PJM 5-Minute Dispatch Proposal Endorsed

Stakeholders gave a nearly unanimous endorsement of PJM’s short-term proposal to resolve issues in five-minute dispatch and pricing at Wednesday’s Market Implementation Committee meeting but urged the RTO to continue seeking intermediate and long-term solutions.

PJM’s proposal won 96% support, with 205 members voting in favor, nine against and 31 abstaining. In a nonbinding vote that asked whether members preferred the package over the status quo, the measure passed with 100% support: 218 “yes” votes and 18 abstentions. “I don’t think I’ve seen this before,” said Bhavana Keshavamurthy of PJM.

The RTO’s proposal will have a first read at the June 18 Markets and Reliability Committee meeting and a July vote at the MRC and Members Committee meetings. Pending FERC approval, implementation is tentatively slated for October.

PJM Dispatch Proposal
Tim Horger, PJM | © RTO Insider

Tim Horger of PJM presented the highlights of the package, which calls for “work streams”: short-term market changes to address pricing alignment; “enhancements and clarifications” to LMP verification; intermediate operational changes to implement more “regimented” real-time security-constrained economic dispatch (RT SCED) case approvals; and long-term operational changes to investigate changing SCED timing and consider previous dispatch instructions.

Horger said PJM decided to break the process up into short-term, intermediate and long-term efforts based on how quickly they could be implemented.

PJM’s proposed short-term fixes would align the locational price calculator (LPC) to use the reference RT SCED case for the same target time. The LPC would calculate prices for the interval from 11:55 a.m. to 12 p.m. using the RT SCED solution for a 12 p.m. target time.

Resource offers, parameters and ancillary service assignments would be inputs to the RT SCED cases. Offers for 11 a.m. to 12 p.m. would be effective through 12, with offers for 12 to 1 p.m. used for the dispatch target 12:05.

FERC ordered PJM last year to revise its Tariff to allow fast-start resources to set clearing prices. In January, the commission voted to hold the RTO’s fast-start pricing compliance filing in abeyance until July 31, agreeing with the Independent Market Monitor and others who said resources’ compensation don’t correspond to their dispatch instructions because PJM uses different market intervals to calculate prices and dispatch. (See FERC Stalls PJM Fast-start Compliance Filing.)

Proposed short-term implementation | PJM

After attempting to craft a joint proposal in response to FERC’s January ruling, PJM and the Monitor told the MIC in April that they were unable to agree on implementation timing. (See PJM, IMM at Odds on 5-Minute Dispatch, Pricing Rules.)

In addition to making changes to settlements as in the PJM plan, the Monitor also proposed changes to dispatch and SCED calculations. “This is an important price formation issue in PJM,” said the Monitor’s Catherine Tyler.

The Monitor’s proposal failed with only 32% support at Wednesday’s MIC meeting.

Wednesday’s vote on the PJM package was limited to the short-term changes, Horger said, and not whether they address the issues the Monitor raised in the fast-start pricing docket. Stakeholders can opine on whether the short-term fix satisfies FERC’s concerns in comments on PJM’s filing, Horger said.

PJM Dispatch Proposal
Paul Sotkiewicz, E-Cubed Policy Associates | © RTO Insider

Paul Sotkiewicz of E-Cubed Policy Associates said many stakeholders are still looking to PJM to move fast-start pricing along in the process and asked if short-term fixes could be a major component of the issue.

Horger said the short-term changes are beneficial regardless of what happens with fast-start pricing. He said PJM’s legal view is that short-term changes will meet the fast-start directives from FERC.

PJM is also committed to the intermediate changes, Horger said, but it doesn’t think they are necessary for fast-start pricing.

“We have not heard a firm commitment [from PJM] on even the intermediate” solution, countered Monitor Joe Bowring.

Becky Carroll of PJM gave an operational update on the intermediate changes the RTO is pursuing. Carroll said a 48-hour test of the five-minute auto case execution was successfully completed before Memorial Day.

Carroll said no concerns were found during the test. The next test of the system is planned for June 22, she said, and if it is successful, PJM will use the procedure permanently and draft manual changes documenting it.

Adrien Ford of Old Dominion Electric Cooperative said her company supports PJM’s short-term changes but would also like to see the intermediate and long-term changes fully pursued. She said she struggles when she hears PJM officials use the phrase “committed” to intermediate changes.

“We really want the whole kit and caboodle,” Ford said.

Vice President of Market Services Adam Keech said the RTO wants to “look more broadly” at potential long-term solutions.

“It’s not clear that the MISO/SPP approach that has been proposed [by the Monitor] here is better than what we’ve proposed and the best option out there,” Keech said. “Our reluctance is not knowing whether it’s the best answer … whether it’s better than what ERCOT does, for example.”

Sotkiewicz said PJM needs to listen “very carefully” to stakeholders’ calls for intermediate and long-term changes. He said interest remains in going all the way with pricing changes and not just stopping with the short-term fixes.

“This is a member-driven organization, and just because it might be hard to do doesn’t mean we should just be committing to evaluate,” Sotkiewicz said. “If it’s something that makes sense, we should be committed to do it.”

“We do commit to doing the analysis on the options,” Keech responded.

CleanPower 2020: Renewables’ Future Still Holds Hope

Before the COVID-19 outbreak, the American Wind Energy Association had planned to unveil a new exhibition hub, bringing together the utility-scale wind, solar and energy storage industries at its annual conference and trade show in Denver.

Instead, it settled for a web-accessible three-day event featuring virtual runs, bike rides, happy hours and, of course, panel discussions with homebound speakers.

“We knew it would be different,” AWEA CEO Tom Kiernan said June 2 in opening remarks from his home. “I sure didn’t think it would be this different.”

Last year’s conference in Houston drew more than 7,000 attendees and more than 450 companies, numbers AWEA was expecting to surpass this year with the rebranded CleanPower 2020. Instead, the organization will have to wait until next year, another disappointment in a year where the pandemic brought much of the economy to a standstill.

CleanPower 2020
AWEA CEO Tom Kiernan (top left) virtually moderates a panel with (clockwise) NHA’s Malcom Woolf, SEIA’s Abigail Ross Hopper and ESA’s Kelly Speakes-Backman.

