Dykes Calls out ISO-NE, FERC on Carbon Pricing

Connecticut Department of Energy and Environmental Protection Commissioner Katie Dykes took aim at both ISO-NE and FERC in a panel discussion on carbon pricing in wholesale electricity markets at Thursday’s Consumer Liaison Group video meeting.

Dykes said she opposes the RTO’s proposal to add a carbon price on top of the Regional Greenhouse Gas Initiative (RGGI), which sets the cap for carbon emissions across New England.

“Our states in New England, participating in RGGI as we do, have sent multiple letters to ISO New England and to [the New England Power Pool] regarding carbon pricing,” Dykes said. “And essentially, repeatedly we’ve had to go on record, stating that we are not in support of a carbon adder as a supplement or perhaps as a replacement for the RGGI program.”

Dykes, who served as chair of the Connecticut Public Utilities Regulatory Authority from 2015 to 2018 and RGGI board of directors chair from 2014 to 2017, noted that states also contract for grid-scale renewables and back utility-administered investments in energy efficiency.

“Overall, those programs, in compliment with the RGGI program, have contributed to achieving significant reductions in carbon emissions in our state at a relatively low cost to families and businesses,” Dykes said.

RGGI’s strengths are that it is governed by state commissioners, Dykes said, which means program designs align with individual states’ policies, and it provides for reinvestment of proceeds from the sale of allowances.

“Those reinvestments are flowing back into energy efficiency programs, which provide the greatest magnifier of benefits for our customers, not just in terms of further reducing emissions … but also helping to offset individual bills,” she said.

ISO-NE carbon pricing

Estimated consumer energy costs that adopt electric vehicles and convert to electric heat pumps | Analysis Group

Asked to comment on Dykes’ remarks, an ISO-NE spokesperson said the RTO “continues to support the states as they work to develop electricity sources that are clean, reliable and cost-effective for the benefit of our region. We’ve recommended carbon pricing as a simple, cost-effective and transparent solution to integrate the state’s policy goals with the wholesale electricity markets. We recognize it as just one of several ideas being discussed among the states and regional stakeholders to deliver a clean energy future for New England.”

Joseph Cavicchi, vice president of Analysis Group, gave the Consumer Liaison Group a presentation on his company’s report on carbon pricing for the New England Power Generators Association (NEPGA). He agreed with Dykes for the “need to be cognizant of the costs that would be incurred by consumers” if carbon pricing pushed up not only electricity prices, but also increased the cost of gasoline, natural gas and oil as well. Cavicchi said progressively increasing the price on carbon emissions can support market-based investment in “clean energy technologies.”

“If you had a carbon price that translated to $25 to $35/short ton in 2025, upwards to $55 to $70/short ton in 2030 and 2035, you’d go a long way toward supporting the kinds of investments that we think are necessary,” Cavicchi said.

‘Tragic’ Disconnect

During the panel’s question-and-answer session, Dykes fielded a question from an attendee who referenced FERC’s Sept. 4 ruling rejecting NYISO’s proposal to make it easier for public policy resources to clear its capacity market. (See FERC Rejects NYISO Bid to Aid Public Policy Resources.)

Dykes said that FERC is challenging the ability of states to rely on competitive markets to achieve decarbonization goals. That is “really the tragedy of this disconnect between the federal policies and in states continuing to address the need to mitigate carbon emissions,” she said.

She also said it concerned her that no state regulators were invited to speak at FERC’s Sept. 30 technical conference on carbon pricing in the wholesale electricity markets. (See FERC Announces Tech Conferences on Carbon, OSW.) ISO-NE CEO Gordon van Welie and Matthew White, chief economist for the RTO, are scheduled to be panelists.

“We look forward to sharing our perspectives,” the RTO spokesperson said of the conference. “The New England states play an important role in evaluating potential solutions, and we fully recognize that any solution for carbon reduction in our region, such as carbon pricing, requires a coordinated effort with state policymakers.”

Boston Climate Action Plan

John Cleveland, executive director of the Boston Green Ribbon Commission, a group of stakeholders working to implement the city’s Climate Action Plan, gave a presentation on the group’s work and the 2019 update of the climate plan, which highlights the steps the city will take over the next five years toward achieving carbon neutrality by 2050.

Cleveland emphasized the need for a “comprehensive and integrated approach,” including reducing energy demand and maximizing energy efficiency; electrification of transportation and heating; and a transition to greenhouse gas-free fuels. “There is no silver bullet,” he said.

As next steps, he urged the RTO to engage stakeholders to reach consensus, “reinvigorate” the Integrating Markets and Public Policy Initiative, invest in the Future of the Grid analysis and develop a decarbonization “pathways” analysis with options including carbon pricing.

ISO-NE Update

Eric Johnson, ISO-NE’s director of external affairs, gave the group an update on activities in the RTO, including the impact of COVID-19 on power demand, the RTO’s proposed 2021 budget and preparations for Forward Capacity Auction 15.

