November 14, 2024

OGE Beats Expectations with Q3 Earnings

By Tom Kleckner

OGE Energy beat expectations last week, reporting third-quarter earnings of $205 million ($1.02/share), up from a year ago, when it earned $183 million ($0.92/share).

A Zacks Investment Research survey of analysts had projected earnings of 96 cents/share.

“Good companies grow, and that is clearly what we are doing,” CEO Sean Trauschke said during a Nov. 8 conference call with analysts.

OGE’s regulated utility, Oklahoma Gas & Electric, contributed 92 cents/share during the quarter, thanks to new rates in Oklahoma, favorable weather and increased customer demand.

OG&E crews at work | OGE Energy

The Oklahoma City company also received earnings of 14 cents/share from Enable Midstream Partners, a gas-gathering and processing joint venture with Texas utility CenterPoint Energy.

Enable said Nov. 7 that it processed record amounts of natural gas during the third quarter. OGE holds a 25.7% limited-partnership interest and a 50% management interest in Enable, while CenterPoint owns a 54.1% share.

OGE increased and narrowed its year-end guidance to $1.59 to $1.61/share, up from $1.43 to 1.53/share.

OGE shares finished the week at $38.08/share, up almost 16% since the beginning of the year.

CenterPoint Earnings Drop 4 Cents

CenterPoint reported third-quarter earnings on Nov. 7 of $153 million ($0.35/share), a drop from a year earlier, when it earned $169 million ($0.39/share).

Revenues totaled $2.2 billion, up from $2.1 billion a year ago, thanks to increased rates and a growing customer base.

CenterPoint Energy
CenterPoint Energy EV | CenterPoint Energy

CEO Scott Prochazka told analysts during a conference call that the Houston-based company in October completed the equity and fixed rate debt components of the financing for its $6 billion acquisition of Indiana utility Vectren. Prochazka said the acquisition is still expected to close in the first quarter of 2019 and has targets in place “that are in line” with an $50 million to $100 million in pretax earnings by 2020.

CenterPoint’s share price lost 51 cents following the earnings announcement, finishing the week at $28.16.

New England Talks Energy Security, Public Policy

By Michael Kuser

MARLBOUROUGH, Mass. — Can New England balance reliability, economics and public policy in a fast-changing energy world? How will the region better prepare itself to handle winter cold snaps than in the past?

These and other questions arose at the Northeast Energy and Commerce Association’s 17th Power Markets Conference on Nov. 8. Here are highlights of what we heard.

NECA
The Northeast Energy and Commerce Association held its 17th annual Power Markets Conference on Nov. 8. | © RTO Insider

Internalize, Don’t Politicize

NECA
Ashley Brown | © RTO Insider

Ashley Brown, executive director of Harvard University’s Electricity Policy Group, said, “My fear today is that we’re moving back to a battle between various special interest groups and further politicizing the sector.”

Resource selection based on economics, reliability and social benefits has given way to state subsidies and mandates that often work against public policy environmental goals, with uneconomic resources chasing bailouts instead of focusing on how to become more efficient, he said.

“Part of the problem … is that we have simply failed to internalize social considerations in economics,” Brown said. “The lack of a carbon policy in the U.S. is not only intellectually bankrupt, but it does in fact penalize emissions-free resources.”

Energy Security Banking

Mark Karl | © RTO Insider

Mark Karl, ISO-NE vice president for market development, said the region is moving into an era in which more resources have less fuel security. The grid operator is concerned the situation will get worse.

Fuel logistics become an issue in winter, whether because of natural gas pipeline constraints, limited dual-fuel storage or reduced ability to deliver oil by truck, he said. The significant retirement of large non-gas-fired generation is an important factor, as is the type of oil used.

“For example, some generators are burning No. 6 oil, which is basically almost asphalt, so in the wintertime, when that stuff gets cold, it gets pretty difficult to pump and move,” Karl said.

The retirement of two nuclear plants and the Brayton Point coal plant in recent years might be good for the environment, but collectively it presents a challenge for reliability, he said.

Karl said ISO-NE is looking to create a new reserve service referred to as “the energy inventory reserve constraint.”

“We’re proposing to incorporate into the real-time market an additional constraint that looks at the ability to provide energy storage or an energy bank,” he said. “I want to be careful here because it’s easy to think about this from the standpoint of conventional generator fuel, but this will apply to any sort of resource that has the ability to maintain essentially a reserve bank of energy that can be converted into electricity when needed.”

The idea is to optimize the use of limited energy over more extended periods compared with how markets are currently designed to optimize energy over the course of an operating day, he said.

Outside the marketplace, operators also worry about the next day and the days that follow, and sometimes order an oil-burning unit offline for a weekend anticipating the need to provide reserves come Monday, “so that’s an out-of-market action that does cause distortions in the marketplace,” Karl said.

Market Reaction

Brett Kruse | © RTO Insider

Brett Kruse, vice president of market design at Calpine, said ISO-NE could use a six- or seven-day-ahead market to effectively manage storage in a way that avoids having to take out-of-the-market actions.

The proposal could help the RTO manage how it deploys plants day to day and provide an insurance policy to keep a certain amount of storage in the system, he said.

“There are a lot of questions about that and how it would be priced, but it’s conceptually a pretty good idea,” Kruse said.

But he also had some reservations about the plan. “Looking at the way they’re presenting it now, where it’s a voluntary forward market, and won’t have any mitigation, which is a key aspect to go with that, we think it has some potential, although it’s hard to see how a lot of load will come into that,” he said.

NECA
NECA energy security panel (left to right): Abigail Krich, Boreas Renewables; David Cavanaugh, Energy New England; Brett Kruse, Calpine; and Matthew Picardi, Shell Energy. | © RTO Insider

David Cavanaugh | © RTO Insider

David Cavanaugh, vice president of regulatory and market affairs for Energy New England, an energy services firm, said the RTO’s thinking at first glance seems robust, as its design extends beyond the winter period into a period where the bulk power system has more renewables and, perhaps, storage resources.

“I’m not sure the sophistication of this model gets us there … but we can be informed by other interim efforts such as the opportunity cost model set for use this winter,” Cavanaugh said. “I think the design is well thought out … just have some concerns when I look at the multi-day-ahead market, its voluntary participation,” in terms of maintaining adequate fuel stocks.

Abigail Krich | © RTO Insider

Abigail Krich, president of Boreas Renewables, said she sees a market design that, “even though it was triggered by fossil fuel issues, could work with that transition to a clean energy system that relies on intermittent generation. It looks like something that makes sure we have a dispatchable store of available energy in reserve.”

“I question whether we need all of these pieces in the proposal or whether we might just use some of them,” Krich said.