The wind industry was coming off a “banner year” in 2019, adding 9.1 GW of capacity to crack the 100-GW barrier and $14 billion in new projects. An “unprecedented” pipeline of projects added to the optimistic outlook. (See AWEA: COVID-19 Places 25 GW of Projects at Risk.)

“Obviously, the COVID pandemic was an economic buzz saw for the U.S. and world economy,” Kiernan said. “We’re facing some significant financing challenges.”

Still, AWEA’s lobbying efforts in D.C. have resulted in the IRS issuing a one-year extension of the safe-harbor provision for wind projects begun in 2016 and 2017, giving developers 12 extra months to qualify for production and investment tax credits.

But there is more work to do, Kiernan said, particularly with an offshore wind sector that was “just taking off.” AWEA says the U.S. has 15 active commercial leases for offshore wind development, capable of supporting about 25 GW in capacity.

“We’ve got to keep that momentum going,” he said. “Despite the world’s economic challenges, renewables in general — and wind in particular — have a bright and extraordinary future. Why? Economics.”

Kiernan said renewables remain the cheapest source of generation. Wind costs have fallen about 70% over the past decade, helping the economics remain “so doggone compelling.”

“Utilities are increasingly buying and using renewables,” he said, pointing to the 16 GW of power purchase agreements in 2018. “Americans want it, and we’re cost effective.”

CleanPower 2020
The Block Island Wind Farm, off Rhode Island, leads an offshore sector that was “just taking off.” | Block Island Ferry

In collaboration with others in the renewable sector, AWEA has put forth a vision of renewables constituting a majority of U.S. capacity by 2030.

“It’s tough to think about going to this great bright future from the depths of where we are now,” Kiernan said. “We have worked to craft a very simple — a very compelling — vision. Pursuing this vision will create hundreds of thousands of jobs, while providing reliable, clean and cost-effective energy.”

Renewable Industries Agree on Advocacy Principles

Kiernan was joined on the webcast by representatives from the solar, hydro and storage industries, who added their thoughts on the majority-renewables-by-2030 vision.

“Having this clear vision is critical. We’re very much mainstream right now, but it wasn’t too long ago that we were alternative energy,” said Malcom Woolf, CEO of the National Hydro Association. “It shows how these technologies work together. We balance each other. We have different attributes that complement each other.”

“It’s really consistent with who we are as an industry,” said Energy Storage Association CEO Kelly Speakes-Backman. “There’s no reason for energy storage to exist without the other sources to our grid. [Storage] is the bacon of the grid; it makes everything a little bit better. We’re more than happy to help resources that make cleaner air for all of us.”

The associations now share advocacy principles “as critical” to attaining their vision of majority renewables by 2030:

  • Achieve significant carbon reductions.
  • Build a more resilient, efficient, sustainable and affordable grid.
  • Advance great competition through fair market rules.
  • Actively collaborate across industry segments.

“Taking that shared vision to [Capitol Hill] and our policy advocacy makes it clear to our own constituencies … that we are creating a vision and markets for all of us,” said Abigail Ross Hopper, CEO of the Solar Energy Industries Association. “If you think about the grid itself, it was designed over 100 years ago for centralized power plants. But the rules as centralized power generators have certain attributes that don’t allow for a lot of competition.

“It’s important we have market rules that compensate generators for their attributes, rather than being for a certain fuel source,” she said.

“These principles really lift all boats and help all of our industry,” Woolf said. “It’s so much more effective when we can work it out behind closed doors before we go to the policymakers.”

PJM Panel Pushes Back Against MOPR

Maryland Public Service Commissioner Michael Richard did not mince words during a panel addressing FERC’s December order requiring PJM to overhaul its capacity market by expanding the minimum offer price rule (MOPR) to new state-subsidized resources within its footprint. (See FERC Extends MOPR to State Subsidies.)

CleanPower 2020
Michael Richard, Maryland PSC

“We’ve been very successful in largely being united [against] the MOPR, largely because we agree it’s an unlawful intrusion,” Richard said, speaking from Maryland’s perspective. “Our citizens will be paying more and not getting the clean energy they’re demanding. It’s an unfair windfall for generators.”

State regulators, utilities and load-serving entities have argued in rehearing requests to FERC that the order goes too far in attempting to control their generation choices and fails to prove state-subsidized resources suppress capacity market prices. One of the primary concerns is for offshore wind, which is subsidized by the states and won’t be able to clear the capacity market because its default MOPR prices are well above clearing prices.

Maryland is one of those states, with the administration, energy office and commission all opposing the MOPR. Richard said the MOPR tends to unite PJM’s states, four of whom are members of the Regional Greenhouse Gas Initiative or are among the 25 states committed to the 2015 Paris Agreement on climate change.

“A majority of our states are moving to decarbonize at different rates. We really need PJM’s support for state policies,” he said, pointing to PJM states’ collective goal of 30 GW of clean energy requirements by 2030. “We’re going to need a lot more renewable energy in the PJM footprint. What FERC is doing, in the words of its own orders, is disregard and nullify its own orders. That’s a great concern and why we’re largely united in opposing the MOPR.”

CleanPower 2020
Kent Chandler, Kentucky PSC

“The reality is some states care what color their megawatts are,” said Kent Chandler, executive director of the Kentucky Public Service Commission, which oversees a regulated market. “A number of states want green energy, and there are two ways to go about it: either accommodate it or go somewhere else. The only way forward is to accommodate [green energy] somehow.

“There has to be a middle way for some states to get green energy without FERC determining what is some sort of cost shift. I fully expect that by the time the litigation over the MOPR is over, we’ll have a different [market] construct by then,” he said.

Asim Haque, PJM’s newly minted vice president of state and member services, said the grid operator’s recent compliance filing was an effort to balance the various constituencies in its 14-jurisdiction region (13 states and D.C.). (See PJM Makes MOPR Compliance Filing.)

“We have a very diverse footprint. We view that as a strength. It’s a wonderful microcosm of the country at large,” Haque said. “It creates challenges for PJM because when we think about where PJM is in a situation like this, we’re trying to homogenize various market priorities to advance particular fuel types or technologies, without detriments to others.