He said the RTO’s latest Electric Generator Air Emissions Report showed carbon dioxide emissions dropped by 31% during the 10-year period of 2009 to 2018. Nitrogen oxide emissions decreased by 43% and sulfur dioxide emissions plunged 94% over the same period, he said.

MISO Looks Back on Turbulent Summer

With a challenging summer in the rearview, MISO expects more traditional reliability risks this fall while making blueprints for an industry roiled by change.

MISO’s relatively low 114-GW summer peak in early July and average $21/MWh real-time prices belied a whirlwind season containing two emergency declarations. The peak was lower than both the grid operator’s projection (125 GW) and last summer’s peak (121 GW).

In late summer, MISO directed its first load-shed event after Hurricane Laura ripped through the heel of Louisiana. (See MISO Keeps Advisories in Effect a Week After Laura.)

MISO Executive Director of Market Operations Shawn McFarlane said the RTO began preparations for the hurricane about a week before the storm’s landfall. At the grid operator’s orders on Aug. 27, Entergy shed about 573 MW of load in the West of the Atchafalaya Basin load pocket.

The load-shed orders maintained grid stability and kept MISO South from experiencing cascading outages, McFarlane said during a summer review Sept. 15 before the Board of Directors’ Markets Committee.

MISO estimated that uplift payments totaled $90 million during the event. McFarlane said that is the largest the RTO has ever experienced from a single episode.

MISO
Restoration work in the wake of Hurricane Laura | Entergy

It could take until the end of October to restore power to all Louisiana ratepayers, based on Entergy’s restoration estimate, he said. About 80,000 Entergy customers remain without power, down from approximately 700,000 immediately after the storm.

McFarlane also said MISO monitored Hurricane Sally, which was brewing in the Gulf of Mexico before ultimately tracking east of its footprint.

The grid operator continues to review the Laura event and will hold future stakeholder discussions during the Market Subcommittee’s public session, McFarlane said. Subcommittee Chair Megan Wisersky has proposed a special joint meeting with the Reliability Subcommittee on Oct. 1 to discuss the hurricane’s impact on the grid.

RTO executives also reported that proactive communication with other grid operators was much improved during its other maximum generation event on July 7, when MISO Midwest was seized by a stubborn heat wave.

“It’s good to hear that coordination has improved. That’s what the public expects of us,” Board Chairman Phyllis Currie said.

“This was an exciting quarter. Usually I begin by saying it was an uninteresting quarter,” Independent Market Monitor David Patton said.

Patton said he is concerned about the availability of supply in Michigan’s Lower Peninsula, which racked up high congestion costs this summer. He said three resources in one transmission pricing zone that cleared the annual Planning Resource Auction were unavailable for most of the summer.

“They provided us virtually no value during the summer,” he said.

MISO: Fall Emergency a Possibility

McFarlane said MISO expects near normal load going forward.

“Load levels will more or less be at the level of what we call non-COVID,” McFarlane told the board. “We haven’t totally confirmed this, but our suspicion was air conditioning load was making up for economic impacts” during the summer, he said, explaining that mostly empty offices were still being temperature controlled while widespread work-from-home employees kept their houses comfortable too.

MISO might have to declare an emergency this fall if conditions are right, despite its 152 GW of available capacity paired with a 113-GW forecasted seasonal peak.

“As we say every quarter, if we end up in a high-load, high-outage situation, it may require access of our emergency resources,” McFarlane said.

He said higher outages paired with extreme weather conditions could lead to tightening supply. MISO said it’s preparing to work around more outages than usual this year, as the pandemic lockdowns in spring led to maintenance rescheduling.

“In the spring, 20 GW of outages were deferred,” McFarlane said.

MISO
Damaged transmission infrastructure caused by Hurricane Laura | Entergy

MISO expects to have a little more than 115 GW of total available capacity in September after factoring in outages. If load stays at normal levels — about 112 GW — the grid operator doesn’t foresee a problem. But if high demand pushes load to 119 GW, MISO will have to dip into at least a few gigawatts of its 14.6 GW in load-modifying resources and operating reserves. The supply picture worsens if MISO has only 104.1 GW of capacity, as predicted by its worst-case outage scenario.

The RTO said that as usual, the largest amount of generation outages are slated to occur in October and November. It said the two months contain the highest potential for significant generation outages on monthly peak days.

MISO projects about 94.2 GW of available capacity in October with nearly 90 GW of usual load and a 95.2-GW high load. Increased outages could cull capacity to just 90.6 GW, making emergency measures all but certain in a high-demand scenario.

In November, MISO said available capacity should rise to 97 GW, handling both a typical 90.3 GW load and a 95.7 GW high load. However, if generation doesn’t return as expected, MISO could have just 92.6 GW of capacity on hand during the month, spurring operational challenges.

Changes Ahead

MISO Executive Director Ken McIntyre, a former NERC and ERCOT staffer, is helping the RTO modernize its operations and markets as the electric industry moves toward renewable and more dispersed generation.