Public Policies

Discussing the race for renewables at the state level, Peter Fuller of Autumn Lane Energy Consulting said the tension in these markets is understandable. While consumers have benefited greatly from the markets, and investors and market participants have an expectation that everyone in the market will play by the same set of rules, states pursuing policy objectives don’t necessarily feel bound by those rules. In addition, the states have not been able, individually or collectively, to identify exactly what they want in a way that an RTO can create a market for it, he said.

Peter Fuller | © RTO Insider

Rather, states want to maintain control of resource decisions as policy objectives continue to evolve over time. “As much as anything they want to control that,” Fuller said. “If I’m a governor or legislator thinking how I want to transform the energy system in my state, my first instinct is not to send somebody to [the New England Power Pool] or to PJM to offer proposals, to come up with a matrix or a set of market rules and see how that plays out.” States are more likely to take direct action that then can cause dislocations in the markets.

Day Pitney attorney Sebastian Lombardi, who serves as counsel to NEPOOL, said that overlaying all the fuel security and grid resilience efforts is the need for regions to continue to engage in efforts to help bridge the divide between evolving state and federal policies and the market.

Sebastian Lombardi | © RTO Insider

“From a state policy perspective, the competitive markets are not always achieving what they’d like the markets to achieve,” Lombardi said.

Darlene Phillips, senior director for strategic policy and external affairs at PJM, explained the RTO’s proposed revamp of its capacity market.

The Extended Resource Carve-out proposal would allow specific, state-subsidized resources to opt out of the capacity market and PJM to adjust market clearing prices as if the resources were still in it. (See related story, PJM Stakeholders Hold Their Lines in Capacity Battle.)

Darlene Phillips | © RTO Insider

“If you don’t want your subsidized resources to get a minimum offer for price and go into the market, we will allow you to take those resources out of the market,” she said. “One of the things that FERC did not like about our original approach is that we actually paid those resources a payment.”

When it comes to existing renewable resources, PJM’s minimum offer price rule would have very little impact because the price would be zero, she said. The RTO applies a 20-MW threshold to renewables for the MOPR, which most of them don’t meet, though that situation might change with large-scale offshore wind coming along.

NERC to Try Again on Inverter Rules

By Rich Heidorn Jr.

ATLANTA — NERC stakeholders are expected to consider a new standard authorization request (SAR) to address inverter-based resources after the Standards Committee rejected two SARs proposed by CAISO in September, officials said last week.

CAISO submitted the SARs in May, saying it had recorded at least 14 occasions since August 2016 when inverter-based solar generation incorrectly tripped or ceased to operate during the routine high-speed clearing of short circuits on bulk electric system (BES) transmission. NERC has issued several reports and alerts following the two most serious incidents: the August 2016 Blue Cut wildfire, when 1,200 MW of solar disconnected; and the October 2017 Canyon 2 fire, which resulted in the loss of more than 900 MW. (See NERC Chief: Inverter, Fuel Assurance Standards Needed.)

Most solar PV generation (top map) is below the 75-MW threshold requiring registration with NERC (bottom map). | NERC

The ISO proposed incorporating performance requirements for inverter-based resources connected to the BES in a revised NERC standard PRC-024, or developing a new standard for such resources and clarifying that PRC-024 applies only to synchronous generation.

At its Sept. 13 meeting, however, the Standards Committee rejected both SARs by a 12-5 vote on a motion by Dominion Energy’s Sean Bodkin, who noted the Institute of Electrical and Electronics Engineers (IEEE) is addressing the issues in Standard 1547-2018.

James Merlo, NERC | © RTO Insider

NERC is working with IEEE on the standards for inverter settings and developing instructions on compliance monitoring and enforcement activities related to the issue, James Merlo, NERC vice president of reliability risk management, told the Member Representatives Committee (MRC) at its quarterly meeting Nov. 6.

FERC Commissioner Cheryl LaFleur, who attended the MRC and Board of Trustees meetings, said she was concerned about the rejection of the SARs, saying “nothing clarifies the mind like an enforceable standard.” She said it was better for NERC and its stakeholders to design standards rather than respond to directives from FERC.

NERC CEO Jim Robb said he was disappointed that the two SARs “met with such headwinds at the Standards Committee.”

“I think we need to get over the notion that any standard creates peril and get to the point where standards create certainty,” he said. “And I think, particularly, in the case of these inverter resources, that’s a very, very important thing for us to do. … These resources are not going away. They’re already at scale in the West, and they will [soon] be at scale … in many parts of the country.”

Merlo said the Operating and Planning committees and the Inverter-Based Resource Performance Task Force will seek a new SAR to modify PRC-024 that will build on a white paper to be released in about two weeks identifying gaps between current standards and what’s needed by grid operators. “The expectation is the Standards Committee would take that up in December,” Merlo said.

“I’m optimistic that that will accomplish much of what we wanted to accomplish through the original two SARs,” Robb said.

Howard Gugel, NERC | © RTO Insider

The work may not stop with revisions to PRC-024, said Howard Gugel, NERC senior director of engineering and standards. “Then that task force is also going to go forward to say, ‘given that this is a brave new world and we have these resources, is there another standard that we should write that says how they should actually operate?’” he said in an interview. “And it’s not just limited to solar. … [idle EVs injecting energy into the grid are] an inverter resource also.”

NERC has already asked solar generators to modify their inverter settings to ensure voltage excursions don’t result in momentary cessation (MC) — when they stop injecting current into the grid. For inverters that cannot use another ride-through mode, NERC asked that MC settings be reduced to the lowest voltage value possible and that the recovery delay be reduced to one to three electrical cycles.

In arguing for the SARs, CAISO’s Keith E. Casey, vice president of market and infrastructure development, noted that NERC guidelines are not enforceable.

“Due to a lack of any standard addressing the minimum performance of inverter-based generation connected to the BES, original equipment manufacturers often apply standards for resources connected to the distribution system to BES resources,” Casey wrote.

NERC reported that most of the lost solar generation in the Blue Cut fire resulted when inverters incorrectly perceived a low frequency condition and tripped, not returning to service for five minutes or longer. “Five minutes may make sense on a rooftop, but five minutes is an eternity on the bulk electric system,” Merlo said.

NERC, which originally surveyed 13,543 MW of solar PV as potentially using momentary cessation, now believes all but about 1,952 MW do not use it or can overcome it with modified settings. (The survey covered only utility-scale solar generators at or above 75 MW, the threshold for generators that must register with NERC.)

“We understand a lot more than we did when we first saw the event just 18 months” ago, Merlo said.

MISO Quick Capacity Reserves Wait Until 2021

By Amanda Durish Cook

MISO is working to create market rules for capacity reserves that can be supplied within 30 minutes, though the RTO won’t have a sophisticated enough technology platform to support the new product for more than two years.