Asim Haque, PJM | © RTO Insider

“Look at the compliance filing,” Haque said. “We worked hard to accommodate as many state policies as we could. The hope is we get through collectively this MOPR phase of the capacity market. Getting through this iteration doesn’t necessarily [solve] the larger problem of how we homogenize these different market priorities within one larger construct.”

Greg Poulos, executive director of Consumer Advocates of the PJM States, said stakeholders have already begun to evaluate PJM’s market design, given its 26% reserve margin, requirements to add 10 GW of wind resources by 2029 and decarbonization discussions.

“The MOPR order hasn’t been implemented yet and already there are thoughts of ‘what do we do now?’” he said. “There’s a clear understanding PJM doesn’t have the ability to implement carbon pricing without the states taking some action. But what are we going to do with [10 GW of wind resources]? There’s not an answer right now. There’s a lot of excess resources, with a lot of resources coming on. How do we pay for all these resources and make it more effective? We’re already thinking about that.”

PJM MIC Briefs: June 3, 2020

The PJM Market Implementation Committee on Wednesday endorsed an initiative to update the RTO’s business rules to accommodate co-located generation and energy storage hybrid resources.

The issue charge passed unanimously by acclamation and is set to be overseen by the proposed Distributed Energy Resource and Inverter-based Resources Subcommittee (DIRS).

Scott Baker, PJM business solutions engineer, provided a first read of the problem statement and issue charge for the effort, which will define how current requirements for solar parks, solar resources, intermittent resources and energy storage resources do and do not apply to generation-battery hybrids.

PJM
Scott Baker, PJM | © RTO Insider

The focus of discussions will initially be centered on solar-battery resources, which represent more than 95% of the more than 10,000 MW of hybrids in the PJM interconnection queue. But the issue charge allows for investigation of other hybrid resources like wind-battery, gas-battery or any other combination. Baker said that as a result of stakeholder feedback at the Markets and Reliability Committee, the issue charge calls for the subcommittee to begin work in July and report its findings and proposed solutions to the MIC by the end of 2020. (See “Action on Hybrid Resource Initiative Deferred on Venue Question,” PJM MRC Briefs: April 30, 2020.)

Baker said the solar-battery hybrid issue assignment was intentionally left blank because the MIC is also discussing the consolidation and creation of the DIRS. He provided the first read of the charter for the new subcommittee and a proposal to sunset the Intermittent Resources Subcommittee (IRS). The IRS originated as the Intermittent Resources Working Group (IRWG) in 2008 to address issues regarding operations and reliability, energy markets, capacity markets and interconnections.

Baker said that although DIRS would operate under the MIC, stakeholders requested that the subcommittee also coordinate with the Planning and Operating committees. Baker said many of the issues discussed at DIRS could affect both markets and operations.

PJM will seek endorsement of the new subcommittee at the next MIC meeting on July 8.

PRD Credits Disposition

Sharon Midgley of Exelon provided a first read of the problem statement and issue charge addressing the price-responsive demand (PRD) credits disposition. The issue calls for the MIC to review the market design to determine if the current load-serving entity PRD credits are appropriate and to explore alternative allocations.

PRD providers represent retail customers that have the capability to reduce load in response to prices. Midgley said current PJM settlement rules do not address electric distribution companies (EDCs) or curtailment service providers (CSPs) that do not have direct responsibility for serving retail load but otherwise meet the eligibility requirements of a PRD provider.

All revenues associated with PRD are credited to the LSE for the area, Midgley said, meaning some market participants are paid for PRD service that an EDC or CSP is supplying while performance penalties stay with the PRD provider.

The committee will vote on the issue charge endorsement at its July meeting. The work effort is expected to take six to nine months, with changes implemented in advance of the 2021/22 delivery year.

Performance Assessment Interval Settlements

Danielle Croop of PJM conducted a first read of a problem statement and issue charge to increase transparency in settlement calculations for nonperformance charges, including ancillary service accounting and the determination of scheduled megawatts. It will also include provisions to make language for energy-only and demand response resources parallel with that of generation resources.

In March, PJM released a report on performance assessment interval (PAI) settlements as an addendum to its review of the Oct. 1-2, 2019, performance assessment event, when an abnormal heat wave led to emergency procedures and the first call on DR resources in more than five years. (See PJM, Stakeholders Baffled by DR event.)

The incident resulted in $8.2 million in nonperformance charges. Bonus payments averaged $32.89/MW-interval, with the average amount of megawatts eligible for bonuses during the event being 9,706.

PJM
| © RTO Insider

In her presentation, Croop said PJM staff found the settlement calculations for the Oct. 1-2 emergency event lacked transparency. A market notice was posted on PJM’s capacity market webpage detailing how the RTO settled the charges and credits.

Croop said the RTO will seek stakeholder input on business rules not described in detail in the governing documents. The initiative will memorialize the business rules in the appropriate agreements and manuals without changing the substance of Capacity Performance rules.

Independent Market Monitor Joe Bowring said he disagreed with some of PJM’s proposed language changes, calling it “subjective” and difficult to interpret. Bowring said some of the proposed rules may not be consistent with CP.

“We want to make sure the end result is that this process works properly,” Bowring said.

The MIC will vote on the issue charge approval at its July meeting.

FERC Transmission Orders

PJM’s Ray Fernandez provided updates at both the MIC and the June 2 Planning Committee meeting on the cost allocation impacts of two recent FERC orders requiring resettlement.

In the first order, FERC ruled that PJM must rebill parties to reverse incorrect cost assignments of Form 715 transmission projects. The costs, which had been allocated 100% to the zone of the host transmission owner, have been spread more widely, reflecting the projects’ regional benefits. (See FERC Stands Firm on Form 715 Assessments.)

PJM found 44 projects impacted by the order, including 33 in the PSEG zone and 11 in the Dominion zone.

Dominion Energy will collect almost $28.5 million in refunds from two dozen other transmission zones, led by American Electric Power and Commonwealth Edison, which will be billed more than $4 million each, according to an estimate posted by PJM on May 27.

Public Service Electric and Gas is owed $53.2 million from five companies, led by Linden VFT ($19 million), Neptune ($15.2 million) and Consolidated Edison ($13.2 million). PJM cautioned that the revised cost assignments could change based on FERC rulings or additional review by the RTO.