“Today, we rely on operator experience and years and years of on-the-job-training. Tomorrow, we will have to rely on advanced monitoring and decision-support tools that predict conditions and provide guidance. Today, more days are the same. Tomorrow, more days will be different. The seasonal and peak demand profiles will become … less obvious and less meaningful for day-to-day operations,” McIntyre said.

He said MISO can launch automated tools using artificial intelligence in control rooms that can “pre-position the grid” for extreme weather or outages.

Vice President of System Planning Jennifer Curran said operations decisions will rely more on artificial intelligence and automated processes in the future.

“Today, we rely on operators with years of experience, and many of them are near retirement,” Curran said during the full board’s Thursday meeting. “There’s not a ready pool of additionally experienced operators to replace them.”

Director Barbara Krumsiek asked how MISO might incorporate “non-traditional forecasting arenas,” such as social forces, to predict energy demand. She pointed out that a coronavirus vaccine’s introduction could rally the economy and cause electricity demand to spike.

McIntyre said MISO might gather society trends by “scraping” data on social media to influence forecasts.

Patton also said MISO should transition to a “more sophisticated, probabilistic forecast” in their control rooms. He said that when faced with tight conditions, MISO tends to overcommit resources. That overcompensation often results in high revenue-sufficiency guarantee payments but low LMPs, he said.

“The tools could be much better to let operators make more surgical decisions,” he said.

MISO Readying Intensive Transmission Planning

Two recently announced special transmission planning efforts could have MISO members soon stringing miles of new wires across the footprint.

Stakeholders heard last week that a recently announced long-term transmission plan may result in project approvals as early as late 2021. At the same time, MISO and SPP will partner on an extra study focusing on transmission projects that could bring more of the renewable generation in the RTOs’ interconnection queues online. (See MISO, SPP to Conduct Targeted Transmission Study.)

Jennifer Curran, MISO’s vice president of system planning, said during the Board of Directors’ teleconference Thursday that while member companies’ renewable transition plans are disparate, stakeholder attitudes have shifted in favor of new transmission to support the metamorphosing generation portfolio.

MISO transmission planning
Jennifer Curran, MISO | MISO

“I think in our stakeholder community, we’re in quite a different place, even from a year ago,” Curran said. “Not all stakeholders are enthusiastic about new transmission … but we have received a lot of letters, feedback [and] emails from stakeholders saying, ‘Yes, it’s time to get going.’ 2030 is the equivalent of tomorrow when you’re talking about long-term, large-scale transmission projects. The work must begin today.”

MISO in mid-July confirmed it will undertake a series of long-range transmission planning studies under its annual transmission planning cycles. (See MISO Foresees Massive Shift to Renewables by 2040.)

Curran likened long-term planning to considering buying a new car rather than replacing a high-mileage car’s bald tires and fixing an oil leak. Long-term projects will not be approved en masse in a special portfolio, but under different annual MISO Transmission Expansion Plans, she said.

“With the Multi-Value Projects, it took four or five years to decide on projects for board approval. I just don’t think we have that kind of time here to bring projects forward for approval in 2025,” Curran said during the board’s System Planning Committee meeting Sept. 15.

From 2020 to 2022, MISO expects members to bring more than 25 GW in new generation online. That number pales in comparison to the 756 projects, totaling 113 GW, currently awaiting interconnection in its queue. (See MISO Processing Heftiest Interconnection Queue Ever.)

Curran acknowledged it will be challenging to find that “just-right, Goldilocks” level of long-term project approvals.

MISO and stakeholders will also work on cost-allocation processes next year as more immediate project needs emerge, she said.

The Organization of MISO States last week announced it has formed a special committee to examine and advise MISO on possible cost-allocation methods for long-term transmission projects. The special committee will be helmed by Indiana Utility Regulatory Commissioner Sarah Freeman.

Curran said the regulators’ perspective on cost allocation will be invaluable to MISO.

Teamwork with SPP

In a first, SPP CEO Barbara Sugg joined the MISO board’s virtual meeting on Thursday to discuss the RTOs’ increasingly crowded generation interconnection queues, the catalyst for the new joint study.

“SPP and MISO are such similar organizations dealing with such similar issues. … Our interconnection queue certainly draws the most criticism in SPP, and I’d wager MISO gets its share of criticism too. I think there’s no better time to collaborate and work together,” Sugg said.

“We thought about those queues … and how to make a difference for both of our members,” MISO CEO John Bear said in agreement.

MISO Executive Director of System Planning Aubrey Johnson said the study will likely last a year and is meant to identify project opportunities that wouldn’t be unearthed in the RTOs’ coordinated system plan studies.

Sugg gave MISO staff her “heartfelt thanks” for joining forces with SPP to possibly plan transmission together.

MISO Board Chairman Phyllis Currie said it was refreshing to see the cooperation between the two RTOs.

“I think her presence today says a lot about the level of commitment,” Currie said of Sugg’s address.