RTO staff told the Market Subcommittee on Nov. 8 that the earliest the new product could be rolled out is the first half of 2021 because it will require the new market platform.

MISO Director of Market Design Kevin Vannoy said the short-term reserve product will address issues that are “more severe” than can be solved by either the ramp product and regulation reserve, which is supplied within seconds, or issues that are “less severe” than the Disturbance Control Standard events requiring the RTO’s 10-minute contingency reserves.

“The idea is to get the 30-minute reserves reflecting actual needs [of the system] rather than trying to have the 10-minute reserves covering it,” Vannoy said.

Bill Peters | © RTO Insider

“We have needs that we make out-of-market commitments for, but they’re not modeled in the market,” said Bill Peters of MISO’s market design team.

The short-term reserves would be furnished by either online generators dispatched according to opportunity costs or offline generators, which would be dispatched based on an offer price.

Peters said short-term reserves would help manage flows on SPP transmission between MISO Midwest and MISO South and aid areas hemmed in by transmission constraints or short on nimble reserves. They also will help meet load and avoid volatility as the RTO adds more intermittent resources.

MISO’s final ranking of Market Roadmap improvements placed the creation of short-term reserves at the highest priority, beating out projects to better model combined cycle generators, and respond to shifting resource availability and need.

Peters said the reserves could have market-wide, regional and local response requirements. He said MISO would dynamically schedule the reserves to a load pocket or region, assessing the state of the system, capacity needs, amount of cleared energy and amount of cleared short-term reserves before dispatch. He also said the RTO is considering applying a demand curve to pricing. Peters said the generators that sign up to provide the service will be tested to demonstrate they’re able to provide capacity within 30 minutes.

MISO has scheduled a Jan. 15 workshop to further discuss the conceptual design of a short-term reserve product.

UPDATED: Destructive Fire Drives Down PG&E Stock

By Hudson Sangree

Updated Nov. 16.

Pacific Gas and Electric’s stock price rose dramatically Friday after state California Public Utilities Commission President Michael Picker made a series of surprising public statements about the company’s future as it faces potentially billions of dollars in wildfire liability for the current Camp Fire, the deadliest in state history, and a series of devastating blazes in 2017.

On Thursday, Picker took part in a call with Wall Street analysts in which he said allowing PG&E to go bankrupt wouldn’t be good policy, Bloomberg News and other media outlets reported. He reiterated those comments in at least two newspaper interviews, and discussed the possibility of legislative action to relieve PG&E’s financial burden.

But Picker also said he was concerned about the utility’s lack of accountability. He told the Wall Street Journal that breaking up the company might be an option for regulators to consider. In a news release, the PUC president said he intended to expand an ongoing investigation into PG&E’s “safety culture” that the commission opened after the San Bruno gas line explosion in 2010.

“In the existing PG&E Safety Culture investigation proceeding,” Picker said in the statement, “I will open a new phase examining the corporate governance, structure, and operation of PG&E, including in light of the recent wildfires, to determine the best path forward for Northern Californians to receive safe electrical and gas service in the future.”

PG&E’s stock rose back to around $24 per share Friday after it plunged this week as the toll of death and destruction from the Camp Fire, the worst in modern California history, increased. The company fell under suspicion for starting the wildfire after one of the utility’s transmission lines was reported downed at the time and location of the fire’s ignition.

NASA’s Earth Observatory photographed the Camp Fire as it exploded late last week. | NASA

The news sent PG&E Corp.’s stock tumbling from roughly $48 per share on Nov. 8, when the fire started, to less than $18 per share on Thursday – a 62.5% drop in one week.

Similarly, Southern California Edison’s stock fell sharply as the Woolsey Fire raged in Los Angeles and Ventura counties, killing two and destroying more than 500 structures so far. Edison told state regulators it experienced an outage at a substation near where the fire started, the Los Angeles Times reported.

On Nov. 8, PG&E filed a report with the California Public Utilities Commission, saying it had experienced an outage on a 115-kV line near where the Camp Fire started and shortly before it was first reported. The company later wrote in a news release that the “information provided in this report is preliminary, and PG&E will fully cooperate with any investigations. There has been no determination on the causes of the Camp Fire.”

Early Thursday morning, firefighters responded to reports of a vegetation fire under transmission lines near Poe Dam, part of PG&E’s Feather River Canyon Power Project in rural Butte County. The California Department of Forestry and Fire Protection (Cal Fire) has identified the area as the approximate location where the fire started. A property owner in the area has told media outlets that she received an email from PG&E saying the company planned to do work on her land because its power lines were causing sparks.

Fanned by 35-mph winds, the fire quickly grew and destroyed most of the town of Paradise (population 27,000). As of Friday, it had killed 63 civilians, destroyed approximately 9,844 homes and hundreds of other structures and burned 142,000 acres, Cal Fire reported.

Previously the deadliest fire in state history was the Griffith Park Fire in Los Angeles in 1933, which killed 29 people, according to Cal Fire. The most damaging in terms of homes and other structures destroyed previously was the Tubbs Fire in Napa and Sonoma counties in October 2017, the cause of which is still under investigation.

The largest wildfire in modern state history, the Mendocino Complex of fires, occurred this summer, burning 459,000 acres in the rugged mountains north of San Francisco from July to September 2018.

The Camp Fire decimated the town of Paradise in the Sierra Nevada foothills. | Cal Fire

The Camp Fire has revived talk of PG&E’s possible bankruptcy, which became the subject of concern following a series of devastating wildfires in 2017. State fire investigators have said PG&E was responsible for 17 of the 21 blazes. The 2017 fires could subject the company to billions of dollars in liability under California’s unique system of holding utilities strictly liable for damage caused by power lines and equipment, regardless of negligence.

Earlier this year Gov. Jerry Brown proposed doing away with that system, known as inverse condemnation, arguing it threatened electric reliability and the state’s efforts to completely exclude carbon emissions from its power grid by the middle of the century.

Lawmakers tasked with formulating a major wildfire bill, SB 901, ultimately left inverse condemnation intact while creating a method by which utilities could issue long-term bonds to pay for some fire damage. (See California Wildfire Bill Goes to Governor.) Critics called the bill a bailout for the utilities, but Brown signed the legislation in September.

PG&E executives recently said in an earnings call that the new law was insufficient, and they intend to seek an end to inverse condemnation through the courts and legislature. (See PG&E Outlines Fire Strategy in Earnings Call.)

Company CEO Geisha Williams also discussed the company’s new practice of proactively shutting down sections of its grid during conditions that made wildfires especially dangerous. The company warned last week that it might have to shut down power to areas, including Butte County, but then decided conditions there did not warrant it.

