A call for FERC to run a technical conference on capacity accreditation ran into a mixed reception in comments filed this week, with the ISO/RTO Council saying it is too regional of an issue for the idea to have an impact (AD23-10).
The American Clean Power Association filed a petition in August calling for the conference, arguing that capacity accreditation was something worth looking at holistically. (See ACP Asks FERC for Capacity Accreditation Technical Conference.)
“While the members of the IRC acknowledge that commission-led technical conferences can often be beneficial and understand the concerns raised by ACP in its petition, the regional variation on matters related to resource adequacy renders the topic of capacity accreditation less well suited for a national forum intended to drive toward ‘consensus,’” the IRC said. “As capacity markets themselves are neither mandatory nor standardized — reflecting regional differences in priorities and reliability needs — so too are the various accreditation frameworks that operate within each capacity market.”
Regions outside organized markets without capacity markets are even more distinct, which means a technical conference applicable to all would have limited value, it added.
Every FERC-jurisdictional ISO and RTO is talking about capacity accreditation modifications for a variety of reasons, and some of those processes contemplate a filing this year or next. Holding a technical conference likely would delay those changes, which are of “vital importance.”
The IRC said it was sympathetic to the issue of ex parte restrictions on commissioners discussing the topic, but it noted that no proceeding was open at this point that would lead to any issues.
“But should one arise, the commission could turn to alternative procedures that would not require a national technical conference to discuss individual ISO/RTO proposals,” IRC said. “For example, commission staff can notice a meeting to gather additional information about the unique reliability concerns facing a particular ISO/RTO to assess proposed capacity accreditation reforms.”
The Electric Power Supply Association told FERC it is not opposed to a technical conference and it supports broad engagement on system planning and resource adequacy. But like the IRC, it cautioned FERC about the idea’s impact on the ongoing stakeholder processes.
“Those processes are the result of extensive stakeholder participation and negotiation and are tailored to the region’s specific needs; for this reason, the commission should take care to both timing and framing a technical conference such that it supports — rather than stymies — this regional progress,” EPSA said.
Colorado Public Utilities Commission Chair Eric Blank wrote to FERC in support of holding a technical conference, saying it would help given all the changes happening on the Western grid. The PUC is working to facilitate a transition that economically reduces greenhouse gases over time while also moving toward more regional cooperation through expanded markets.
“Taken together, these forces will likely result in a significant increase in interregional transfers, an expansion in alternative generator and customer supply structures, and greater investment in intermittent and customer-sited resources, all of which present new challenges for maintaining resource adequacy,” Blank said.
Capacity accreditation may need to change from analyzing a few hours of peak demand in a deterministic way to dynamically evaluating in a probabilistic way the value of individual resources during more frequent tight supply conditions, he added.
The Solar Energy Industries Association told FERC a conference is a good idea given the changes the industry is going through.
“Regions are shifting from a single summer peak to biannual summer and winter peaks, with climate change exacerbating the reliability risks associated with these changes,” SEIA said. “The risk of correlated outages of thermal resources during extreme weather events is becoming more commonplace, and capability during extreme weather events is now the biggest risk to the reliability of the grid.”
Advanced Energy United said it would like FERC to offer guidance on the patchwork of capacity accreditation rules around the country and thus supported the technical conference.
“Existing ongoing efforts — which will continue to be iterated on for years at RTOs/ISOs — point to the need for a technical forum to holistically discuss issues and challenges related to capacity accreditation that have and will continue to arise,” AEU said. “Existing processes to accredit capacity are inconsistent and leave out some of the important issues raised by ACP in its petition.”
Sierra Club, Earthjustice, RMI, the Natural Resources Defense Council and the Sustainable FERC Project filed joint comments arguing a national technical conference on capacity accreditation would be worth FERC’s time.
“This subject is also a matter of substantial public interest as policymakers at all levels strive to maintain affordable electric rates while grappling with increasingly frequent extreme weather that threatens reliable electricity supplies,” the groups said. “Accurate capacity accreditation is key to a successful transition from conventional generation resources to a more decentralized and lower-emitting resource mix broadly supported by consumers and many state and local policies.”
The current patchwork might reflect legitimate regional and operational differences, but FERC hasn’t examined whether that is the case or whether different rules undermine reliability and skew investment decisions in a way that doesn’t benefit customers, they added.