“Meeting after meeting, I’ve heard from our stakeholders that we need to do something about our seams issues. I hope this is evidence that we hear you,” Currie told stakeholders. “We can’t solve all seams issues, but I think it’s important we show that we’re listening to concerns.”

Director Baljit Dail said the “fantastic” teamwork between MISO and SPP was difficult to imagine more than a decade ago when he joined the board. “It may have taken a bit of time to get there, but we got there,” he said.

Clean Grid Alliance’s Beth Soholt also commended MISO and SPP for agreeing to the “important undertaking.”

Director Mark Johnson asked that MISO executives update the board on the study’s progress during the March quarterly board meeting.

NC Muni Wins Right to Add Storage over Duke Objections

FERC on Thursday granted North Carolina Eastern Municipal Power Agency’s (NCEMPA) request for a declaratory order allowing it to add battery storage to its system under its full-requirements power purchase agreement with Duke Energy Progress (EL20-15).

The commission rejected Duke’s opposition to the request, ruling that the PPA permits NCEMPA to use battery storage technology as either demand-side management or demand response. The commission cited a sentence in the agreement stating that it does not “preclude [NCEMPA] and/or its members from instituting or promoting activities designed, in whole or in part, to manage or reduce the members’ demands and/or loads through demand-side management programs.”

NCEMPA) storage
NCEMPA serves 32 cities and towns with their own municipal electric distribution systems in North Carolina. | Electricities of North Carolina

“When used as NCEMPA proposes, battery storage technology is inherently a load-shape-modifying device, designed not to reduce a customer’s overall load, but to shift the incidence of such load, i.e., to manage the customer’s demands,” the commission said. “Similar to other demand-side management activities, such as pre-cooling buildings overnight or midday to avoid withdrawing energy to provide air conditioning during afternoon peak-load conditions, NCEMPA’s proposed use of battery storage technology simply determines when energy is consumed.”

NCEMPA said it intended to use storage to reduce its load when prices are high because of increased system demand.

The commission noted that Order 841 — although not applicable in this case because NCEMPA is not part of an RTO or ISO market — “confirms that battery storage resources are capable of providing demand response service.”

The commission rejected Duke’s “restrictive interpretation” that battery storage is a form of generation, saying that it allows “a withdrawal of energy for later injection back onto the grid.”

Duke’s “argument ignores the fact that NCEMPA still would be purchasing its full energy requirements from Duke. The power used to charge the batteries would come from Duke’s generation, and then that power would be discharged from the batteries to serve NCEMPA’s customers,” FERC said. “The fact that NCEMPA is buying power from Duke at one hour and then using that same power from Duke in another hour does not change the fact that NCEMPA is meeting its full requirements through Duke.”

NCEMPA serves 32 cities and towns with their own municipal electric distribution systems. Between 1981 and 2015, it was the co-owner with Duke of two coal-fired generating units and three nuclear-fueled generating units operated by Duke.

FERC: No MISO Rules on Mid-queue Fuel Change Studies

FERC on Thursday said that MISO’s Tariff was silent on the issue of whether a generation project can switch from wind to solar while in the RTO’s interconnection queue (ER19-1823-003).

It also said that there was no requirement in Order 845 that requires grid operators to study projects that opt to change fuel types.

The issue stems from a Leeward Renewable Energy Development wind project currently in the definitive planning phase (DPP) of MISO’s generator interconnection queue. The developer wants to convert the project to using solar energy while also retaining its position in the queue.

Leeward said MISO was disregarding its own Tariff when it refused to perform an analysis to determine whether switching the project would constitute a material modification. Borrowing a phrase from Order 845, Leeward argued that the switch would result in “equal to or better” electrical performance.

Order 845 allows interconnection customers to make certain technological advancements to their generation projects without triggering a material-modification rule. Under the order, a customer can offer evidence that a requested technological change results in “equal to or better” performance. MISO must evaluate such claims and render a decision before projects can proceed.

MISO fuel change
| Leeward Renewable Energy Development

Order 845 also dictates that changes between wind and solar technologies should not automatically be treated as non-material modifications because “such changes involve a change in the electrical characteristics of an interconnection request, and the transmission provider would likely need to evaluate the impacts of such changes.”

MISO argued that it should not have to evaluate “mid-DPP fuel change requests” under Order 845 and said its Tariff doesn’t permit fuel type changes to projects after they enter the DPP.

But FERC said the Tariff allows Leeward to at least make a case for a fuel change in its generation project. It said Order 845 didn’t change MISO’s pre-existing material-modification provisions in its generator interconnection procedures. While Order 845 doesn’t require the grid operator to study fuel type changes, FERC said MISO also doesn’t have language in its generator interconnection procedures to preclude itself from studying fuel change requests.

“We find that the question of whether these pre-existing Tariff provisions allow an interconnection customer to submit a fuel change request after its project enters the DPP is therefore outside the scope of MISO’s Order No. 845 compliance filing,” FERC said.

The commission added that its decision was without prejudice to MISO making any filings to “further address the permissibility of, and requirements for, fuel change requests.”