In its recent third-quarter earnings call, SCE said its equipment was likely a partial cause of the hugely destructive and deadly Thomas Fire last year. That fire was the largest in state history until this year’s Mendocino Complex far surpassed it. (See Edison Takes Partial Blame for Wildfire in Earnings Call.)

SCE’s stock price fell from more than $25 a share before the Woolsey fire began, also on Nov. 8, to around $21 per share in trading Thursday.

NERC to Try Again on Inverter Rules

By Rich Heidorn Jr.

ATLANTA — NERC stakeholders are expected to consider a new standard authorization request (SAR) to address inverter-based resources after the Standards Committee rejected two SARs proposed by CAISO in September, officials said last week.

CAISO submitted the SARs in May, saying it had recorded at least 14 occasions since August 2016 when inverter-based solar generation incorrectly tripped or ceased to operate during the routine high-speed clearing of short circuits on bulk electric system (BES) transmission. NERC has issued several reports and alerts following the two most serious incidents: the August 2016 Blue Cut wildfire, when 1,200 MW of solar disconnected; and the October 2017 Canyon 2 fire, which resulted in the loss of more than 900 MW. (See NERC Chief: Inverter, Fuel Assurance Standards Needed.)

The ISO proposed incorporating performance requirements for inverter-based resources connected to the BES in a revised NERC standard PRC-024, or developing a new standard for such resources and clarifying that PRC-024 applies only to synchronous generation.

At its Sept. 13 meeting, however, the Standards Committee rejected both SARs by a 12-5 vote on a motion by Dominion Energy’s Sean Bodkin, who noted the Institute of Electrical and Electronics Engineers (IEEE) is addressing the issues in Standard 1547-2018.

NERC is working with IEEE on the standards for inverter settings and developing instructions on compliance monitoring and enforcement activities related to the issue, James Merlo, NERC vice president of reliability risk management, told the Member Representatives Committee (MRC) at its quarterly meeting Nov. 6.

FERC Commissioner Cheryl LaFleur, who attended the MRC and Board of Trustees meetings, said she was concerned about the rejection of the SARs, saying “nothing clarifies the mind like an enforceable standard.” She said it was better for NERC and its stakeholders to design standards rather than respond to directives from FERC.

NERC CEO Jim Robb said he was disappointed that the two SARs “met with such headwinds at the Standards Committee.”

“I think we need to get over the notion that any standard creates peril and get to the point where standards create certainty,” he said. “And I think, particularly, in the case of these inverter resources, that’s a very, very important thing for us to do. … These resources are not going away. They’re already at scale in the West, and they will [soon] be at scale … in many parts of the country.”

Merlo said the Operating and Planning committees and the Inverter-Based Resource Performance Task Force will seek a new SAR to modify PRC-024 that will build on a white paper to be released in about two weeks identifying gaps between current standards and what’s needed by grid operators. “The expectation is the Standards Committee would take that up in December,” Merlo said.

“I’m optimistic that that will accomplish much of what we wanted to accomplish through the original two SARs,” Robb said.

The work may not stop with revisions to PRC-024, said Howard Gugel, NERC senior director of engineering and standards. “Then that task force is also going to go forward to say, ‘given that this is a brave new world and we have these resources, is there another standard that we should write that says how they should actually operate?’” he said in an interview. “And it’s not just limited to solar. … [idle EVs injecting energy into the grid are] an inverter resource also.”

NERC has already asked solar generators to modify their inverter settings to ensure voltage excursions don’t result in momentary cessation (MC) — when they stop injecting current into the grid. For inverters that cannot use another ride-through mode, NERC asked that MC settings be reduced to the lowest voltage value possible and that the recovery delay be reduced to one to three electrical cycles.

In arguing for the SARs, CAISO’s Keith E. Casey, vice president of market and infrastructure development, noted that NERC guidelines are not enforceable.

“Due to a lack of any standard addressing the minimum performance of inverter-based generation connected to the BES, original equipment manufacturers often apply standards for resources connected to the distribution system to BES resources,” Casey wrote.

NERC reported that most of the lost solar generation in the Blue Cut fire resulted when inverters incorrectly perceived a low frequency condition and tripped, not returning to service for five minutes or longer. “Five minutes may make sense on a rooftop, but five minutes is an eternity on the bulk electric system,” Merlo said.

NERC, which originally surveyed 13,543 MW of solar PV as potentially using momentary cessation, now believes all but about 1,952 MW do not use it or can overcome it with modified settings. (The survey covered only utility-scale solar generators at or above 75 MW, the threshold for generators that must register with NERC.)

“We understand a lot more than we did when we first saw the event just 18 months” ago, Merlo said.

ACORE Forum Ponders ‘Energy Revolution’

By Hudson Sangree

FERC Commissioner Richard Glick | © RTO Insider

SAN FRANCISCO — This year’s ACORE Renewable Energy Grid Forum took place in a high-rise hotel within blocks of the headquarters of tech revolutionaries Twitter, Uber and Airbnb, among many others. So it was fitting that the forum’s speakers, including Google’s head of global energy policy, grappled with what keynote speaker and FERC Commissioner Richard Glick called the “energy revolution.”

Coming advances in electricity generation and distribution — such as mass storage, distributed renewables and computer algorithms that can monitor a vastly complicated grid — will make older modes seem like the horse and buggy at the dawn of the automobile era, Glick said. Back then, those invested in buggies would try to dissuade people from buying automobiles, he said.

“Every time a car would drive by someone would yell, ‘Get a horse,’” Glick told the audience at the Grand Hyatt San Francisco, near Union Square. “We’re kind of in that situation now” with fossil fuels and renewables, he said.

ACORE President Gregory Wetstone poses questions to CAISO CEO Steve Berberich. | © RTO Insider

Another keynote speaker, CAISO CEO Steve Berberich, said the traditional model of centralized generation using fossil fuels is already “fraying around the edges” as the price of solar and wind power continues to plummet. The cost of storage is also falling, he said, and every state except Idaho has a renewable energy goal.

“Even conservative states such as Utah are pursuing [renewable energy],” Berberich noted.

Laura Nelson, energy adviser to Utah’s governor. | © RTO Insider

The third keynote speaker, Laura Nelson, energy adviser to the Utah governor’s office, told the audience that the price of renewables has dropped 50% in the last five years, and Utah has increased its reliance from 1% to 8%, with big investments in utility-scale solar and geothermal power.

In a panel titled “Evolving Models for Electricity Markets,” Ralph Cavanagh, senior attorney with the Natural Resources Defense Council, said the biggest impediment to renewable integration is the fragmented Western grid.

Efforts to expand CAISO to an RTO for Western states had sputtered, he said, because other states were not willing to accept a board appointed by the California governor and confirmed by the State Senate, and California politicians weren’t willing to share control of the RTO. (See Can Calif. Go All Green Without a Western RTO?)

