FERC on May 14 granted Nevada Power an exemption simplifying the NV Energy subsidiary’s filing of its triennial updated market power analysis (ER24-1518).
In a March 15 filing, Nevada Power asked FERC to change its designation from a Category 2 to a Category 1 seller in the Southwest Region.
A Category 2 seller must regularly file updated market power analyses, while sellers in Category 1 are exempt from that requirement. For a Category 1 designation, a seller must own or control no more than 500 MW of generation in the region, and it also faces limits on owning or operating transmission facilities.
Nevada Power noted in its filing that even with a Category 1 designation for the Southwest region, it would still have a Category 2 designation in the Northwest region, and therefore would continue to file triennial market power analyses.
With Category 2 designations in both regions, Nevada Power would be required to file duplicate triennial updates six months apart, the company said.
“To be clear, unlike other entities that have filed to be relieved of or exempted from Category 2 status, Nevada Power is and will remain a Category 2 seller in the Northwest Region — its home reporting region — and will continue to submit full triennial analyses addressing the whole of Nevada Power’s horizontal and vertical holdings, including those holdings in the Southwest region,” the company said in its filing.
FERC denied Nevada Power’s request for Category 1 status in the Southwest region, saying the company was disqualified by its ownership of transmission facilities in that region.
According to Nevada Power’s filing, the company partially owns the El Dorado substation in the Southwest region and within the CAISO market, as well as the Navajo-Crystal-McCullough line and associated substations in the Los Angeles Department of Water and Power (LADWP) balancing authority area.
But FERC agreed to grant Nevada Power an exemption from the filing requirements for a Category 2 seller. FERC Order 697 allows the commission to evaluate exemption requests on a case-by-case basis.
“In our attempt to keep the Category 1 criteria as simple and straightforward as possible, we may have swept under Category 2 particular sellers whose circumstances make it unlikely that they could ever exercise market power,” FERC acknowledged in Order No. 697.
FERC ordered Nevada Power to submit a compliance filing within 30 days with a revision to its market-based rate tariff reflecting the exemption.
No interventions or protests were filed in the case.
Nevada Power filed an updated tariff in 2014 designating itself as a Category 2 seller in the Northwest and Southwest regions, and a Category 1 seller in the remaining four regions: Central, Northeast, Southeast and SPP.
At the time, the company owned or controlled more than 500 MW of generation in the Southwest region, but that’s no longer the case, the company said in its March 15 filing.
Before 2014, the relevant regions for the Nevada Power balancing authority area and for the BAA of its sister company, Sierra Pacific Power, were the Southwest and Northwest regions, respectively.
But the two BAAs were consolidated in 2014, when the One Nevada transmission line came online. Nevada Power’s home reporting area became the Northwest region under the consolidation.