FERC Upholds MISO Self-fund Order, Glick Dissents

FERC on Thursday left MISO transmission owners’ ability to self-fund network upgrades intact over a protest from the American Wind Energy Association and the dissent of Commissioner Richard Glick (EL15-68-005, et al.).

MISO in August 2018 reinstated TOs’ rights to self-fund network upgrades necessary for new generation. That meant generator interconnection agreements signed between June 24, 2015, and Aug. 31, 2018, could be revised to allow TOs to fund network upgrades and bill interconnection customers. (See MISO Gauging Aftershocks of TO Self-fund Order.)

The change came after the D.C. Circuit Court of Appeals remanded FERC’s 2015 decision barring TOs from electing to provide initial funding for network upgrades.

MISO Self-fund Order
FERC Commissioner Richard Glick | © RTO Insider

AWEA argued that the commission’s ultimate decision is “patently discriminatory” because it will allow those who had never applied for the self-fund option to do so and treat different interconnection customers differently. The association pointed out that before mid-2015, only one MISO TO has ever opted to self-fund a network upgrade.

FERC disagreed with the claims of discriminatory treatment.

“The fact that transmission owners may not have elected transmission owner initial funding in GIAs they were a party to prior to the interim period … does not, by itself, support a finding that such transmission owners should be barred from electing transmission owner initial funding on an ongoing basis,” FERC wrote.

AWEA also argued that FERC strayed from its usual mode of “preserving the sanctity of contracts.” It said the commission “has previously only departed from that precedent in extreme circumstances, such as fundamental industry restructuring and reorganization of a bankrupt utility.” The association contended that TOs shouldn’t be allowed to self-fund upgrades under multiparty facilities construction agreements because MISO’s original compliance filing didn’t mention such agreements.

FERC disagreed, noting that prior orders found that MISO’s facilities construction agreements and multiparty facilities construction agreements should be treated like GIAs.

Glick said the commission’s order didn’t “meaningfully” address AWEA’s concerns about the possible discrimination of some interconnection customers.

“Today’s order … doubles down on the unwise decision to permit the reopening of numerous previously negotiated interconnection agreements, despite considerable evidence that allowing transmission owners and affected-system operators to retroactively elect to self-fund the network upgrades associated with those agreements will result in substantial harm to interconnection customers and could lead to project terminations,” he wrote.

AWEA also argued that resource owners may have already started depreciating network upgrade investments in their books. FERC said that since 2015, generation owners have been put on notice that TO self-funding could again become a possibility.

Glick said that FERC stumbled by simply reversing its 2015 decision after the D.C. Circuit’s remand. He pointed out that the commission five years ago found that allowing TOs to unilaterally elect to fund upgrades could deny interconnection customers the “opportunity to finance network upgrades with more favorable rates and terms.”

He also said FERC’s decision to treat GIAs, facilities construction agreements and multiparty facilities construction agreements similarly was done without “any additional analysis or meaningful response to arguments raised by protesters.”

MISO Members Urge Dynamic Line Ratings

MISO members last week said the RTO’s footprint could benefit from transmission line ratings that change with the weather and other factors.

Clean Grid Alliance’s Natalie McIntire said static, conservative line ratings might be unnecessarily limiting transmission capacity and the amount of new generation resources that can interconnect to the MISO system.

“There might be transmission limitations that might exist for a small number of hours every year,” she said during a Advisory Committee conference call Wednesday.

McIntire also said it would be helpful if MISO transmission owners offered more information on how they form line ratings and for the RTO to identify the circuits that stand to benefit the most from more flexible ratings.

“As we’re all trying to make the most efficient use of the system, it would be helpful for MISO to tell us which are the lines that have the most potential gap between the static and dynamic ratings,” she said. Dynamic line ratings (DLRs) will ensure that consumers “get the most from their investment,” McIntire said.

DTE Energy’s Nick Griffin said MISO and its TOs should concentrate first on congested flowgates with the largest impact. “It doesn’t have to be broad range right at first,” he said.

MISO Dynamic Line Ratings
| © RTO Insider

Other members said MISO should establish a standard method for TOs to report the latest line ratings.

Organization of MISO States Executive Director Marcus Hawkins said transmission ratings in the RTO aren’t formed transparently. He has asked stakeholders to decide how large a role the grid operator should take in managing line ratings.

“MISO really could play a critical role in deciding where these enhanced ratings could be most beneficial and most cost-effective,” Hawkins said last month during an Advisory Committee teleconference.

Independent Market Monitor David Patton has said temperature-adjusted ratings would save the RTO about 10% of its total transmission congestion. He has estimated that MISO stands to save more than $150 million on an annual basis but says TOs remain reluctant to adopt DLRs because it involves investing in equipment and manpower with little return. Entergy already uses ambient-adjusted ratings in MISO South.

“The costs of not utilizing our transmission network is large,” Patton said during MISO’s Market Subcommittee meeting in April.

The Monitor and TOs have been discussing the possibility of DLRs in nonpublic Reliable Operations Working Group meetings.

