November 19, 2024

FERC Orders Fast-start Rules for PJM, NYISO

By Michael Kuser, Christen Smith and Rich Heidorn Jr.

WASHINGTON — FERC on Thursday ordered PJM and NYISO to revise their tariffs to allow fast-start resources to set clearing prices, saying their current rules are not just and reasonable.

The order concludes investigations FERC began in December 2017 under Federal Power Act Section 206 and directs the grid operators to eliminate inflexible operating limits and other rules that the commission said are preventing prices from reflecting the marginal cost of serving load. (See FERC Drops Fast-Start NOPR; Orders PJM, SPP, NYISO Changes.)

Left to right: FERC staffers Jorge Moncayo, Kaleb Lockwood and Daniel Kheloussi give a presentation on FERC’s fast-start orders for PJM and NYISO. | © RTO Insider

“Fast-start resources are typically committed in real time, very close to the interval when needed, and can respond quickly to unforeseen system needs. But without some form of fast-start pricing, some fast-start resources are ineligible to set prices,” the commission said in a press release.

FERC said the changes it is requiring will more accurately reflect marginal costs when the dispatch of a fast-start resource is the next action taken to meet load. It said the new rules will provide more accurate and transparent price signals to influence investment decisions, minimize production costs and reduce uplift.

“We find that commitment costs for fast-start resources are marginal because they are generally incurred in coordination with the real-time dispatch,” the commission said.

FERC ordered NYISO to revise its pricing logic to reflect the start-up costs of fast-start resources and relax the economic minimum operating limits of all fast-start resources by up to 100% to allow them to set prices (ER18-33).

The commission gave PJM a longer list of changes, ordering it to make a compliance filing by July 31 (EL18-34).

In opening the investigations in 2017, the commission said MISO and ISO-NE have already implemented fast-start best practices and that CAISO would get limited benefit from such changes. The commission also opened a Section 206 investigation into SPP’s practices, which remains pending (EL18-35).

NYISO

The commission directed NYISO to make a compliance filing by Dec. 31 and implement the Tariff changes by Dec. 31, 2020.

NYISO currently applies fast-start pricing logic to online and offline fixed block units that can start in 10 minutes. The ISO defines a fixed block unit as one that, “due to operational characteristics, can only be dispatched in one of two states: either turned completely off, or turned on and run at a fixed capacity level.”

In the first step of its optimization process, NYISO establishes resources’ physical base points in their real-time energy schedules. In the second step, the pricing run, the ISO relaxes the economic minimum operating limit of fixed block units to allow them to be eligible to set prices. The price of offline fixed block units can include a unit’s start-up costs.

“However, NYISO neither relaxes the economic minimum operating limits of dispatchable resources (i.e., resources that are not block-loaded), nor does it include the start-up costs of these or any online resources for the purpose of setting prices,” the commission said.

FERC acknowledged that NYISO does have fast-start pricing rules and said it is not proposing that the ISO implement a new pricing concept, nor would it require it to change its offline fast-start pricing or its rules on overgeneration “at this time.”

The Electric Power Supply Association and the Independent Power Producers of New York filed comments in February 2018 supporting the changes, saying that “reflecting all resources which have fast-start capability in energy and operating reserve real-time pricing is a fundamental concept,” and “it is critical that fast-start pricing includes all commitment costs.”

NYISO’s Market Monitoring Unit also filed supportive comments last year, saying that, “We agree with this proposed change because it is fully consistent with the economic principle that the competitive price for any good should reflect the marginal cost of supplying the good. Hence, well-designed fast-start pricing rules allow real-time prices to include the cost of committing and running peaking units when they are the marginal source of energy.”

PJM

The commission identified six Tariff revisions needed to correct PJM’s rules.

First, the commission said PJM must update its software to consider fast-start resources dispatchable from zero to their maximum operating limits for the purpose of setting prices.

Fast-start pricing also must apply to all applicable resources, which FERC said should only include those with a start-up time of one hour or less and minimum run time of one hour or less. Currently, PJM identifies combustion turbines with a two-hour start-up time as fast-start resources.

FERC also required PJM to:

  • Alter the real-time energy market clearing process to consider fast-start resources in a way that is consistent with minimizing production costs;
  • Include commitment costs in energy prices for fast-start resources in both the day-ahead and real-time markets; and
  • Implement its proposal to use lost opportunity cost payments to offset the incentive for overgeneration or price chasing.

In addition to submitting a compliance filing by July 31, PJM must make a one-time informational report by Aug. 30 explaining how the revisions do not raise new market power concerns.

FERC said PJM has special pricing rules only for block-loaded units — resources whose economic minimum operating limits equal their economic maximums, meaning they have no dispatchable range. The RTO seeks to let them set prices by relaxing the economic minimum operating limit of online block-loaded resources by up to 20% — increased from 10% in 2016.

“Even with this increase, we remain concerned that without allowing relaxation by up to 100%, marginal actions taken by system operators will not be reflected in prices,” FERC said.