In the second order, FERC ruled that two merchant transmission operators in New Jersey are still liable for some cost allocations under PJM’s Regional Transmission Expansion Plan (RTEP) despite converting from firm to non-firm service after the cancellation of the Con Ed-PSEG “wheel” in 2017 (ER18-680). (See FERC Rejects Cost Formula for NJ Merchant Tx.)

Linden and Hudson Transmission Partners (HTP) own merchant transmission facilities that carried power into New York City as part of the wheel, in which 1,000 MW were exported from upstate New York to PJM through PSE&G facilities in northern New Jersey, and then exported to the city. Con Ed and PSE&G canceled the agreement in April 2017, prompting HTP and Linden to convert their firm transmission withdrawal rights (TWRs) to non-firm TWRs.

HTP would be billed $24.1 million and Linden $5.7 million under PJM’s resettlement estimate. PSE&G is the biggest beneficiary, due $22.9 million.

Linden, Long Island Power Authority, Neptune and the New York Power Authority (NYPA) made requests for a rehearing to FERC, Fernandez said. Linden and NYPA also requested settlement relief if FERC does not grant a rehearing request by delaying billing until January 2021 and to allow for a 12-month settlement period in equal installments from Jan. 1, 2021, through Dec. 31, 2021.

NEPOOL Participants Committee Briefs: June 4, 2020

ISO-NE’s energy transactions rang in at $159 million in April, the lowest monthly total since 2003, as the COVID-19 pandemic and ensuing shutdown of most economic activity continued to weigh on New England’s energy market.

NEPOOL
Data through May 27 indicate the full month will likely surpass April’s record for the lowest energy market value in New England since 2003. | ISO-NE

“I wouldn’t be surprised if May breaks April’s record in terms of the lowest energy market value over the last 17 years,” COO Vamsi Chadalavada reported to the New England Power Pool Participants Committee on Thursday. His report covered data through May 27, which showed a month-to-date energy market value of about $120 million.

[Note: Although NEPOOL rules prohibit quoting speakers at meetings, those quoted in this article approved their remarks afterward to clarify their presentations.]

May 2020 natural gas prices over the period were 16% lower than April average values and down 41% from a year ago. Average real-time hub LMPs ($16.39/MWh) were 9.4% lower than April averages and down 28% from May 2019 averages.

The RTO still has approximately 95% of its workforce working remotely and will continue that “remote deployment posture” until June 15, when it expects to start its re-entry plan, Chadalavada said.

“We are comfortable that we are compliant with the guidelines issued by [the Centers for Disease Control and Prevention], the states of Massachusetts and Connecticut, and also the local authorities,” he said.

Boston RFP and System Disturbances

ISO-NE’s competitive transmission solicitation for Boston garnered 36 proposals from eight qualified parties by the March 4 deadline, Chadalavada said, adding that the RTO would present a draft list of qualifying Phase One proposals at the June 17 Planning Advisory Committee meeting. (See “Faster Boston RFP,” National Grid, Eversource Finalist for Boston Tx Plan.)

A markedly quiet month in terms of operations turned less so in the last week of May with system disturbances on May 27 and 29, Chadalavada said.

On May 27 at 2:48 p.m., the system experienced the loss of the Phase II transmission line to a lightning strike, resulting in the loss of 1,980 MW, “a fairly severe source loss, given the size of New England,” he said.

NEPOOL
Real-time LMPs (blue line) spiked May 29 when a control rod malfunction at the Seabrook nuclear plant in New Hampshire took 1,340 MW off the grid. Day-ahead prices are shown in orange. | ISO-NE

May 29 brought two events, Chadalavada said: “We lost a major generation facility at [2:04 p.m.], which was about 1,250 MW, and later that evening, we lost the first pole at Phase II at 8:23 p.m. and the second one at 8:34 that night, again due to equipment failure.”

According to a report from New Hampshire Public Radio, the evening event stemmed from a control rod malfunction at the Seabrook nuclear plant, with the subsequent scram taking 1,340 MW off the grid.

The total loss was about 2,600 MW, “so on a 14,000- to 15,000-MW load, that translates to north of 20% of energy loss that had to be replenished,” Chadalavada said.

All transmission and disturbance control standard criteria were met and maintained during and after the events, he said.

Virus Reduces RTO Spending

The financial impact of the COVID-19 pandemic will likely translate into net savings in ISO-NE’s 2020 budget, said Chief Financial and Compliance Officer Robert Ludlow in presenting the preliminary 2021 and 2022 operating and capital budgets.

Committed COVID-19 spending totals $730,000, with current projected possible risks of an additional $300,000, but offsetting those increased costs are $800,000 in planned costs that will not be incurred in 2020. Those savings are primarily derived from suspended travel and training and the limited hiring of interns this year.

ISO-NE Tariff collections for January through April were lower by 5.7% (or $3.6 million), reflecting decreased load, which is estimated to be 3 to 5% lower because of the pandemic.

The 2021 and 2022 budgets’ year-over-year increases before depreciation are projected to be $4.8 million (2.7%) and $6.3 million (3.5%), respectively.

The proposed budgets will be presented in August with a detailed review of project budgets and estimated go-live dates.

Order 1000 Questions on Tx Planning

The PC approved changes to Planning Procedure 10 (PP10) to provide implementation details for the alignment of reliability reviews of delist bids with the competitive transmission solution process, as recommended by the Reliability Committee in May. (See “Changes to PP10 for Tx Solution,” NEPOOL Reliability Committee Briefs: May 19, 2020.)

The motion passed with 99.12% in favor.

Exelon argued in a presentation that ISO-NE is abandoning planning principles for expediency and thereby risking reliability.

“The proposed amendment to Planning Procedure 10 appears to be a result-driven attempt to preclude the potential retention of Mystic 8 and 9 for transmission security; the amendment and its attendant consequences, however, will live long after Mystic 8 and 9 have retired,” Exelon said in its presentation. (See Exelon Bid to Keep Mystic Units Running Provokes Outrage.)

“A significant amount of information is provided to the ISO early in the solicitation process, including information necessary for the ISO to determine whether the reliability need can be satisfied with the proposal,” said ISO-NE Director of Transmission Services and Resource Qualification Al McBride.