The TOs said they’re working on their own benefit analysis of DLRs. Some cautioned that while some lines’ ratings could go up, some could also be lowered.

Transmission Owners sector representative Stacie Hebert said changes to facility ratings could result in higher cost recoveries and additional risk to TOs’ equipment.

DLR implementation made a shortlist of improvements that the MISO community was interested in working on in 2020. (See 7 Projects Make MISO 2020 Integrated Roadmap.)

Some stakeholders have said that while it’s true that lines can carry more capacity in below-freezing temperatures, it’s the generation component that’s often lacking in emergency conditions. That is especially true in MISO South, which is less prepared for arctic blasts.

Heat Waves, Blackouts Slow Western EIM Expansion

Heat waves and capacity shortfalls in August and September have slowed an effort by the Western Energy Imbalance Market (EIM) to expand from a real-time interstate trading forum to a day-ahead market, CAISO and EIM entities told the market’s Governing Body at its Wednesday meeting.

The events included CAISO-ordered rolling blackouts Aug. 14-15. (See CAISO Avoids Blackouts amid Brutal Heat, Fires.)

The extended day-ahead market (EDAM) initiative is moving forward with a straw proposal on topics including resource sufficiency and transmission use. Comments had been due Sept. 10, but CAISO extended the deadline by two months to Nov. 12 at the request of stakeholders, said Mark Rothleder, vice president of market policy and performance.

“I think that’s a fair and good approach because I think people should factor in and consider the learnings of the August and September events,” Rothleder said. The extension is “providing everyone, including the ISO, time to consider [those] events.”

The EDAM initiative, one of CAISO’s highest priorities, is divided into three “bundles” of topics that the ISO is addressing in succession through next year. The market is expected to go live in 2024. (See CAISO Proposal Sets Course for EIM Day-ahead.)

“It’s very timely that we’re talking about resource sufficiency,” Rothleder said of the initial set of topics. “I think there is a nexus between resource adequacy discussions, both in California and across the West, that I think do come together in an important way in the resource sufficiency discussion in bundle 1 of this topic.”

EIM heat blackouts

| Ready.gov

The EIM includes 11 members across the West, with 10 more set to join in the next two years. The newest members are Seattle City Light and Arizona’s Salt River Project. On July 3, the EIM surpassed $1 billion in benefits for its members since its launch in 2014.

Jim Shetler, general manager of the Balancing Authority of Northern California, an EIM participant, spoke on behalf of all EIM entities about tapping the brakes on EDAM.

“We know there’s a lot of evaluation going on about the heat wave events of August and September,” Shetler said. “As these issues are being discussed and evaluated, we’ve been hearing some comments made by some parties about ‘the utilities are relying on exports from others too much’ and whether there’s a need to become more independent and self-sufficient.”

CAISO was faulted by some for its reliance on out-of-state exports to meet its evening peak demand, an apparent cause of the shortfalls and outages this summer.

The EIM entities support a robust resource adequacy program and a strong resource sufficiency test that applies the same metrics to all participants, Shetler said.

“However, we equally recognize that collaboration across the West is absolutely necessary in order for the region to reliably and efficiently manage the changing resources with the ever increasing variable renewables and decreasing dispatchable resources,” Shetler said.

The EIM was a first step in greater regional collaboration, he said. The EDAM is the logical next step, and EIM entities support the day-ahead market moving forward.

“We do not want to lose the momentum that has been established,” but the heat waves and blackouts have shown potential resource deficiencies and economic issues that could impact the EIM and EDAM, Shetler said. Taking time to address the issues will ensure an EDAM design “that meets the needs of all the market participants,” he said.

Governing Body member Robert Kondziolka asked Shetler if EIM entities are looking into the shortfalls and could brief the Governing Body on their findings.

“We’re in the middle of looking at what each one of the EIM entities have experienced as a result of the August and Labor Day weekend heat waves,” Shetler said. “We’re trying to summarize [the findings]” and plan to update the ISO and EIM once the analyses are complete, he said.

Overheard at IPPNY 2020 Fall Conference

More than 150 industry representatives, state officials, legal scholars and analysts attended the 35th annual Independent Power Producers of New York (IPPNY) Fall Conference on Tuesday to discuss resource adequacy, carbon pricing and emissions limits, as well as the broader need to address social and environmental justice.

IPPNY President and CEO Gavin Donohue released a set of six principles to guide members on their varied approaches to the transition to renewable energy resources. Reliability comes first, followed by the need to use markets to achieve decarbonization, electrify the transportation and heating sectors, develop needed transmission infrastructure, diversify fuels and technologies, and examine economic impacts.

“At some point in the near future, the question of New York’s reliability — generators’ ability to perform with quick, fast-starting, environmentally responsible units — is going to collide with the state’s public policy goals,” Donohue said.

Following is some of what we heard at the virtual meeting.

State Leadership

Ali Zaidi, chair of climate policy and finance in the office of Gov. Andrew Cuomo, highlighted three new initiatives this year to improve administrative efficiency and speed up the pace of the clean energy transition.