The commission also said PJM’s limiting of applying fast-start pricing to block-loaded resources alone does not reflect the marginal cost of serving load when a dispatchable fast-start resource is needed. It said it agreed with commenters on “a technology-neutral approach [that] ensures that no resource that can perform the same service is unnecessarily excluded from fast-start pricing treatment.”

Commissioner Cheryl LaFleur noted that the order limits fast-start resources to those with start-up or minimum run times of one hour or less, rejecting PJM’s request for a two-hour threshold.

Daniel Kheloussi, of FERC’s Office of Energy Policy and Innovation, said the order finds that resources with start-up and minimum run times exceeding an hour “lack the flexibility to operate in a manner consistent with unforeseen and transient real-time needs, and therefore, commitment and dispatch of such resources are not analogous to a marginal decision.”

MISO Planning Subcommittee Briefs: April 16, 2019

MISO and its stakeholders are considering how to more accurately measure the potential benefits of proposed transmission projects.

Adam Solomon | © RTO Insider

The RTO is in the process of “refreshing” an ongoing list of possible new benefit metrics, planning adviser Adam Solomon said during a Planning Subcommittee meeting Tuesday.

MISO last year created two new metrics to help size up the benefits from market efficiency project candidates: the value of deferred or avoided reliability transmission projects resulting from an MEP, and the value of increased capacity on the contract path connecting its Midwest and South regions.

The RTO said it may develop even more benefit metrics by the end of the year, including increased capacity import and export limits, reduced congestion from fewer transmission outages, reduced transmission losses and whether projects can boost grid resilience. (See “More Benefit Metrics?” MISO MEP Cost Allocation Plan Goes to FERC.)

In 2017, MISO and stakeholders participating in the Regional Expansion Criteria and Benefits Working Group (RECBWG) created a “high potential” list of possible benefits that included the transmission losses and resilience metrics, as well as reduction of capacity costs from reduced peak load losses and the value of future capacity expansion deferral from increased capacity import/export limits.

Stakeholders asked MISO to elaborate on how it plans to measure the benefits of added resilience.

“We were hoping you would actually,” Solomon joked, noting the RTO is seeking stakeholder input on the metric.

“Resilience seems so vague and broad … you would almost have to create a separate stakeholder process to [define it]. I would just hate to see this bog down the process when you have other, specific and quantifiable ideas,” said Sam Gomberg, senior energy analyst with the Union of Concerned Scientists.

Solomon said he would return to the RECBWG with an updated list of benefit ideas stakeholders want to explore. MISO and stakeholders will work on prioritizing the list in the middle of the year, then discuss the feasibility of the selected benefit metrics in the third quarter. He asked stakeholders to submit written comments on the issue by May 17.

Release of 2nd Tx Cost Estimate Guide

MISO and stakeholders are finalizing the second-ever version of a cost estimation guide for the RTO’s 2019 Transmission Expansion Plan.

The RTO released its first cost estimation guide for market efficiency or multi-value projects early last year with the intent of updating the estimates as appropriate. (See MISO Releases Transmission Cost Estimates Guide.)

MISO divides transmission costs into four categories: land and right of way; structures and foundations; conductor, optical ground wire and shield wire; and professional services and overhead. Substation cost estimates are the sum of land and site work; equipment and foundations; protection and control; and professional services and overhead.

This year, MISO has added estimates for wooden poles as a structure type and for removing existing transmission lines.

But the cost estimates will be limited to traditional transmission construction components. The guide does not include estimates for HVDC lines and burgeoning technology such as energy storage-as-transmission, design engineer Alex Monn said.

“More specialized and customized project ideas are challenging to generalize for the purposes of a cost estimation guide. MISO will consider these project types on a per project basis,” the RTO said.

“From our research … those projects are really customized and site-specific, so you won’t find those in our cost estimate guide,” Monn said.

MISO could finalize and post the guide for MTEP 19 as early as the end of this week.

— Amanda Durish Cook

MISO Previews Abridged MTEP Report

By Amanda Durish Cook

MISO is considering moving ahead with a plan to streamline its report detailing the projects in its annual Transmission Expansion Plan (MTEP) beginning with this year’s.

Project Manager Sandy Boegeman on Wednesday told MISO’s Planning Advisory Committee that the RTO is considering removing brief histories of previous MTEPs, some descriptions of regional studies, an introduction to the resource adequacy construct, and descriptions of MTEP futures development and independent load forecasting.

Last month, MISO said it planned to reconfigure the MTEP report to emphasize the justifications and analyses behind the list of proposed projects while condensing planning process narratives. The RTO aims to create a more concise and readable report, which typically runs about 200 pages and always includes descriptions of the studies and processes used to recommend projects. (See MISO Considering Slimmed-down MTEP Report.)

MISO hopes the new format will help guide the RTO’s Board of Directors in its deliberations over project approvals, Boegeman said.

Jesse Moser | © RTO Insider

Jesse Moser, MISO director of economic and policy planning, said the RTO is also examining the accessibility and usability of the planning section of its website to ensure that information removed from the report is easier to locate online. He said the web improvements could take a few years to complete.

“We’re trying to do this in a way that retains what’s important,” Moser said.

