland’s contract-for-differences with the developer of a combined cycle unit, saying that by tying the contract to PJM capacity prices, the state had violated federal jurisdiction.

In May, American Electric Power and FirstEnergy withdrew power purchase agreements that Ohio regulators had approved with their unregulated generation after FERC indicated it would review the deals for violations of affiliate abuse rules. “The merchant generators basically did a very surgical strike in [their] filing at FERC” in requesting the affiliate review, Clark said.

With ZECs, “the states … have really gotten craftier about how they can [preserve at-risk generators],” said Clark, noting that they were designed to be similar to state renewable energy credits (RECs).

“Merchant generators have … said these RECs are an out-of-market subsidy [that] distort prices. And the commission has said, ‘OK, theoretically we understand what you’re saying.’ But there wasn’t enough provable harm for the commission to really do anything about it,” Clark said.  The RECs “were either conceptual at the time of the challenge … or it was a small enough part of the market … that it didn’t seem like it was a big enough issue that the commission could act on. So effectively the commission could punt on that issue.

“Now if you’re talking about certain regions of the country where nuclear units are 20%, 30% of the market, or if you’re talking about other out-of-market interventions like in the Northeast — you’ve heard about long-term power contracts … with Canadian hydro — that might be 30% of the state’s energy needs.

“Well that does have a very material impact on the market themselves, so that will be a challenge for the commission to see if this is a zero-sum game, or the commission will have to declare in some ways these things federally jurisdictional and carve the states out. Or is there a way to thread the needle? That’s what each of the ISOs that’s dealing with this is doing.

“Here’s where it will get to be very tricky for the commission,” Clark concluded. “I’m not sure exactly how it will end up dealing with it.”