CAISO’s governance structure would need to change for California and neighboring states to participate in an organized wholesale market, he said. Gov. Jerry Brown supported the failed efforts at regionalization, partly as a means of achieving the clean energy goals of SB 100, which he signed in September. (See Calif. Gov. Signs Clean Energy Act Before Climate Summit.)

From left to right: Ralph Cavanagh, NRDC; Mars Hanna, Google; Rose McKinney-James, Energy Works; Andrew Murphy, Edison International. | © RTO Insider

Mars Hanna, Google’s head of global energy policy and markets, said his company, like California, is trying to reach a goal of relying on 100% carbon-free energy. To get there, he said, “We need to be able to blend Wyoming wind with Nevada solar.”

Addressing the recent election, Rose McKinney-James, managing partner of Nevada-based Energy Works, said state voters had rejected Question 3, a ballot proposal to allow customers to choose their energy providers, largely because they were concerned about rates going up. (See related story, High Failure Rate for Western Ballot Measures.) Nevada’s electricity rates are 45% less than California’s, she said.

Another big factor, she said, was that NV Energy, the state’s monopoly electric provider, had announced plans before the election to develop 1,300 MW of solar generation. But that would only happen if the company remained a monopoly, she said.

Cavanagh agreed. “[NV] Energy reinvented itself” as green and clean, he said. “It gave us something to vote for.” Now “you’re going to have a revitalized [NV] Energy as a player in the West.”

Pat Reiten, senior vice president of government relations for Berkshire Hathaway Energy, also was on the panel. NV Energy is a subsidiary of Berkshire Hathaway, billionaire Warren Buffett’s company.

Reiten said the falling cost of solar had persuaded the company to invest in it. NV Energy once uselessly bid solar into California’s market at $100/MWh, far more than fossil fuels, he said, but the price now is $20 or $30/MWh and competitive with other energy sources. “That’s rather remarkable,” Reiten said.

On the stage at the Grand Hyatt near Union Square, McKinney-James turned to Reiten and said she and many others expect NV Energy to keep its commitments.

“We do have expectations, and there will be feet held to the fire,” she said, eliciting laughs from the audience.

After lunch, conference attendees were invited to submit questions via an app to panelists Angelina Galiteva, a member of CAISO’s Board of Governors and founder and chairwoman of the Renewables 100 Policy Institute, and Dan Reicher, executive director of Stanford University’s Steyer-Taylor Center for Energy Policy and Finance.

From left to right: Chris Carr, Baker Botts; Neil Gerber, IBM; Jamie Link, EDF Renewable Energy; Aram Shumavon, Kevala Analytics and John Westerman, Dynamic Energy Networks | © RTO Insider

The first question was, “What is the biggest issue facing the grid as renewables proliferate?”

Intermittency, both speakers said, but they argued it isn’t as big a problem as many critics have contended.

Galiteva said she grew up in Tanzania, where local solar proved far more reliable than the spotty power supplied by a central generating station. “That’s where I fell in love with renewables,” she said.

Many criticize renewables such as wind and solar as being intermittent and unreliable, but Galiteva said she believes “renewables are more reliable than centralized power,” especially as renewable power sources proliferate.

The fact that renewable energy sources are distributed provides an inherent safety backup compared with centralized power, Galiteva said. “Look at the San Onofre power plant,” she said. The San Onofre Nuclear Generating Station, on the Southern California coast, shut down suddenly in 2012 after problems arose, and the grid lost the plant’s 2,350 MW.

Galiteva also pointed to the Aliso Canyon gas storage facility, a major resource for the Los Angeles area, which shut down after a massive leak was discovered in October 2015. Constraints on natural gas supply have resulted ever since. (See CAISO Seeks to Extend Aliso Canyon Rules.)

Reicher said intermittency was generally considered the main problem with renewables, but not all renewables are intermittent, he said. Hydropower, geothermal and biomass are regular, dependable sources, he said.

Storage, including pumped hydro, will make solar and wind more readily available during peak demand times, he said.

Floating wind farms off the coast of California, if ever approved by federal authorities, would be a reliable source of wind power. California’s coast has some of the most regular winds in the nation, and those winds pick up just as the state’s solar energy tapers off for the day, Reicher said.

“When you go to the beach in California,” he said, “the sun goes down and the wind comes up.”

Texas PUC Briefs: Nov. 8, 2018

By Tom Kleckner

Walker Pushes for Improved RC-to-RC Agreements with SPP, MISO

Texas Public Utility Chair DeAnn Walker said last week she has asked ERCOT, SPP and MISO to work together to improve the reliability coordination (RC) agreements among the grid operators.

Walker told her fellow commissioners she wants to ensure the grid operators’ RC operators understand their responsibilities and “can act on those responsibilities.”

“I believe all three regional coordinators would agree the documents we have now could have more clarity,” Walker said during the PUC’s Nov. 8 open meeting. “My intent is for them to work through those agreements, so there’s more clarity … for reliability purposes.”

Walker said she last month discussed her intentions with SPP leaders, who assured her their staff would work with ERCOT staff “to get something done by the end of the year.” She said she is also working on setting up a meeting with MISO CEO John Bear.

Separately, SPP and MISO are working to improve coordination across their seam following January and September events this year. (See “SPP-MISO Operating Procedures not yet Documented,” SPP Board of Directors/Member Committee Briefs: Oct. 30, 2018.)

Walker’s concern is over the use of switchable generating units, interconnected to other regions but available to ERCOT. Its most recent seasonal assessment of resource adequacy listed 3.7 GW of installed capacity as being available to the Texas grid operator in an emergency situation.

“We’re not trumping [SPP and MISO] on a reliability need to their system,” Walker said. “If they say they’re not willing to release [switchable units], we have options here in ERCOT we can use for reliability purposes.”

Walker said she was also driven to share her work with Commissioners Arthur D’Andrea and Shelly Botkin because of “a lot of discussion out there misrepresenting what I’m trying to do.” As an example, she pointed to opposition to an ERCOT revision request that would add a new resource status code for switchable units.

“There’s so much pushback on very reasonable things,” Walker said. “To me, it’s all about reliability. Ratepayers in ERCOT have been paying for the transmission to interconnect these units. They should have some reason to be here for reliability.”

PUC to Discuss Market Changes

The commission agreed to reserve time during its Dec. 7 open meeting for a broader discussion of potential changes to ERCOT’s market, including real-time co-optimization and incorporating marginal losses into dispatch decisions (Project 48551).

Both proposals have varying degrees of stakeholder support. Staff have been asked to provide additional information and offer recommendations on the proposed changes, which were the subject of two workshops last year. (See ERCOT, Regulators Discuss Need for Pricing Rule Changes.)