Veriquest Group’s Dave Harlan said that removing futures development information from the report may inadvertently weaken its rationale for some transmission projects.

“To just sort of poke around on the website … is a burden that’s going to frustrate everyone,” Harlan said. He asked MISO to create a “definitive” appendix of website links in the report supporting the necessity of the projects in the plan.

Moser said he and his team would consider the idea and asked for additional stakeholder feedback by May 3.

PAC Chair Cynthia Crane urged stakeholders to think about what pieces of the report are essential and which should be memorialized. The PAC is scheduled to vote on whether to recommend the MTEP 19 report at its Oct. 16 meeting.

FERC: ISO-NE Won’t Change EE Rules Without Stakeholder Talks

By Robert Mullin

Call it a false alarm.

In rejecting a request for a declaratory order on Tuesday, FERC provided the petitioners exactly what they were seeking: assurance that ISO-NE will not alter its energy efficiency performance standards outside the stakeholder process.

In February, Advanced Energy Economy (AEE) and the Sustainable FERC Project petitioned FERC to issue a declaratory order that would prevent ISO-NE from retroactively revising Forward Capacity Auction 13 qualification packages to include new measurement and verification (M&V) standards not previously applied to EE resources. They also asked FERC to clarify that the RTO must seek commission approval to make any such changes. (See Groups Seek to Head off ISO-NE EE Changes.)

In their initial filing, the groups said their petition arose from reports that ISO-NE staff had made a series of phone calls to Forward Capacity Market participants with qualified EE capacity resources. During those calls, staffers said the RTO intended to change how it measures the demand reduction value of EE resources for participation in the FCM.

Graph shows New England’s projected energy savings from energy efficiency projects. | ISO-NE

The petition alleged the changes could include new “net-to-gross” conversion factors to revalue EE resources, meaning the resources could only offer into the FCM their net energy savings, rather than their gross reduction to load from baseline federal standards. The petitioners noted the factors were “never previously required of, nor imposed on, market participants” nor defined or described in the RTO’s Tariff or manuals.

The groups contended ISO-NE staff indicated the RTO would potentially make the changes retroactively and without seeking commission or stakeholder approval, “even though the contemplated changes could significantly change the quantity of the resources that have already qualified for, and cleared, the most recent Forward Capacity Auction, FCA 13.”

The petition garnered widespread support, including from public interest organizations, the Massachusetts attorney general and Eversource, which asked that ISO-NE follow the New England Power Pool stakeholder process before making any changes.

FERC on Tuesday dismissed the petition as “premature,” citing ISO-NE’s own statements in response to the petition and its lack of action on the issue (EL19-43).

“We find that the harm alleged in the petition is speculative in light of ISO-NE’s clarification that it has not made any proposal, nor does it currently have any plans, to change its M&V standards,” the commission wrote. “Furthermore … because ISO-NE has not proposed a change to its M&V standards, there is not concrete proposal for the commission to evaluate to determine whether a Tariff filing is required. As such, there is no controversy or uncertainty necessitating a declaratory finding at this time.”

ISO-NE said it was all a misunderstanding.

“As the script used by an ISO staff member for calls to energy efficiency providers makes clear … the ISO was informing energy efficiency providers that it is in the process of evaluating the implication of potential changes in federal energy efficiency standards and new information regarding net-to-gross savings ratios,” the RTO said in its March 7 initial response to the petition. “The communications do not reflect that the ISO was proposing a practice change or intending to make one.”

The RTO said it was evaluating current M&V practices because expected changes in lighting efficiency standards under section 321 of the Energy Independence and Security Act of 2007 “could substantially affect the baseline against which the savings from efficient lighting programs are determined.”

It also cited “a growing disparity between gross savings and net savings values for energy efficiency resources” reflected in updated state studies on the performance of energy efficiency measures.

“These factors warrant evaluating current practices regarding the measurement of energy savings for energy efficiency resources to assess whether changes to the ISO’s measurement standards are appropriate,” ISO-NE said.

But it said any changes would require modifications to ISO-NE manuals or Tariff and would be done “only after any such changes are vetted through the stakeholder process and any Tariff changes are filed and accepted by the commission.”

The commission’s order included comments reassuring to the petitioners. “In particular, in its second answer [to the petition], ISO-NE committed that it would only implement a gross-to-net savings methodology for determining the capacity value of energy efficiency resources through a Section 205 filing.”

AEE said it was happy with the outcome.

“As the commission states in its order, ISO New England has committed that it will not make changes to the measurement and verification standards for energy efficiency resources without engaging stakeholders and making a filing with FERC,” Jeff Dennis, AEE managing director, said in a statement. “We appreciate this commitment by ISO-NE in its answer to our petition, and the commission’s recognition of it, which brings needed clarity and certainty for energy efficiency resource providers.”

NERC Standards Committee Briefs: April 17, 2019

The standard authorization request (SAR) was prepared by the Inverter-Based Resource Performance Task Force (IRPTF), based on disturbance analyses and the development of the PRC-024-2 Gaps Whitepaper. The IRPTF identified potential modifications to PRC-024-2 to “ensure inverter-based generator owners, operators, developers and equipment manufacturers understand the intent of the standard.” (See NERC to Try Again on Inverter Rules.)