The changes are intended to prevent unnecessarily retaining a resource for reliability if transmission responses in the competitive solicitation process address the reliability need, McBride said.

Consent Agenda

The PC on its consent agenda approved a revision to Operating Procedure 12 (OP-12) related to voltage and reactive control, as recommended by the RC in May.

The changes:

  • reflect the source of the data in OP-12B (voltage and reactive schedules);
  • explain the different categories of voltage control for generators;
  • clarify the use of “On Peak Period” and “Off Peak Period”;
  • add that OP-12B would be updated “as needed”; and
  • specify that ISO-NE may request technical status for certain units that have operational impact.

The committee also approved revisions to Market Rule 1 and Manual M-11 to modify the day-ahead energy market offer window, as well as clean-up changes to the offer cap, as recommended by the Markets Committee last month.

The submission deadline for day-ahead offers and bids moves from 10 to 10:30 a.m.; the offer cap filing revisions were approved by FERC (ER17-1565).

The PC also voted to approve a FERC filing to address rejected portions of ISO-NE’s Order 845 compliance filing (ER19-1951), as recommended by the Transmission Committee in May following the commission’s May 19 rejection of the RTO’s request for clarification on the issue. (See NEPOOL Transmission Committee Briefs: May 27, 2020.) The commission issued Order 845 in 2018 to set pro forma minimum standards for large generator interconnection procedures and agreements.

The PC deferred voting on major changes to the RTO’s billing policy until fall, with some related clean-up changes to the ISO-NE Financial Assurance Policy to be voted sooner at the virtual summer meeting June 23.

The committee also considered in executive session and unanimously approved — with some abstentions — ISO-NE Tariff revisions to carry out the settlement agreed to among New England Transmission Owners (NETOs), FERC staff and municipally owned power companies on pool transmission formula rates (EL16-19).

Litigation Report

The monthly litigation report mentioned that FERC will hold a technical conference July 8-9 to explore the potential longer-term impacts of the emergency conditions caused by COVID-19 on FERC-jurisdictional entities (AD20-17).

In addition, the commission issued a supplemental notice waiving through Sept. 1 its regulations that require filings with FERC be notarized or supported by sworn declarations (AD20-11).

Another item noted that FERC in May approved a procedure for “critical” New England generators and transmission operators to obtain compensation for compliance with NERC rules regarding interconnection-reliability operating limits (IROL) (ER20-739). (See FERC OKs Payment Rules for IROL Facilities.)

“Regarding the IROL, we were disappointed to see that,” said Brett Kruse of Calpine. “We do think ISO New England in this case acted in good faith, and we appreciate what they tried to do. This has ramifications. The next time the ISO comes to us and says, ‘We need you to start spending money on x, y or z because it’s a reliability issue,’ the first thing we’re going to have to think about, instead of going out and immediately doing it like we did this time, is go get it in front of FERC and get them to approve it. If that takes two and a half years, as it did in this case, well that’s what it takes.”

In addition, the litigation report noted that several market participants and state entities had filed comments and protests on the separate Energy Security Improvements filings submitted by ISO-NE and NEPOOL (ER20-1567). (See ISO-NE Sending 2 Energy Security Plans to FERC.)

IBR Models Remain Persistent Challenge, Task Force Warns

The lack of reliable modeling and simulation resources for inverter-based resources (IBRs) continues to pose a serious challenge for reliable operation of the North American electric grid, members of NERC’s Inverter-based Resource Performance Task Force (IRPTF) warned in a webinar on Monday.

Presenting a recent report on a questionnaire following up on two NERC Alerts issued after the 2016 Blue Cut and 2017 Canyon 2 fires, Ryan Quint — NERC’s lead engineer for advanced system analytics and modeling — said that many generator owners (GOs) and transmission planners had yet to fully act on NERC recommendations regarding modeling of solar photovoltaic resources to prevent momentary cessation (MC). Both incidents resulted in considerable shortfalls in solar PV generation: 1,200 MW of generation for Blue Cut and 900 MW for Canyon 2.

NERC
CAISO’s modeling improvement process. | NERC

In particular, the alert following the Canyon 2 fire recommended that GOs ensure that the dynamic models being used accurately represent the dynamic performance of the solar facilities and work with inverter manufacturers to identify changes that could help eliminate or reduce MC as much as possible. In the follow-up questionnaire, transmission planners and planning coordinators complained that GOs had failed to follow through on this advice.

“Many of the TPs and PCs stated that no models were provided or that minimal modeling improvements were provided,” said Quint. “But really the biggest issue was that the models that were provided … were incorrectly parameterized [or] not considered usable … They weren’t matching the list of acceptable models defined by the TP or the PC, or in some cases they were just the wrong model entirely.”

System planners were not blameless either, as most reported making little effort to follow up on missing or incorrect modeling information. While the report did not attribute a specific cause to this lack of action, one likely reason was the failure of the NERC alert to provide a mechanism for doing so, which left PCs and TPs unsure about their responsibilities, IRPTF staff said. Indeed, those planners that followed up with GOs did so largely “outside the NERC Alert process,” according to the report.

CAISO Modeling Updates Challenged

To illustrate the challenges in obtaining accurate modeling information, IRPTF highlighted the model update process implemented by CAISO in 2018. The ISO created the process in response to the Canyon 2 NERC Alert, with all generator owners participating in the CAISO market required to follow a five-step process:

  • CAISO and participating transmission owners create a package for each GO to gather updated modeling data.
  • GOs collect the necessary modeling information and provide it to CAISO within 120 days of receiving the request.
  • CAISO and its TOs review the data to ensure acceptable performance, sending feedback to the GO within 90 days.
  • GOs have 60 days to address any deficiencies identified.
  • GOs resubmit modeling data for a second 90-day review by CAISO and TOs.

As of Sept. 25, 2019, CAISO had received updated models accounting for 109 resources with nearly 14 GW of capacity. Of the models provided, 101 had been reviewed at the time of the report’s publication, with 95 identified as deficient. Of those, just 10 have been resubmitted with proposed corrections.