Walker said she is hopeful about “getting those things behind us,” despite apparent stakeholder concerns that the PUC is moving too quickly.

“I’ve been astonished in the past week by people saying we’re rushing to a decision on this,” Walker said, noting potential market reforms were before the commission when she joined last year. “It doesn’t feel like much of a rush to me. I guess people judge rushes differently.”

Enforcement Actions Result in $2.83M in Penalties

The PUCT released a report detailing its enforcement actions for the 2018 fiscal year.

According to the “2018 Summary of Customer Complaints and Enforcement Activities,” commission staff concluded 114 investigations, with results ranging from fines and license revocations to findings of no violation. The PUC approved orders imposing $2.83 million in administrative penalties and returning more than $108,000 in refunds to Texas ratepayers.

“The Texas Legislature created a level playing field for the companies competing to serve utility customers, and it’s our job to throw penalty flags for infractions,” Walker said in a release.

Electric retail and wholesale issues accounted for 40% and 24%, respectively, of the investigations. Water (25%), electric service quality (9%) and telecommunications (2%) made up the rest.

Non-IOUs Get Rate-Review Schedules

In other actions, the PUCT approved a rate-review schedule for non-investor-owned transmission service providers (Project 48377) and modified a previous order granting Oncor a certificate of convenience and necessity for its Far West Texas Project (Project 48095). (See PUCT Grants Oncor CCN for Far West Texas Project.)

During their executive session, the commissioners agreed to intervene in two Entergy dockets before FERC:

Entergy Services’ request to transfer its ownership interests in two transmission control centers to Entergy’s operating companies (EC19-18). The centers are in Jackson, Miss., and Little Rock, Ark.

Entergy Services’ filing of an unexecuted joint ownership and operating agreement that identifies the terms and conditions of the operating companies’ ownership of the control centers (ER19-211).

NERC MRC/Board Briefs: Nov. 6-7, 2018

By Rich Heidorn Jr.

ATLANTA — NERC’s Board of Trustees and Member Representatives Committee (MRC) held their quarterly meetings last week at the Grand Hyatt Atlanta. Here are some of the highlights. (See related story, LaFleur, Stakeholders Anxious over NERC Retirement Study and NERC to Try Again on Inverter Rules.)

NERC’s Board of Trustees and Member Representatives Committee held their quarterly meetings last week at the Grand Hyatt Atlanta, where discussions focused on potential governance changes, and the transition to new reliability coordinators in the West. | © RTO Insider

New ERO Enterprise Dashboard

NERC is proposing a new approach to how it collects and presents metrics, advancing a “dashboard” that separates measures of industry performance from those indicating how well the organization is meeting its goals.

NERC CEO Jim Robb | © RTO Insider

CEO Jim Robb said the dashboard represents a “very different approach to performance management than what we’ve done in the past” and that executives will use it to allocate resources.

The dashboard shows green for risk indicators that are improving, yellow for stable metrics and red for metrics getting worse.

For 2018, the indicators showed improvements in the number of bulk power system events; forced outages because of cold weather or lack of fuel; outages resulting from operator or other human performance issues; and unauthorized physical or electronic access.

Vegetation encroachment metrics were unchanged from 2017, while protection system misoperation rates and failures of substation and circuit equipment got worse.

NERC’s three-year operating plan lists six goals: developing risk-responsive reliability standards; objective, risk-compliance monitoring, mitigation and enforcement; reducing known reliability risks; identifying and assessing emerging risks; reducing cyber and physical security; and improving its efficiency and effectiveness.

FERC Commissioner Cheryl LaFleur | © RTO Insider

FERC Commissioner Cheryl LaFleur, who attended the meetings, said she supports separating the metrics into two categories but questioned the cybersecurity metric. “Losing load from a cyber incident is a pretty gross standard [for measuring cybersecurity]. There must be leading indicators, [numbers of] incursions or whatever. That’s something that [FERC has] been focused on: … trying to get more data.”

Robb acknowledged that the metric was “anemic” and said NERC is seeking ways to capture other indicative data.

In written comments, the ISO/RTO Council (IRC) supported the bifurcation of the metrics but said tools other than standards and enforcement “needs to be a higher priority” for NERC.

“With steady state standards, efficiency reviews and compliance program enhancements to reduce the compliance burden, NERC must develop alternative methods to effectively address new and evolving reliability concerns without having to undo or jeopardize these past improvements and effective compliance behaviors,” the IRC said, adding that some existing metrics “do not have a direct correlation with NERC programs.”

The IRC also expressed concern over the proposed color choices, saying yellow should be replaced with a “neutral” color to illustrate metrics that are unchanged and satisfactory. “A yellow color is associated with caution or imminent threat and can be misinterpreted,” it said.

The North American Generator Forum, the Northeast Power Coordinating Council, the Cooperative Utility sector, the Canadian Electricity Association (CEA) and the Edison Electric Institute all generally supported the revised metrics.

The CEA called for additional metrics to define an “adequate level of reliability.”

EEI questioned a goal focused on enhancing or proposing new standards. “NERC should consider the use of other tools (e.g., Reliability Guidelines, lessons learned, best practices), in addition to reliability standards, similar to the [electric reliability organization’s] compliance and enforcement philosophy, to efficiently and effectively address reliability and security risk,” EEI said.

Robb said the feedback will be incorporated in the final dashboard model.

Addressing Overlap of CIP, Planning and Operating Committees

Mark Lauby, NERC senior vice president and chief reliability officer, briefed the MRC on a proposal to rethink its committee structure to respond to what he called the “increasing convergence” of subjects overseen by the Critical Infrastructure Protection, Planning and Operating committees.

NERC briefed stakeholders on a proposal to rethink its committee structure to respond to the increasing convergence of the subjects overseen by the Critical Infrastructure Protection, Planning and Operating committees. | NERC

Lauby said the MRC should consider eliminating those committees and using “mission-driven” task forces that would study an issue, make recommendations and disband when their missions are complete.

Mark Lauby, NERC | © RTO Insider

Lauby said the current committee structure, in place for more than a decade, is “expensive and time consuming” for NERC members and that the committee “silos” are blurring in part because of new technologies and changing industry models.

Task forces, he said, could ensure the stakeholders have the right subject matter expertise.

Consultant Herb Schrayshuen, representing the Small End‐Use Electricity Customer sector, and Oncor Vice President of Regulatory Affairs Liz Jones, representing the Regional Entity sector, said the committees are necessary for some recurring tasks such as annual reliability assessments. Jones said the PC and OC don’t need to meet quarterly or separately, but “there is value in retaining” them.