One of the most significant changes is in Section 4.1.2., where NERC proposes expanding applicability to include transmission owners “that own a bulk electric system (BES) generator step-up (GSU) transformer or collector transformer.”

It also requires inverters not trip or “enter momentary cessation” — an interruption in their injection of current into the grid — within the “no trip zone,” except for “documented and communicated regulatory or equipment limitations.”

NERC’s D.C. offices | © RTO Insider

Slight Change to Standards Efficiency Review Retirements

The standard drafting team for Project 2018-03 Standard Efficiency Review Retirements informed the committee of a need for a minor tweak to existing rules.

Reliability standard INT-009-2.1 Requirement R1 references standard INT 010-2, which has been selected for retirement. The team will remove references to INT 010-2 from the remaining standard to avoid confusion.

The drafting team arose from NERC’s 2017 Standards Efficiency Review (SER) to consider the retirements of all or part of more than 30 reliability standards. (See “Team Gets Go Ahead on Standards Retirement Review” in NERC Standards Committee Briefs: Jan. 23, 2019.)

Standards Drafting Team Set for Response to FERC Order 851

The committee unanimously approved nine nominees for a standards drafting team to respond to the directives in FERC Order 851, which approved NERC’s revised geomagnetic disturbance standard.

NERC created Reliability Standard TPL-007-2 (Transmission System Planned Performance for Geomagnetic Disturbance Events) in response to FERC’s directives to improve how its initial GMD standard, approved in 2016, addressed the risks from “locally enhanced” events.

Order 851, approved in November, directed NERC to revise the standard further to require the implementation of corrective action plans for responding to vulnerabilities to “supplemental” GMD events and to authorize case-by-case extensions of deadlines on corrective action plans. (See Revised NERC GMD Standard Approved.)

– Christen Smith

NERC Standards Committee Briefs: April 17, 2019

The standard authorization request (SAR) was prepared by the Inverter-Based Resource Performance Task Force (IRPTF), based on disturbance analyses and the development of the PRC-024-2 Gaps Whitepaper. The IRPTF identified potential modifications to PRC-024-2 to “ensure inverter-based generator owners, operators, developers and equipment manufacturers understand the intent of the standard.” (See NERC to Try Again on Inverter Rules.)

One of the most significant changes is in Section 4.1.2., where NERC proposes expanding applicability to include transmission owners “that own a bulk electric system (BES) generator step-up (GSU) transformer or collector transformer.”

It also requires inverters not trip or “enter momentary cessation” — an interruption in their injection of current into the grid — within the “no trip zone,” except for “documented and communicated regulatory or equipment limitations.”

NERC
NERC’s D.C. offices | © RTO Insider

Slight Change to Standards Efficiency Review Retirements

The standard drafting team for Project 2018-03 Standard Efficiency Review Retirements informed the committee of a need for a minor tweak to existing rules.

Reliability standard INT-009-2.1 Requirement R1 references standard INT 010-2, which has been selected for retirement. The team will remove references to INT 010-2 from the remaining standard to avoid confusion.

The drafting team arose from NERC’s 2017 Standards Efficiency Review (SER) to consider the retirements of all or part of more than 30 reliability standards. (See “Team Gets Go Ahead on Standards Retirement Review” in NERC Standards Committee Briefs: Jan. 23, 2019.)

Standards Drafting Team Set for Response to FERC Order 851

The committee unanimously approved nine nominees for a standards drafting team to respond to the directives in FERC Order 851, which approved NERC’s revised geomagnetic disturbance standard.

NERC created Reliability Standard TPL-007-2 (Transmission System Planned Performance for Geomagnetic Disturbance Events) in response to FERC’s directives to improve how its initial GMD standard, approved in 2016, addressed the risks from “locally enhanced” events.

Order 851, approved in November, directed NERC to revise the standard further to require the implementation of corrective action plans for responding to vulnerabilities to “supplemental” GMD events and to authorize case-by-case extensions of deadlines on corrective action plans. (See Revised NERC GMD Standard Approved.)

– Christen Smith

NYISO Studies Grid Transformation, Fuel Security

By Michael Kuser

RENSSELAER, N.Y. — A new NYISO study will examine the energy market and reliability implications of a grid being transformed faster by public policy than by market forces, stakeholders learned Monday.

Nicole Bouchez | © RTO Insider

“We are addressing the reliability, resilience and flexibility needs of the grid transitioning to a greener New York,” Nicole Bouchez, NYISO principal economist, told the Installed Capacity/Market Issues Working Group during an April 15 meeting that discussed the study’s outline.

New York state policies will add large volumes of zero variable-cost resources to the market, with 15,000 MW of new intermittent resources expected to lead to the retirement of 4,000 to 6,000 MW of conventional generation over the next decade, the outline said.

“We’re trying to figure out what has been done and what needs to be done, so we want stakeholder feedback,” Bouchez said.

