Page 1313 – RTO Insider

June 6, 2017

MISO Interregional Plans with SPP Echo PJM Efforts

By Amanda Durish Cook

CARMEL, Ind. — After two years, MISO and SPP have negotiated a memorandum of understanding to address overlapping congestion charges, implement a small interregional project type and swap flowgate control to account for power flows.

RTO officials say the MOU, which borrows elements from MISO’s coordination efforts with PJM, provides market-to-market specifics where the joint operating agreement is vague. The document won’t result in major changes in coordination, officials said.

The MOU addresses exchanging control of market flows, correcting errors in firm-flow entitlements, studying the impacts to entitlements when facility ratings are changed, capping entitlements at the security operating limit and making market-to-market hold-harmless reimbursements. (See “MISO, SPP Agree to M2M Improvements,” SPP-MISO Briefs.)

Complex Topics

MISO PJM SPP interregional plans — Ahmed | © *RTO Insider*

SPP Director of Interregional Relations David Kelley said the RTOs have been working to improve M2M coordination since early 2015. “These are some very complex topics that often involve months or years of negotiations,” he said.

Staff say the memo is meant to target problems the RTOs have experienced since the start of the M2M process, including ineffective real-time congestion management on flowgates and errors in settlement calculations. Kelley said the memo documents the RTOs’ “common agreement” on how to handle M2M issues. “There were honestly some different interpretations of the JOA,” Kelley said at a May 31 meeting between the two RTOs at MISO’s headquarters, the first JOA meeting in a year. MISO’s Jeremiah Doner said that given the complex interregional goals the RTOs have laid out, another JOA meeting would be scheduled soon.

Kelley said the memo’s objectives aren’t written out verbatim in the JOA, but the “intent” of the memo is in the JOA.

Ron Arness, of MISO’s seams management division, said a few of the items outlined in the MOU, such as swapping control of flowgates, will require JOA changes. Arness said the agreement still needs approval from representatives of both RTOs’ legal departments and executive leadership.

Kelley said the document won’t necessarily be filed or become public. He said the RTOs want to execute the MOU in the next few weeks and file with FERC a revised JOA to allow limited resettlements during the summer.

Swapping Flowgate Control

“The longest pole in the tent is the market flow control change. We have software being delivered for that,” added MISO Director of Forward Operations Planning Kevin Vannoy.

The memorandum allows MISO and SPP to use an alternative flowgate control at certain times when power swings are significant, so predominant market flow dictates relief control on a flowgate, and not solely which RTO has monitoring control, Kelley said.

There have been situations in the past where MISO has had 95% of the flow on a flowgate but SPP still controls it, and it’s difficult to manage, Kelley said. He added that the RTOs will only swap control of flowgates when both agree that it’s the best course of action, either resulting in better price convergence or better congestion constraints. All instances where the RTOs trade monitoring roles will be reviewed after-the-fact.

At MISO’s last Board of Directors meeting in March, MISO Market Monitor David Patton appealed for MISO, PJM and SPP to become more active in transferring monitoring of constraints. (See Tornadoes, Wind Generation Drive MISO Tx Congestion.)

Resettlements

MISO and SPP will also form a technical committee by early October to address M2M issues and resettlements, but the RTOs said they will not retroactively provide resettlements more than six months prior to the MOU except for three 2015 cases, in which SPP will refund MISO more than $600,000.

Kelley said the RTOs will not pursue any other resettlements. “While we would love to chase down every penny, we don’t think that’s effective. We don’t think that’s a good use of your dollars,” Kelley said.

Going forward, when market participants dispute settlement amounts in the M2M process, Kelley said they will have to fill out a standardized form for RTO staff to review.

Stakeholders asked if the MOU’s resettlement provisions will extend to overcharges on pseudo-tied resources from double-counting congestion. Vannoy said those charges are not in the scope of the memo, and the issue will probably be handled with FERC-ordered refunds.

Adam McKinnie, chief utility economist for the Missouri Public Service Commission, asked whether the MOU is permanent or will be continually revised depending on future resettlements.

“Is this going to be some interminable, shifting document that we’re never quite sure of?” he asked.

Kelley said SPP’s resettlements are discussed at monthly Seams Steering Committee meetings.

“You’re not my problem as much as the other RTO in this room,” McKinnie said.

“Shots fired,” Kelley jokingly replied.

Arness said MISO presents resettlement payments exceeding $250,000 at the Seams Management Working Group, but McKinnie countered that not all seams issues are routed through the group.

“I know where to go when there’s a seams issue at SPP. … It’s frequently difficult to follow seams issues at MISO,” he said.