NERC said that in addition to Midwest Reliability Organization, the Florida Reliability Coordinating Council, SERC Reliability and Western Electricity Coordinating Council also have reorganized their committee structures.

The Western Area Power Administration’s Lloyd Linke, a member of the MRO board, said he generally supported the change, calling it “somewhat similar to the process that the MRO” has adopted. “When the MRO did this, they did keep some committees … to provide some of that continuity on some of the yearlong type things,” he said.

Carol Chinn, representing the State/Municipal Utilities sector, said the proposal was a good start but “there needs to be much more dialogue” with MRC members before changes are made.

MRC Vice Chair Greg Ford agreed “it is time to look at our committee structure.”

“The right answer may be: Keep the three committees but streamline them,” he said.

NERC plans to create a staff/stakeholder working group reporting to the board to explore the issue further and develop a restructuring proposal.

“Let’s set some sort of a time frame,” NERC Trustee Dave Goulding said, “because this is a project that could go on and on and on and you’ll never get everybody on board.”

Long-Term Reliability Assessment Sees Shortfalls in CAISO, MISO, Ontario

John Moura, NERC | © RTO Insider

John Moura, NERC’s director of reliability assessments and technical committees, gave a presentation on the draft 2018 Long-Term Reliability Assessment through 2028, noting it is the first such report to include metrics on “essential reliability services” such as frequency response and ramping capability.

Moura said the projected 10-year compound annual growth rate for North America of 0.57% (summer) and 0.59% (winter) is the lowest on record. None of the regions projects annual load growth of more than 2%.

“For the first time, we’ve seen five areas — New York, New England, Maritimes, Manitoba Hydro and the WECC California-Mexico area — actually reducing [their] peak demand over the 10-year period,” he said. “That’s kind of unheard of.”

In 2008, NERC projected a 30-GW increase in coal generation by 2018. Instead, coal capacity dropped by 50 GW. It also vastly underestimated the increase in natural gas generation, having predicted an increase of only 50 GW. | NERC

The report projects MISO and Ontario will see planning reserve margin shortfalls beginning in 2023. In addition, probabilistic evaluations indicate resource adequacy risks in the California and Mexico region of WECC in off-peak hours after the sun sets and during spring and fall maintenance outages. The loss-of-load expectation for the WECC-CAMX region — most of California and a small northern portion of Baja California — is projected to rise from nine hours in 2020 to 95 in 2022.

Although the grid is losing inertia as renewables replace synchronous generation, all interconnections should have adequate frequency response through 2022, the report says.

The report projects the addition of more than 30 GW of distributed solar PV by the end of 2023, when it said California will have 18 GW and Massachusetts and New Jersey will have 4 GW each.

But Moura said the report should be viewed with humility, saying stakeholders should remember that the only certainty about its projections is that they will be wrong. In 2008, he noted, NERC projected a 30 GW increase in coal generation by 2018. Instead, coal capacity dropped by 50 GW. “That was an 80-GW miss,” he said.

It also vastly underestimated the 200-GW increase in natural gas generation, having predicted an increase of only 50 GW.

The departure of Peak Reliability as the reliability coordinator in the West will create new seams between the RC footprints of CAISO, SPP, the Alberta Electric System Operator (AESO) and BC Hydro. | WECC

Update on Western Reliability Coordinators

WECC CEO Melanie Frye provided the board with an update on efforts by CAISO and SPP to replace Peak Reliability as the reliability coordinators (RCs) in the Western Interconnection. (See Western RC Transition ‘Hot Topic’ at WECC Meeting.)

Five regions, including New York and New England are projecting a drop in their peak demand over the next 10 years. | NERC

WECC CEO Melanie Frye | © RTO Insider

She said officials have identified tie lines that begin in one RC footprint and end in another, including 114 such lines between CAISO and SPP. “So we’re doing some additional technical analysis to try to understand what could be the change in flows in the system if there were to be elements out of service,” she said. “What that’s really highlighted is the need for both RCs in that example to model the broader footprint.”

Robb said he was “very pleased” with NERC’s collaboration with WECC, CAISO, SPP and others to address the transition, but he acknowledged concerns over seams in the desert Southwest.

“There’s the potential for a couple seams to be developed between Phoenix and San Diego. That’s a very important path and has been a very vulnerable path in the West. So, there’s a lot going on to understand issues that that topology creates and how to manage through it,” Robb said.

NERC Chair Roy Thilly said “it appears that everything is being looked at very, very thoroughly.”

FERC-NERC Study on Southern Cold Weather Event

NERC officials did not offer any new details on their collaboration with FERC on a report on the Southern cold weather event in January. (See FERC, NERC to Probe January Outages in MISO South.)

But Robb acknowledged concerns heading into winter 2018/19. “We haven’t completed the inquiry … but there was an awful lot of generation offline during that event, which at least raises the question about whether or not cold-weather preparation is adequate for the circumstances.

“This is the third [winter] in a row that we’ve had some large amounts of generation offline.”

Trustee Approvals

Howard Gugel, NERC | © RTO Insider

The Trustees unanimously approved:

  • TPL-001-5, a response to FERC’s 2013 Order 786, which will require assessments of single points of failure and inclusion of them in future transmission studies. Based on a cost-benefit analysis and industry feedback, NERC decided not to require eliminating single points of failure, said Howard Gugel, senior director of engineering and standards. “The response that most of industry and NERC staff [agreed on] is no … there is some risk that — as long as you know what that risk is — it’s a risk that’s acceptable to have and at least know how that risk can be mitigated.” Gugel said that out of 12,000 misoperation events in NERC’s database since 2011, less than 30 involved three-phase faults, and “we only had 10 instances where a three-phase fault was also associated with a relay failure. We also [asked], of all the events that we’ve seen on the system, do any of those correlate with any of those 10? … We cannot find an instance in the data we have.”
  • The standard specifies the types of events and nonredundant protection system components that should be studied. It also eliminates the minimum six-month threshold for including outages in planning studies, which FERC said “could exclude planned maintenance outages of significant facilities from future planning assessments.”
  • The retirement of IRO-006-TRE, which is redundant to other reliability standards. The Texas Reliability Entity board approved its retirement in September.
  • The Reliability Standards Development Plan for 2019-2021, which focuses on periodic reviews, FERC directives, the Standards Efficiency Review and the standards grading initiative.
  • Revisions to sections 600 (Personnel Certification) and 900 (Training and Education) of NERC’s Rules of Procedure. The revisions are in response to a July 19 FERC order (RR17-6) that changes regarding NERC’s training and continuing education programs but rejected deletion of its personnel certification rules. (See “Split Ruling on NERC Rules of Procedure,” FERC Orders Expanded Cybersecurity Reporting.)
  • The execution of a memorandum of understanding outlining MRO’s compliance monitoring of Manitoba Hydro.