The ISO will release the first draft of the study May 22 for discussion on May 30, ahead of the Board of Directors’ June meeting, followed by another draft at the end of August to help inform the board’s strategic planning meeting in September, she said.

NYISO thinks the market needs appropriate investment signals to attract, retain and operate new and existing resources while avoiding additional out-of-market compensation.

“The goal here is not to get ourselves into an RMR [reliability-must-run] world,” Bouchez said. “We will be looking at market revenue sufficiency; I think in many ways that’s the most ambitious part of this whole paper.”

Transitional Roles

David Clarke, director of wholesale market policy for Power Supply Long Island, asked about the transitional role of carbon pricing.

“There are ways carbon pricing can lead to short-term carbon savings,” Clarke said. “The big question is, ‘Can the state count on the market to achieve its goals?’ Is there a robust market structure that can reliably get you to 2040?”

Bouchez said the ISO sees the situation differently; the state is the one achieving its clean energy goals, with the wholesale market trying to accommodate the changes while remaining effective. (See NYISO Seeks to Refine Carbon Price Equation.)

Erin Hogan, representing the New York Department of State’s Utility Intervention Unit, asked the ISO to provide more precise definitions of the state’s goals. The study refers to a carbon-free grid by 2040, for example, when in fact the current announced target is a carbon-neutral grid, which is not the same thing, she said.

Raj Addepalli, representing the Alliance for Clean Energy New York, asked whether the ISO knows of anyone in the world with experience fully operating a system on resources with no variable costs and how markets can be structured in such a scenario.

Bouchez noted California has been thinking about the topic somewhat longer than New York but has not yet figured it out.

Miles Farmer of the Natural Resources Defense Council asked if the ISO has plans to address the inconsistency between its market mitigation rules and the state’s announced plan to pursue 100% emissions-free resources. He contended mitigating state-supported resources does not make sense with “a state-driven market entry model.”

“We will be looking at the mitigation rules and their compatibility with the desire of the state to have programs that value different attributes,” Bouchez said.

The ISO also announced April 23 as the date for a second presentation by Analysis Group on the outline of a new study to provide additional insights into pricing carbon into NYISO’s wholesale electricity markets. The firm’s Sue Tierney and Paul Hibbard will present initial analysis results May 14, and the ISO expects to post the final results by the end of May. (See Analysis Group Presents NYISO Carbon Pricing Study Plan.)

Fuel Security

NYISO also said Monday it will take a second look at assumptions being used in a separate study commissioned to assess winter fuel and energy security for the New York Control Area.

Hibbard presented additional details on the study, reviewing weather and natural gas market assumptions.

“The 17-day cold snap from last year is used in the new model, but it also includes three days from an older and more severe cold period,” he said.

Graph shows degree days and local distribution company natural gas demand for the 17-day modeling period to be used in the fuel security study. | NYISO

Based on review of local distribution company documents, Hibbard said essentially all pipeline export capacity from New York to New England is assumed to be under firm contract to deliver flowing gas or transport stored gas, with 889 MMcfd of natural gas available for electric generation after accounting for retail gas demand in New York, equivalent to roughly 5 GW of electricity generation under severe cold conditions.

Hogan asked what kind of validation process Analysis Group used “to make sure [it was] in the ballpark with results.”

“We’re trying to see where the risks are to the electric power system based on natural gas supply constraints, not the worst-case or best-case scenario,” Hibbard said.

Wes Yeomans, the ISO’s vice president of operations, said, “Remember, on the supply side, we’re going to have Indian Point out and no coal. … Things will be different in 2023 from what they were in earlier forecasts.”

One stakeholder mentioned the importance of considering the impact of energy storage on fuel demand, given the state’s programs to help finance development of 800 MW of new energy storage resources. (See NYPSC Expands Storage, Energy Efficiency Programs.)

Weather assumptions for the fuel security study will now include data from a previous 3-day severe cold snap. | NYISO

“We likely will not change base assumptions in the initial scenario but will address storage and various other stakeholder concerns in the scenarios and as part of the findings of the analysis,” Hibbard said.

Analysis Group currently expects to present initial findings of the energy security study in May, additional findings in June and final results in July.

FERC to PJM: Clarify Allowable Costs for Energy Offers

By Christen Smith

FERC handed PJM a mixed ruling Monday on a set of proposed Tariff and Operating Agreement revisions intended to equalize the cost recovery treatment of gas-fired plants with that of other thermal generators.

The commission approved the Tariff changes, agreeing PJM’s existing rules “unduly discriminate” against combined cycle and combustion turbine generators by preventing them from recovering inspection costs as a “maintenance adder” in their energy prices.

Those types of variable costs are considered related specifically to electricity production and should be recoverable in the energy market, the commission said (ER19210). Many nuclear and fossil generators currently factor these expenses into their avoidable-cost rates in the capacity market.

In approving the Tariff changes, FERC rejected the PJM Independent Market Monitor’s argument that major maintenance costs incurred as a result of electricity production should be recovered in the capacity market because they are not short-run marginal costs. The PJM Load Coalition likewise insisted variable operations and maintenance costs belonged in capacity market offers only.