“The first is significant reform to our approach to permitting renewables within the state. You will be seeing soon proposals for how those changes get made here just a few months after the passage of the [siting] law,” Zaidi said.

The Office of Renewable Energy Siting the following day proposed draft regulations for permitting new wind and solar energy projects, as directed by the Accelerated Renewable Energy Growth and Community Benefits Act included as part of this year’s state budget.

Second is the governor’s “build-ready” initiative whereby the New York State Energy Research and Development Authority (NYSERDA) will prepare existing or abandoned commercial sites and brownfields to bundle with renewable energy contracts to provide de-risked package deals for private developers.

And third is the effort to speed up transmission infrastructure permitting and construction under the Public Service Commission’s grid study program, Zaidi said. (See NYPSC Launches Grid Study, Extends Solar Funding.)

“We know that if we want to decarbonize the entire economy, we need to help the grid reach further and deeper into the economy; specifically that means electrifying a greater share of the economy year over year,” he said. To that end, the governor this year launched an initiative to invest $1.5 billion in preparing the infrastructure to support electric vehicle charging stations, he said. (See NYPSC Approves $700 Million for EV Chargers.)

Asked what the administration’s thinking is on the upcoming carbon pricing conference at FERC and how it fits in with the state’s future, Zaidi said the technical conference would focus on state-of-the-art methods for evaluating the social costs of carbon and the implications for the power sector.

“Those are important conversations to have … and over the summer, we have proposed draft regulations on the social cost of carbon, which is going to be important in thinking about how those social costs are shaping decisions within state agencies,” Zaidi said.

Social Justice

The Climate Leadership and Community Protection Act (CLCPA), signed by Cuomo in July 2019 and enacted this year, calls for 70% of New York’s electricity to come from renewable energy resources by 2030 and for electricity to be 100% carbon-free by 2040.

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Raya Salter, NY Renews | IPPNY

“This landmark climate legislation has really shaken the ground and reset the table for the environmental conversation in New York state,” said Raya Salter, member of the New York Climate Action Council and lead policy organizer for NY Renews, a coalition of more than 200 environmental, justice, faith, labor and community groups.

Climate justice emanated from environmental justice as people became more aware of the climate crisis, and the concept eventually assumed economic aspects with the idea of a Green New Deal, she said.

“People are gravitating toward this idea of how can we make sure that we address the climate crisis yet make sure that folks get jobs [and] health care,” Salter said. “The origins of the term, however, are not as lefty as people may think. It still comes from a central-left, neoliberal or neoclassical economic idea that Milton Friedman came up with: … make these investments, and market-based mechanisms will help us drive our economy and address the climate crisis.”

The CLCPA is unique in terms of renewable portfolio standards, not only edging out California as being the most aggressive, but it includes justice provisions, she said. For example, no less than 35% of state spending on climate change will be directed toward disadvantaged communities.

IPPNY
IPPNY CEO Gavin Donohue | IPPNY

Donohue asked whether NY Renews would be open to amending the CLCPA to open the industry up to more innovation and allow, for example, carbon capture and sequestration as an offset for IPPNY members, and allow them to use other technologies.

“Because NY Renews is a coalition, I can’t speak on behalf of it unless we have an official position. … However, I think innovation is opened up rather than constrained by the CLCPA,” Salter said.

On carbon pricing, the effort needs a revenue stream.

IPPNY Chairman Chris LaRoe, senior director for regulatory affairs at Brookfield Renewable, asked what initiatives or policies do Salter or NY Renews support to help existing renewable resources across the state benefit those communities in need of environmental justice: Is there a way for them to support each other, such as increased delivery into those areas?

“I think that’s right,” she said. “Certainly NY Renews has been a part of the large-scale renewable clean energy standard docket before the Public Service Commission. … Yes, we want to alleviate transmission constraints; yes, we want to see more in-city and in-state development of clean and resilient power.”

Investing in Reliability

NYISO Executive Vice President Emilie Nelson moderated a panel on capacity markets, public policy and the age of intermittency.

“When we think about New York specifically, we see the energy and ancillary services markets working together to provide sufficient revenues for the resources needed for reliability,” Nelson said. “With that idea, and considering that we’re working on a transitioning grid and there are significant environmental mandates that need to be satisfied … where do we start?”

Pallas LeeVanSchaik, vice president of Potomac Economics, which serves as the ISO’s Market Monitoring Unit, urged policymakers to retain the existing capacity market framework as “indispensable” for achieving the CLCPA’s goals.

“In our comments earlier this year in the [resource adequacy model] proceeding, we calculated just the outstanding obligations for capacity would reach $25 billion by 2040, so [leaving the organized capacity market] would involve huge risks to ratepayers and would also greatly increase market risk for suppliers,” he said.

Considering the reduction in capacity value since state renewable energy contracts were signed up to the summer of 2020, “our estimate is in the hundreds of millions of dollars of additional capacity costs to cover this shortfall … and that’s just in 2020 alone,” LeeVanSchaik said.