A lack of accurate models could have serious consequences for the ability of system planners to understand the behavior of connected generators under stress, but the IRPTF says their ability and inclination to push generator owners for better information may be limited by the current state of NERC reliability standards. Staff said these may need to be updated to provide the impetus needed by industry operators on both sides.

“With a synchronous machine, it’s a little more straightforward on how these models work … It’s really physics,” Quint said. “These new inverter-based resource models are much more complicated and there’s a lot of nuance. It’s hard to parameterize these models and it really requires expert input, so there’s a huge accountability issue here on who’s going to take responsibility for making sure these models get updated.”

COVID Complicates Western Firefighting Efforts

A U.S. Senate hearing Tuesday addressed the issue of fighting wildfires in the midst of the coronavirus pandemic, a widespread concern in the West this year, including in California, where utility-sparked wildfires and public safety power shutoffs wreaked havoc in years before the virus spread.

covid fire season
Sen. Lisa Murkowski chaired Tuesday’s hearing. | U.S. Senate

“This summer fire season is shaping up to be as severe as any,” said Sen. Lisa Murkowski (R-Alaska), chair of the Senate’s Energy and Natural Resources Committee. “As fire activity increases, we can expect over 20,000 firefighters to be mobilized by the [U.S.] Forest Service, Interior [Department] and their state, tribal, local and volunteer cooperators.

“At a moment’s notice, fire personnel will be traveling by airplane and vehicle across state borders,” Murkowski said. “Large concentrations of firefighters, support specialists and private service contractors will be assigned to incident command posts — fire camps — where they will eat, rest and stage equipment and supplies. What was operationally routine before may be exactly the kinds of activities that now risk spreading the coronavirus around the fire services.”

The hearing took place in a sparsely populated meeting room where Senate staff members wore masks and kept their distance from each other, and panelists testified by video.

John Phipps, the deputy chief for state and private forestry at the U.S. Forest Service, outlined steps being taken to combat fires while keeping firefighters from spreading infection. He said this summer is expected to be an especially bad wildfire season, requiring new approaches, including an increase in the number of firefighting aircraft.

“Based on long-term weather forecasts and expected dry conditions, 2020 is projected to be a higher-than-average year for wildland fire,” Phipps said. “Aggressive initial attack, supported by airtankers and helicopters, will be used wherever possible to extinguish wildfires quickly and minimize the need to bring large numbers of firefighters together.”

Firefighters will work in small units rather than gathering in large fire camps, he said, and will be screened for COVID-19 symptoms.

“Consistent and continual monitoring of personnel will be a crucial step in preventing the movement of potentially infected individuals and the spread of COVID-19,” Phipps said. “A ‘module as one’ approach is being used for crews and modules to insulate as one unit and reduce exposure to the public and other crews.”

Amanda Kaster, acting deputy assistant secretary for land and minerals management at the U.S. Department of the Interior, said Bureau of Land Management firefighters will work as “family units to protect people, property and themselves.”

With a lower-than-average snowpack in the mountains and faster-than-average snowmelt, Northern California and parts of Oregon face a heightened fire potential, she said.

Fire Season Arrives Early

Already this year, the BLM has sent smokejumpers to Colorado, Nevada and Utah in response to wildfires, Kaster said. Firefighters in New Mexico and Arizona have responded to several incidents, and crews from Montana were sent to Arizona twice, including to national forest land.

covid fire season
The Sprague Fire burned through Glacier National Park in September 2017. | National Park Service

“So far in 2020, we are seeing increased levels of wildfire activity in the Great Basin, [Southwestern] and Rocky Mountain geographic areas,” Kaster said. “Based on the most recent seasonal outlook compiled by the National Interagency Fire Center’s Predictive Services Program, we can expect potential for above-normal fire activity in 2020.”

Norm McDonald, director of fire and aviation for the Alaska Division of Forestry, testified remotely from Alaska, where it was 6 a.m. He said Alaskans are concerned about firefighters coming from out-of-state and traveling to small remote communities to fight fires and potentially spreading the coronavirus.

“In Alaska, all incoming personnel are being asked to take a COVID-19 test upon arrival,” McDonald said. “Testing occurs at either of the two major jetports upon arrival, and results are available in 24 to 48 hours. The incoming staff are asked to quarantine at their billets until test results are provided.

“This service will also assist with any COVID-19 cases in the fire ranks and will transport, care for, isolate, house and feed any firefighters that come down with COVID-19 while on assignment in Alaska,” he said. “This is a unique arrangement, but it will help to allow teams to stay focused on what they know best, fighting fire, while third-party medical units care for staff infected with COVID-19.”

Menezes Nomination Clears Senate Panel

The Senate Energy and Natural Resources Committee Tuesday approved Energy Under Secretary Mark Menezes’ nomination as deputy secretary.

menezes

Energy Under Secretary Mark Menezes | © RTO Insider

Menezes, a former utility lobbyist, was approved on a voice vote, with Nevada Democrat Catherine Cortez Masto casting the lone vote in opposition.

President Trump nominated Menezes to the Department of Energy’s Number 2 post to replace Dan Brouillette, who was named secretary after the resignation of Rick Perry in December.

At his confirmation hearing on May 20, Cortez Masto pressed Menezes to clarify comments he made during a House Energy Subcommittee hearing in February in which he indicated the Trump administration was pursuing Nevada’s Yucca Mountain as a permanent nuclear storage site. That contradicted the White House’s proposed 2021 fiscal budget, which included no money for development of the site, 100 miles northwest of Las Vegas.

“The president has been very clear on this. The administration will not be pursuing Yucca Mountain as a solution for nuclear waste,” Menezes testified, without explanation for his earlier remarks. “And I’m fully supportive of the president’s decision and I applaud him for taking action when so many others failed to do so.”

Cortez Masto opposed Yucca’s selection and is co-sponsor of the Nuclear Waste Informed Consent Act, which would ensure states, local governments and tribal communities have a voice in any nuclear waste siting process, including interim storage.

Menezes said the administration had not taken a position on the senator’s legislation. “However, we do know that the solution for nuclear storage will rest with Congress and we do pledge to work with you,” he said.

Testing Concerns

In a statement Tuesday, Cortez Masto said that while she “appreciated [Menezes’] clarification of the administration’s position that it will no longer pursue Yucca Mountain as the nation’s permanent nuclear waste disposal site,” she voted no because of recent reports suggesting the administration is considering resuming explosive nuclear testing.