The commission also dismissed concerns that the changes risked double recovery by generators in both the energy and capacity markets.

FERC agreed with PJM that its existing rules for maintenance cost recovery discriminates against CC and CT generators | Panda Power Funds

“We accept PJM’s Tariff revisions to clarify that all resource types are prohibited from recovering variable maintenance costs that are directly attributable to the production of electricity in their avoidable-cost rate in the capacity market,” the commission wrote.

But FERC found related changes in PJM’s Operating Agreement to be “unjust and unreasonable” because “the definitions of maintenance adders and operating costs fail to provide sufficient clarity with respect to permissible cost components of cost-based energy market offers.”

The commission directed PJM to submit a compliance filing clarifying what maintenance costs sellers can include in their energy market offers. The revised OA must do the following:

  • Create a single, properly defined operating cost component.
  • Remove “incremental fuel costs” and “other incremental operating costs” from the list of permissible components in a cost-based offer.
  • Add a definition for “opportunity costs” and create a new section detailing this component.
  • Create a new section for the “application of cost components to three-part cost-based offers.”
  • Move definitions for “maintenance adders” and “operating costs” to a new opportunity costs section.
  • Expand the list of maintenance costs to include cooling towers, fuel and water pumps, emissions-reduction catalyst equipment, and replacement of filters and cartridges.
  • Add sections to memorialize PJM’s process of calculating major maintenance costs based on 10- or 20-year histories.
  • Revise the section related to the review of maintenance adders and operating costs to require market sellers to specify the maintenance history years on which their maintenance adders are based.

The Monitor had pushed for the required clarifications.

FERC on Monday also accepted PJM’s quadrennial revision of its variable resource requirement curve used in the Reliability Pricing Model, effective Jan. 17 (ER19-105).

OSW Industry Urges Cooperation as States Covet Jobs

By Rich Heidorn Jr.

NEW YORK — Looking for a place to assemble offshore wind farms on the East Coast?

New York officials say their 63 acres at the South Brooklyn Marine Terminal could be just the place. For about $300 million, a report for the New York State Energy Research and Development Authority says, it could demolish existing warehouses, dredge the dock area and fortify the ground to withstand loads of 6,000 pounds/square foot to dedicate the port to OSW staging and deployment.

Massachusetts officials, meanwhile, are touting New Bedford, insisting the new industry can coexist with fishermen in the most productive fishing port in the country. In October, developers signed a lease to use the New Bedford Marine Commerce Terminal to stage and construct turbines for the 800-MW Vineyard Wind project 15 miles south of Martha’s Vineyard.

And Boston office buildings are renting space to members of the European OSW industry looking to create a headquarters for their U.S. operations.

East Coast states are now promising to fund the construction of nearly 18,000 MW of offshore wind, almost equal to Europe’s current capacity. While state officials say the procurements are long-term investments intended to address climate change, they acknowledge the immediate lure is economic development. The European OSW industry employs 40,000 people.

At the Business Network for Offshore Wind’s 2019 International Partnering Forum at the Grand Hyatt New York last week, the talk was all about the jobs and contracts the industry would bring. In the forum’s exhibit area, state economic development agencies and labor unions manned booths alongside engineering firms and providers of everything from cranes to helicopters to drones.

Liz Burdock, CEO of the Business Network, said that while building a local supply chain will lower the cost of U.S. OSW, it is the economic development that the industry should promote in talking with other stakeholders.

“As we talk about public acceptance and getting more people willing to support our industry, I don’t think it is really about what is the lowest cost of energy. It has to be about what is the job creation. And maybe we are going to have to pay a little bit more,” she said. “I think that’s something that we need to start saying.”

“We have every intention to be here locally,” said Jason Folsom, director of U.S. sales for MHI Vestas Offshore Wind, a joint venture between Mitsubishi Heavy Industries and turbine maker Vestas Wind Systems based in Denmark. “We do not want to run our new market businesses from Europe. We’re here to build stuff.”

Cooperation vs. Competition

Numerous speakers at the conference questioned whether states can cooperate to nurture the fledgling industry even as they compete to promote their ports as potential manufacturing hubs. Several urged states to stagger their procurements to create steady, predictable demand.

“The supply chain in the U.K. was really dependent on having consistent procurements happening,” said Eric Thumma, director of policy and regulatory affairs for Avangrid Renewables. “When they had an on-again, off-again nature of the procurements, that made it very difficult to get supply chain folks to be confident enough to invest. So, one of the challenges in the U.S. is how do you get the states to collaborate on sort of a comprehensive offshore policy?”

NYSERDA Chairman Richard Kauffman said the states are cooperating through the National Offshore Wind Research & Development Consortium, which the agency started last year with funding from the U.S. Department of Energy. Other participants include the National Renewable Energy Laboratory, Brookhaven National Laboratory, developers, and the states of Maryland, Massachusetts and Virginia.

“We frankly never realized the power of friendly competition that we started through this collaboration,” Kauffman said. “All Eastern states with water can benefit from scale.”