Kathleen Spees, principal at The Brattle Group, said that markets can play the main role in achieving state clean energy goals, rather than a secondary, supporting role, with buyer-side mitigation central to the discussion.

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The graphs show what costs customers might face from buyer-side mitigation in New York. Energy and AS prices decrease in some cases because excess capacity depresses prices in tight hours; and because higher contract payments (from lack of capacity payments) cause energy prices to be more negative in over-generation hours. | The Brattle Group

NYSERDA and the Department of Public Service this year engaged Brattle to explore alternatives to the existing capacity markets under the resource adequacy proceeding (Case No. 19-E-0530). Brattle provided qualitative analysis in May and updated quantitative analysis in July.

“Not just New York, but many of the states are concerned about buyer-side mitigation rules resulting, as they’re intended to do, in excluding policy resources from clearing in the capacity market,” Spees said. “The outcome of that is to keep capacity market prices higher than they otherwise would be.”

Carbon pricing would be “way better” if applied economywide, across regions, but Brattle prefers the Forward Clean Energy Market as it put forth in a paper last September, she said.

William Hogan, research director of the Harvard Electricity Policy Group (HEPG), which examines alternative strategies for competitive electricity markets, recommended increasing the importance of scarcity pricing.

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Clockwise from top left: Emilie Nelson, NYISO; William Hogan, Harvard Electricity Policy Group; Matthew Schwall, IPPNY; Kathleen Spees, The Brattle Group; and Pallas LeeVanSchaik, Potomac Economics. | IPPNY

“What I am trying to do is dispel the notion that the arrival of intermittent renewables with zero variable costs means that the energy market becomes unimportant, which is wrong; but what it does mean is that scarcity pricing becomes much more important,” Hogan said.

ERCOT is implementing much more aggressive scarcity pricing than what New York is doing, he said.

Examining ERCOT performance for summer 2019, Hogan said that “the tightest conditions frequently occurred earlier than the time of peak demand, so intuitively you would expect that net demand matters more than peak demand.”

Nelson asked panelists for an alternative to carbon pricing.

“I’m a hawk on this subject, so I think carbon pricing is necessary but not sufficient,” Hogan said. “We should be focusing our research and development on new technologies and innovation, not deploying the ones we currently have. We need something way better and that’s going to be transferrable to India.”

LeeVanSchaik agreed, but with a twist: “Even if [carbon pricing] by itself doesn’t achieve the goals of the CLCPA, in concert with other things, it certainly will allow the state to achieve those goals at a significantly lower cost.”

MISO to Finish 2020 Under Budget, Courtesy Pandemic

The coronavirus pandemic continues to clamp down on MISO’s spending, with the RTO again predicting to be millions under budget by the end of the year.

Staff told the Board of Directors during its meeting Thursday that they expect MISO’s base operating expenses to be about $6.6 million, or 2.5%, below budget. That’s a slight decrease from the $7.3 million variance the RTO reported to the board in June. The RTO budgeted $264.7 million in base operating expenses this year. (See Pandemic Pause Leaves MISO Under Budget.)

MISO has reduced expenses through slimmed-down employee training and travel expenses, a product of social distancing measures aimed at slowing the virus’s infection rate. The grid operator also has a higher-than-normal employee vacancy rate, as the pandemic complicated its usual hiring tempo.

Carl Nystrom, MISO’s senior director of corporate planning and analysis, said building maintenance expenses are also down this year because the facilities are less populated and offices used less often. However, he said the grid operator is buying a new air filtration system and equipment to improve ventilation in its Carmel, Ind., headquarters.

MISO budget
MISO CFO Melissa Brown | MISO

CFO Melissa Brown said MISO expects to bill its members for 703 TWh of energy in 2020, a 3.3% reduction from 2019’s 727 TWh. Lower load levels during pandemic lockdowns have now inched back to near normal.

“In 2021, we are forecasting a return to normal,” Brown said, adding that MISO expects to collect on about 730 TWh next year.

MISO has a 45-cent/MWh Tariff revenue rate in effect for 2020 and will have a 44-cent rate in effect for 2021.

The grid operator said it expects continued pandemic-related cost savings to persist through at least early 2021. Brown said MISO anticipates pared-down travel and an embargo on in-person stakeholder meetings through June 2021.

“Obviously if the pandemic eases before then, we could have travel pick up,” she said.

MISO is planning for a $379 million budget in 2021, a 3% increase from 2020. Next year’s budget includes a $270.2 million base operating budget, a $50 million investment budget and $58.7 million in other operating expenses.

“Likely in 2022, we expect to see upward pressure on our budget,” Brown said. She attributed the increase to a more normal travel schedule, rebounding employee training activities, technology upgrades, and increased costs from running the old and new market systems in parallel during the new platform’s testing phase.

CEO John Bear said technology costs are trending toward subscription-based payments instead of lump-sum investments.

“We will be expensing things in the year instead of amortizing them,” Bear said of future budgets.