The senator noted that Nevada was the site of more than 900 atmospheric and underground nuclear tests between 1945 and 1992, when the federal government developed a plan to ensure nuclear weapon readiness without explosive testing.

“Annually, the safety, reliability and effectiveness of the nation’s nuclear stockpile has been certified by the directors of the Los Alamos, Sandia and Lawrence Livermore National Laboratories, along with the secretaries of Defense and Energy,” she said. “Yet, reports are suggesting that this administration is prepared to jeopardize the health and safety of Nevadans, undercut our nation’s nuclear nonproliferation goals and further weaken strategic partnerships with our global allies just to flex its muscles on the global stage.

“There has been a changing tide in the administration on Yucca Mountain, and I believe Secretary Brouillette has played an important role in improving our communications with the department, but these recent events only suggest that the department still has work to do to earn back the trust of Nevadans,” said Cortez Masto.

Senate Floor Vote

Committee Chair Lisa Murkowski (R-Alaska) began the committee meeting by praising Menezes as “well qualified” for the deputy’s post, noting his prior work on Capitol Hill and his prior Senate confirmation. “I’m hopeful that Mr. Menezes will again draw strong bipartisan support and that we’ll be able to confirm him quickly once his nomination reaches the Senate floor,” she said.

menezes

The Senate Energy and Natural Resources Committee approved Mark Menezes’ nomination as deputy Energy secretary.

Confirmed as Under Secretary in 2017, Menezes previously worked in the Washington office of Berkshire Hathaway Energy. He also is a former partner at Hunton & Williams, where he headed the Regulated Markets and Energy Infrastructure practice group, and former chief counsel for energy and environment for the House Energy and Commerce Committee.

Before coming to Washington, he was a vice president with Central and South West. After its merger with American Electric Power, he was AEP’s associate general counsel for federal and state legislative and regulatory affairs.

 

PJM Operating Committee Briefs: June 4, 2020

PJM presented the Operating Committee with proposed rule changes concerning the testing, compensation, substitution and termination of black start resources Thursday.

Most of the changes involve additions to Schedule 6A of the Tariff and section 4.6 of Manual 12, said PJM’s Becky Davis, who walked stakeholders through a matrix of revisions. She said redline versions of the Tariff and manual language will be available for review by the OC’s July 9 meeting.

The committee approved an issue charge for the initiative at its May meeting. (See “Black Start Issue Charge Endorsed,” PJM Operating Committee Briefs: May 14, 2020.)

The problem statement focuses on four areas:

  • Making units that entered black start service through a transmission owner integration subject to the same testing requirements as those compensated under Schedule 6A: a successful test every 13 months.
  • Clarifying rules for substituting one black start unit for another. Current rules allow a black start unit owner to substitute one unit for another if the substitute is on the same voltage level and has a valid annual test. PJM said it is responding to an increase in questions about adding, maintaining and managing black start substitutes. The proposed rules would require 40 days’ notice for substitution requests.
  • Adding language allowing PJM to replace black start units that fail or do not perform tests without lengthy delays.
  • Allowing updates to the capital recovery factor table governing compensation for black start capital costs to remain consistent with current tax law and interest rates.

PJM attorney Steve Pincus said the RTO is not concerned over potential conflicts between its rules and black start units covered by “legacy” agreements with TOs.

Pincus said PJM would look at the agreements on a case-by-case basis to resolve any potential conflict, noting there are only a “handful” of agreements that fall into that category. He said the PJM testing rules are likely more stringent than those in the legacy agreements but that if an agreement with TOs was more demanding than PJM’s, “I’m confident we would not have a Tariff [violation] issue.”

If necessary, Pincus said PJM would seek a Tariff waiver from FERC to address any inconsistencies.

In addition to the four topics in the problem statement, the OC also will consider how to compensate black start owners for their fuel costs under the minimum tank suction level (MTSL) rules. The Markets and Reliability Committee approved the expansion of the initiative to cover MTSL on May 28. (See “Fuel Requirement Issue Charge,” PJM MRC Briefs: May 28, 2020.)

Dispatch Interactive Map Application

Ed Kovler of PJM conducted a first read of a proposed problem statement and issue charge to consider giving TOs access to the Dispatch Interactive Map Application (DIMA), a geospatial situational awareness tool that the RTO’s dispatchers have used since 2014.

PJM and several TOs brought forward draft language for the Operating Agreement to be endorsed through the “quick fix” process documented in Manual 34. The OC will vote on the issue charge at its July 9 meeting.

DIMA allows operators to see the location of problems on the grid in real time and respond quickly.

PJM
DIMA geospatial overview | PJM

Kovler said DIMA has been a “paradigm shift” for PJM dispatchers, moving away from old tabular displays that most operation centers have to a geospatial display that helps them better understand the relationship of equipment.

TOs have requested read-only access to DIMA to improve their own operators’ situational awareness, Kovler said.

PJM plans to present the DIMA issue charge at the July and August MRC meetings and the September Members Committee meeting. If endorsed, the OA changes will be sent to FERC in September for review.

Kovler said PJM expects FERC to act in about 60 days and that the RTO will begin implementing the increased access “almost immediately” afterward.

“There’s a lot of IT work that needs to be done,” Kovler said, estimating it could take more than five months to complete. A “phased rollout” could take several months more to complete, he said.

Analyst: Texas ROFR Bill Likely to Survive

A Texas law giving incumbent transmission companies the right of first refusal to build new power lines in the state will likely survive another round of judicial review, according to one energy analyst.

The 5th U.S. Circuit Court of Appeals last week heard oral arguments in NextEra Energy’s effort to repeal the 2019 law but is not expected to rule on the matter for several months (20-50160).

NextEra Energy Capital Holdings, on behalf of four other NextEra transmission owner/developer entities, appealed a U.S. district court’s February decision to not overturn Texas Senate Bill 1938. (See NextEra Appeals Court Decision on Texas ROFR Law.)