NYSERDA CEO Alicia Barton was asked by an audience member during one panel discussion at the IPF whether New York would invest in assets outside the state if it can’t build a manufacturing hub in any of its ports.

“We get that question a lot,” she acknowledged, without definitively answering it. “I work for the people of New York, and I am, along with Gov. [Andrew] Cuomo, committed to making New York the center for the U.S. offshore wind industry. We’re not shy about that.

“On the other hand, we are quite realistic. … We want 9,000 MW of offshore wind. That makes us a very large buyer of offshore wind, locally speaking. … It is without a doubt in our interests to see the U.S. supply chain mature [and] develop as fast as possible to see the U.S. industry scale as fast as possible so that as a large buyer, we will get the best deal possible.”

Tim Sullivan, CEO of the New Jersey Economic Development Authority, said he’s realistic. “We’d love to have those 40,000 [jobs] in New Jersey, but it’s going to be a regional thing,” he said.

Sullivan said states will need to work with community colleges and labor unions to develop the workforce needed to ensure the supply chain is developed locally. “Cobbling together wind, offshore wind and oil and gas [resources] from the European supply chain … would be a really unfortunate outcome,” he said. “That would be a terrible outcome for New Jersey … for the Northeast, because this is a once-in-a-generation opportunity.”

Sullivan said officials overseeing port development for OSW also need to balance short- and long-term considerations.

“There will be an impulse to overly design the infrastructure and the supply chain to [accommodate] the first set of projects that are moving forward as opposed to designing for an industry,” he said. “We want a network of ports that is somewhat project-agnostic, that is somewhat developer-agnostic, so it can have multiple users over the next 45 to 50 years.”

Walter Cruickshank, acting director of the U.S. Bureau of Ocean Energy Management, which awards leases and oversees OSW projects in federal waters, said his agency is doing its part to ensure the industry’s growth by developing “an efficient and predictable regulatory process.”

BOEM has issued 15 leases totaling more than 1.7 million acres at a cost of almost $477 million since 2012. The lease price per acre — which had been as low as $39 in 2013 — topped $1,000 in three auctions off Massachusetts last year.

Cruickshank said OSW projects will be subject to President Trump’s “one federal decision” executive order, which requires all federal agencies to coordinate their reviews of major infrastructure projects in a single proceeding and to issue rulings within two years.

BOEM also is taking a regional approach to its evaluation of some potential new wind energy areas (WEAs), he said.

Rather than focus on the small section of the ocean off New Hampshire’s narrow 18.5-mile coast, he said, “We see value in looking at the Gulf of Maine as a whole, and pulling in the states of Maine and Massachusetts to look … at the effect of sharing natural, socioeconomic and cultural resources to plan how we might proceed in that area.”

BOEM also is combining the planning processes for the Carolinas, with plans to identify a WEA there later this year.

Giles Dickson, CEO of WindEurope, a trade group representing the European wind industry, said success for the U.S. OSW industry will require “happy coexistence” with the military as well as the fishing and shipping industries.

NYSERDA was cognizant of those stakeholders when it issued a solicitation for the state’s first, 800-MW OSW procurement, Barton said. The agency is expected to announce the winners next month. (See Four Bidders Vie for NY Offshore Wind Project.)

“We made clear … that we wanted to see great projects,” Barton said. “That we wanted to see strong economic development commitments, that we wanted to see commitments to labor … we wanted to see fishery mitigation plans.”

100% Clean

The Atlantic states’ OSW targets are central to their efforts to reduce carbon emissions and address climate change.

In January, for example, Cuomo announced New York was nearly quadrupling its offshore wind energy goal to 9 GW as part of its plan to reach “100% clean power” by 2040. (See New York Boosts Zero-carbon, Renewable Goals.)

New Jersey, California, Hawaii, New Mexico, Puerto Rico and more than 100 cities across the country have also pledged to move to 100% renewable or “clean” energy, as have more than 150 companies, from Adobe to Walmart.

While the 100% goal has no shortage of critics who question its feasibility, those who support it say OSW will be a big part of the resulting generation mix. A recent Stanford study projected a 19% share for offshore wind, with onshore wind and utility-scale PV at 31% each.

“It’s very ambitious, but we do believe it’s actually achievable,” Barton said of Cuomo’s goal. “To achieve that target, offshore wind has to be a huge piece of the puzzle,” she added, noting that the 9,000 MW of OSW would represent 30% of the state’s load.

Barton said the 100% pledges by Cuomo and other governors reset “the conversation about what’s possible. Even a year or two, three years ago, we would not be talking about California, New York [and] New Jersey — major economies in the U.S. — committing to a 100% clean electricity. It’s been a radical mind shift. It’s clear we don’t have a lot of time … to do what we know needs to be done to combat climate [change].”

Marie Hindhede, deputy permanent secretary for the Danish Ministry of Energy, Utilities and Climate, said higher penetration by renewables doesn’t mean less reliability, noting her country had 99.99% “security of supply” despite getting three-quarters of its power from wind, solar and biomass.