New MRC Officers, Seeking Canadian Trustee

Trustee Fred Gorbet, head of the board’s Nominating Committee, said a five-person interview team has met with candidates to replace him as the Canadian representative on the board. The team will share its recommendation with the committee Dec. 10 with hopes to install the winner in February 2019, said Gorbet, who is leaving because of NERC’s term limits.

The MRC elected Greg Ford as chair and Jennifer Sterling vice chair for 2019. Ford is CEO of Georgia System Operations Corp., which manages 38 distribution cooperatives and Oglethorpe Power. Sterling is vice president of NERC compliance and security for Exelon.

Retirements for ELCON’s Hughes, NERC’s Roxey

John P. Hughes, Electricity Consumers Resource Council | © RTO Insider

The quarterly Trustee meeting was the last for retiring John P. Hughes, president of the Electricity Consumers Resource Council (ELCON) and NERC’s Tim Roxey, chief operations officer for the Electricity Information Sharing and Analysis Center (E-ISAC).

“I will miss [Hughes’] voice,” LaFleur said. ELCON, which represents industrial customers, has tapped Devin Hartman, formerly of the free-market think tank R Street Institute, as its new chief executive effective Jan. 1. Hughes, who has degrees in engineering and economics, joined ELCON in 1987 and became its CEO in 2015.

Roxey, a former nuclear engineer who began working at the E-ISAC in 2009, received a commemorative resolution and a standing ovation from the approximately 200 stakeholders.

Tim Roxey, NERC | © RTO Insider

“It has indeed been a long strange trip,” Roxey said. “You cannot have a bulk power system or a distribution system [be] reliable without the support and functioning of all of this,” he said, looking at the dozens of stakeholders in the large hotel ballroom. “I’ve come to understand and appreciate [reliability] standards and compliance — which I used to object to, but I now embrace as a necessary part of the [Compliance Monitoring Enforcement Program]. It is critical … that we be proactive in creating standards because that’s what we do. We don’t have to be told.”

Split FERC OKs New ‘Economic Life’ Rules for ISO-NE

By Rich Heidorn Jr.

FERC on Friday approved ISO-NE’s plan to correct a key calculation in evaluating delist bids, a change that could reduce capacity prices.

The 2-1 ruling, supported by Commissioners Cheryl LaFleur and Richard Glick, prompted a dissent by Chairman Neil Chatterjee, who said that making the change effective for Forward Capacity Auction 13 violated the commission’s rule against retroactive ratemaking (ER18-1770). Commissioner Kevin McIntyre, who is battling a brain tumor, did not participate.

At issue was how ISO-NE’s Internal Market Monitor calculates the “economic life” of resources that want to retire or permanently leave the capacity market. Such a resource must provide at least five years of cash flow estimates to justify their delist bids, which specify the price at or below which it would retire.

To determine whether the bid price is competitive, the Monitor calculates the expected remaining economic life of the resource — the number of capacity commitment periods in which the resource could continue operating profitably. The Monitor calculates the competitive delist price as the lowest capacity payment at which the resource would be no worse off by retaining its capacity obligation rather than retiring immediately.

Under ISO-NE’s old rules, the economic life for this example generating resource would be five years because the cumulative net present value remained positive even though the plant lost $3 million in the last year. Under the new rules, the economic life would be four years, when its NPV peaked at $10 million, recognizing that the owner would not want to absorb losses in year five. | © RTO Insider

ISO-NE said the Monitor recently determined that its calculations — which defined the economic life as the period for which the resource’s cumulative net present value (NPV) is positive — were overstating the true economics of some resources and could result in improperly high delist bids.

The calculation assumed that a resource that earned positive cash flows in the earlier years would continue to operate while suffering losses as long as the cumulative cash flows remained positive — an assumption that ignored that a resource would choose to retire as soon as its cash flows turned negative.

Under the new rules, the economic life of a resource will be the period that maximizes the NPV. The rules are effective Aug. 10, 2018, and will apply for FCA 13 in February 2019.

In ISO-NE’s filing, Hemant Patil, an economist with the Monitor, gave an example of a resource that expects positive cash flows of $5 million in year one and negative cash flows of $3 million in year two and each subsequent year. “The current Tariff calculation would yield an economic life of two years because the resource could operate for two years with resulting cumulative cash flows of $2 million — positive $5 million in year one plus negative $3 million in year two. This assumption is inconsistent with how a competitive supplier would operate a resource. In this example, the supplier would not choose to operate its resource beyond year one and incur the negative cash flows of $3 million in year two. Instead, it would choose to exit the [Forward Capacity Market] after year one in order to maximize its cumulative cash flows at $5 million.”

ISO-NE and the New England Power Pool’s Participants Committee said they sought the change after an unidentified supplier submitted delist bids for four resources totaling 2,000 MW for FCA 13, which they said could harm the competitiveness of the auction.

The RTO gave another example in which its prior rules estimated a resource would need $11 million in revenue to break even, inflating the delist price by $2.5/kW-month over the $8 million revenue requirement under the revised rules. If the supplier has market power, it could also inflate the prices for the remainder of its portfolio. If that unit was the marginal bid affecting 30,000 MW of cleared capacity, the incorrect calculation would raise consumer costs by about $900 million ($2.5/kW-month x 12 months x 30,000 MW), the RTO said.

LaFleur and Glick rejected a protest by the New England Power Generators Association, which complained that the Aug. 10 effective date requested by ISO-NE and NEPOOL disrupted market expectations and violated the commission’s rule against retroactive ratemaking. NEPGA asked the commission to reject the proposal and order the RTO to bring it before stakeholders, with no changes effective before FCA 14 in 2020.

The proposal was approved by NEPOOL’s Markets and Participants committees, both with about 69% in support. The commission said that although the stakeholder review was “expedited, the record reflects that ISO-NE met its burden for stakeholder review … under its Participants Agreement.”

“A rational resource, in exercising competitive bidding behavior, would seek to exit the market, or retire, before it starts incurring consecutive losses,” the commission said in approving the change. “The benefits of the proposed economic life revisions outweigh potential disruptions to market participants’ settled expectations and harm caused by reliance on the existing [capacity market] rules.”

Chatterjee disagreed, saying that making the rules effective for FCA 13 harmed “market participants who relied on the existing Tariff in calculating prices and entering into contracts” in preparation for the auction.

Chatterjee said it was “troubling” that the RTO submitted the proposal after calculating the economic impact of the existing rules. “This change would achieve a specific price-oriented outcome based on information ISO-NE possesses due to its unique role as both system operator and auction administrator,” he said. “This case raises very serious questions about when and how the rule against retroactive ratemaking applies.”