Texas ROFR
The 5th Circuit Court of Appeals in New Orleans is weighing NextEra’s appeal of Texas’ right-of-first-refusal legislation. | 5th U.S. Circuit Court of Appeals

The law essentially allows only incumbent transmission companies to build new power lines in Texas by granting regulatory certificates of convenience and necessity to the owners of the endpoints of a new transmission line. NextEra has alleged the law imposes burdens on interstate commerce by restricting entry into Texas’ transmission market, “outweighing any local benefits.”

ClearView Energy Partners, a D.C.-based independent energy policy research firm, said in a letter to its clients that it believes oral arguments during the June 1 hearing provide SB 1938’s proponents a reason to be optimistic.

Texas ROFR
Judge Jennifer Elrod | Ballotpedia

The firm said Judge Jennifer Elrod appeared “skeptical” of NextEra’s standing and the “ripeness of the appeal.” Judge Gregg Costa “appeared at times to share” that view, it said.

“Judge Costa, however, did offer the view that Texas was not just establishing a right of first refusal … akin to a Minnesota law recently upheld by the 8th Circuit, but rather an outright ban,” the firm said.

Costa was referring to a similar case in Minnesota before the 8th U.S. Circuit Court of Appeals. (See Justice Dept. Joins Challenge to Minn. ROFR Law and Courts Uphold Minn. ROFR, MISO Cost Allocation.)

ClearView also said it considers the upcoming decision to be a “potential indicator of whether other states may see low judicial risk if they consider similar laws.”

Texas ROFR
Judge Gregg Costa | Appellate Academy

“The 5th Circuit’s ruling could provide additional clarity of how the courts are interpreting the limits the dormant Commerce Clause imposes on states that create in-state preferences or requirements, an issue that has raised judicial risk in the past for state renewable power mandates,” the firm said.

NextEra is appealing the decision because it says NextEra Energy Transmission (NEET) Midwest could lose its “lawfully won right” to build the $115 million Hartburg-Sabine Junction transmission project in MISO’s East Texas footprint. It says SB 1938 “substantially impaired” NextEra’s reasonable contractual expectation to obtain a CCN from the Texas Public Utility Commission, as required by NEET Midwest’s agreement with MISO.

NEET Midwest won the project’s rights in 2018 through a competitive bidding process. (See NextEra Wins Bid to Build MISO’s 2nd Competitive Project.)

The legislation also affects NEET Southwest’s application with the PUC, the appeal’s defendants, to transfer ownership of 30 miles of 138-kV facilities from Rayburn Country Electric Cooperative in SPP’s region of East Texas.

PMU Vote Delayed by PJM

PJM’s Planning Committee postponed a vote by one month on “quick-fix” manual revisions to implement the RTO’s plans to expand the use of synchrophasors and make them a requirement for certain projects under the Regional Transmission Expansion Plan (RTEP).

Stakeholders were scheduled to vote on the issue charge and endorse the proposed manual language at the June 2 PC meeting to require synchrophasors — also known as phasor measurement units (PMUs) — in all new substations and major construction projects to monitor bus voltage and line flows.

Some members said they were concerned about using the quick-fix process to endorse the changes and questioned PJM staff about missing Tariff language in the proposal.

Dave Souder, PJM’s senior director of system planning, said the PMU expansion will improve reliability and give operations staff the tools they need for the increasingly dynamic monitoring needs of the grid. Souder said he recognized some stakeholders may have issues with the quick-fix method, so he requested that members express their concerns about the proposed manual language in advance of the July PC meeting.

“I really don’t want to force a quick-fix solution down the stakeholders’ throats,” Souder said.

PJM PMU
Types of projects under the PMU Placement Strategy | PJM

Shaun Murphy of PJM reviewed the PMU problem statement, issue charge and proposed solution at the meeting. In his presentation, Murphy said language is being proposed for section 1.4.1.3 of Manual 14B to add a PMU Placement Strategy (PPS) to identify the synchrophasor device coverage needed to support the RTO’s real-time synchrophasor applications. The PPS, which includes placement targets and required operational dates, would make mandatory a program that is currently voluntary.

Murphy said instituting the PPS would close the gap between research and real-time control room use and improve data reliability and oscillation detection. (See Oscillation Event Points to Need for Better Diagnostics.)

Making each substation “PMU ready” costs as much as $120,000, he said, and each substation would have two or three PMUs that cost about $10,000 each. As many as 889 projects could be created over a 12-year span if a voltage threshold of 100 kV for each unit is accepted, according to PJM. The PMU requirement would be effective for projects presented to the Transmission Expansion Advisory Committee after June 1, 2021.

Murphy said about 80 PMUs will be added each year at a cost of about $8 million annually.

PJM PMU
PJM identified nearly 900 possible projects under its proposed PMU Placement Strategy. | PJM

Tom Hyzinski of GT Power Group said the yearly price tag seemed reasonable compared to the value of the information that could identify costly problems on the system. Hyzinski asked if there was any discussion by PJM on ways the cost could be allocated across stakeholders so that no one would be greatly impacted by the expense.

Souder said PJM was open to discussing cost allocation among stakeholders, but he said the RTO felt PMUs have to be expanded across the system to be effective. Souder said the technology would be required for both baseline and supplemental projects to spread the technology.

Dave Mabry of the PJM Industrial Customer Coalition (ICC) said he was thankful for the educational session PJM held on May 26 on PMUs and their benefits to the system. He asked if there were any Tariff changes considered in the PJM proposal, noting that the Tariff makes references to PMUs in generation interconnection.

Souder said PJM’s legal review concluded the manual language was sufficient.

| PJM

Mabry said the ICC opposed using the quick-fix solution and thinks the issue would benefit from further consideration by stakeholders regarding the implementation strategy and cost allocation. He said the education session convinced the ICC to support the problem statement but that the group still has reservations about the PJM proposed solution and is concerned that it will increase the justification of supplemental projects, which are reserved for incumbent transmission owners and not subject to competitive bidding.

“We don’t want to implicitly approve supplemental projects we have questions about,” he said. “Our concern is whether PMUs are going to become a nexus for trying to justify supplemental projects.”

Souder said he understood that stakeholders have concerns about supplemental projects but said if PJM only requires PMUs in baseline projects, it will limit the ability to propagate the technology across the system.

“It truly is a catch-22,” Souder said. “We need the data across the systems so we can fully utilize the tools.”