To reach the 100% goal, she said, Denmark needs an active demand-side response and more transmission to sell power across national boundaries. Hindhede said power trading with other countries has been key to balancing intermittent generation thus far but that electric storage will likely be part of the solution in the future.

Steve Dayney, head of North American offshore operations for Siemens Gamesa Renewable Energy, said reaching 100% is “not really an issue of technology. It’s an issue of, do we have the will to do it? It’s an issue of how fast new technologies can emerge and how quickly can we industrialize it to make it cost-competitive.”

Ditlev Engel, CEO of DNV GL, which provides risk management and quality assurance services to OSW and other maritime energy industries, said one key to winning political support for 100% policies is to include the health-related costs of climate change and air pollution in the discussion.

“Everybody talks about the cost of electricity per megawatt or per kilowatt-hour. But what about the costs to society? Are we using the right rulers for how we set the systems up?” he asked.

Longer Tx Planning Horizon Seen for OSW

By Rich Heidorn Jr.

NEW YORK — U.S. grid operators may have to consider a different way of transmission planning for offshore wind, panelists told the Business Network for Offshore Wind’s 2019 International Partnering Forum last week.

Speakers said interconnections to the land-based grid should be shared “social” resources and that queue positions shouldn’t be a deciding factor in states’ OSW solicitations.

Christer af Geijerstam, president of Equinor Wind US, said locating offshore cables is not a concern. “But if you are targeting substations that are 20 miles inland, how many times do you want to go dig up that same road for future projects? Should we pre-invest in capacity?”

Sven Utermöhlen, board member for E.ON Climate & Renewables, agreed that a long time horizon is essential to OSW transmission planning.

“If you think about 15 to 20 individual projects in the next decade or so to be constructed, you may find that there is only a handful of really suitable, sensible grid connection points … you better have a plan in place because you don’t want to dig up the same onshore connection route five times over the next 15 years.”

Repeated construction could undermine public support and complicate permitting, he said. “So, you better start thinking about a real network development plan.”

Clarke Bruno, lead partner for Anbaric Development Partners, said New York will have to expand its onshore grid to move its planned 9,000 MW of offshore wind from delivery points on Long Island and in New York City.

“Long Island [is] about a 2,400-MW load. Taking half of that 9,000 MW and trying to drop 4,500 MW into a 2,400-MW system is going to be a challenge. The same is true in New York City [with] a much larger average load of 6,400 [MW].

“There are very few interconnection points in Long Island and New York that have the degree of robustness that you would like to have. And … getting from offshore to those interconnection points, you have very few good routes, given the congestion on Long Island and the wetlands and, in New York City, the bottleneck of the Verrazano Narrows. So, with those challenges in mind, it strikes me that a planned transmission system is essential.”

The state must “plan and permit the offshore wind so that we are able to … seize the optimal interconnection points and allow equal access to all developers to those very scarce social resources.”

Gil Quiniones, CEO of the New York Power Authority, agreed with Bruno’s description of the challenges.

“Long Island, especially on the East End … we [say] ‘the wires are thinner.’ And New York City is very dense and [does not have] a lot of very easily accessible connection points. … Logic tells you that there is maybe an opportunity to have a collector system … and bring it to the optimal interconnection point. It does require planning. It requires all the regulatory bodies — state and federal — to be aligned in making that happen.”

State officials and grid operators have only begun to consider the transmission challenges of offshore wind.

The New York State Energy Research and Development Authority’s OSW Master Plan, published in January 2018, said an expandable “backbone” transmission system would offer economies of scale and reduced barriers to entry but could also lead to overbuilding and stranded asset costs. A transmission system custom-built for a single offshore facility — the “direct radial” model — would be less efficient and is limited in scope, the report said. (See NY Offshore Wind Plan Faces Tx Challenge.)

Proposed offshore wind projects in Connecticut (1,760 MW), Rhode Island (1,056 MW) and Massachusetts (6,064 MW) represent almost half of the 18,600 MW in ISO-NE’s transmission queue, Alan McBride, the RTO’s director of transmission and strategy services, told the IPF conference in a presentation.

PJM Begins Talks on OSW Tx Rules

In February, PJM’s Planning Committee approved a problem statement to consider granting merchant transmission developers capacity interconnection rights (CIRs) for offshore wind. (See “PC Moves Forward on Offshore Interconnection Rights,” PC/TEAC Briefs: Feb. 7, 2019.)

Current rules allow merchant transmission developers to obtain transmission injection and withdrawal rights for DC facilities or controllable AC facilities connected to a control area outside the RTO. Under the problem statement, stakeholders will consider allowing merchant transmission developers to request CIRs, or equivalents, for non-controllable AC transmission offshore.

Offshore transmission developers want to acquire CIRs so PJM can identify the necessary network upgrades.

The key difference from the normal procedure is that the developers want to build transmission before the generation is sited. Without generation at the other end of the line, PJM cannot perform stability or short-circuit analyses.

The first meeting of the initiative, on April 16, will consist of education about the RTO’s current process. Three months of exploration into alternative options are planned before members will return to the PC in August to consider endorsement of proposed changes.