Flowgate Management Criteria

MISO and SPP staff also revealed new flowgate management criteria in the memo and said M2M flowgates will be removed when a non-monitoring RTO does not have at least a 5% forward or dispatchable 5% reverse impacts. Flowgates can be reinstated once they pass the 5% threshold.

Vannoy said he imagined that the RTOs would address which flowgates are used in their weekly M2M staff meetings. A more formal review to remove flowgates will take place at monthly meetings between SPP and MISO staff.

Overlapping Congestion

The RTOs are currently monitoring interface pricing and are asking for stakeholder advice on how to reduce their overlapping congestion charges after a joint analysis.

The RTOs analyzed price incentives using current interface definitions, comparing them to “ideal” incentives with no congestion overlap. An analysis of binding constraints in 2015 and 2016 showed congestion pricing was 1.85 times the ideal, said Dustin Grethen of MISO’s market evaluation design group. Vannoy said the RTOs are over-incentivizing impacts of transactions, paying 85% more than necessary when congestion pricing is used.

The RTOs are considering resolving the modeling problem using either a MISO Monitor-endorsed solution in which the monitoring RTO prices the entire path from the non-monitoring RTO area with zero payments made by the non-monitoring RTO, or use a common bus interface definition in which each RTO sets its interface price “relative to a common set of interface points,” the solution MISO and PJM elected to use. (See PJM, MISO Go Quiet on Pseudo-Ties; Reach Interface Pricing Accord.)

SPP’s Tanzila Ahmed said the RTOs don’t have to use the common interface definition just because it worked for PJM and MISO. “We’ll possibly see if there are other solutions. These two solutions might not work perfectly with SPP and MISO.”

MISO and SPP currently charge or credit congestion for the entire path of pseudo-ties, even when the path crosses into another balancing authority.

The RTOs are also considering varying levels of rebates depending on whether they adopt a common bus definition and the eventual scheduling of pseudo-ties in the day-ahead market to address the double-charging problem, Vannoy said. They’re also still analyzing pseudo-tie data and the RTOs’ separate modeling methods and have not yet arrived at any solution, he said.

Replacing Freeze Date, Implementing TMEPs

As with PJM, MISO is aiming to replace the freeze date by which firm-flow entitlements are calculated with SPP with four tranches based on generator in-service date, and implement a targeted market efficiency project (TMEP) type for cost-effective and congestion-relieving seams projects that might otherwise be overlooked because of their low cost and small size. (See “Four Categories for Freeze Date,” MISO-PJM TMEP Projects Drop to Five.)

MISO and PJM filed to implement TMEPs in their JOA on Dec. 30 (ER17-721); the two have identified $17.25 million worth of upgrades in five TMEP candidate projects. By September, both RTOs hope to finish evaluation of TMEP candidates and ask for board approvals by the end of the year.

MISO and SPP could begin drafting JOA and Tariff language to create the project type while looking for small project candidates that could relieve historical congestion on the seam, said Davey Lopez, MISO adviser of planning coordination and strategy. He said the RTOs could determine regional and interregional cost allocation throughout 2018 and have board-approved projects ready for construction by early 2019.

Entergy’s Yarrow Etheredge said she was apprehensive that the RTOs will begin selecting projects before the JOA language is finalized. She wondered if MISO and SPP had considered that their TMEP would have different criteria than a MISO-PJM TMEP. “The needs on the PJM-MISO seam are so different than the needs on the SPP seam, so an entirely different process could be warranted,” she said.

Lopez said the RTOs built enough time into the project creation and selection timeline for multiple rounds of stakeholder reviews. Kelley also said there is room for “commonalities” between the two types of TMEPs, and SPP stakeholders have signaled that there is appetite for a similar TMEP project type creation.

McKinnie asked if MISO and SPP assume that no TMEPs would be opened to competitive bidding because of the short timeline. MISO engineer Adam Solomon said MISO expects that “99%” of TMEP project candidates — including all five current MISO-PJM TMEP candidates — will be upgrades to existing facilities and therefore not open to competitive bidding.

June 6, 2017

MISO Reliability Subcommittee Briefs

CARMEL, Ind. — Barring a FERC denial, MISO says it will begin sharing gas usage profiles of gas-fired generators with three natural gas pipeline owners before winter as part of a pilot program aimed at improving reliability.

Mark Thomas, MISO manager of gas-electric coordination, said the RTO will offer day-ahead hourly usage profiles to Northern Natural Gas, ANR Pipeline and DTE Energy in an effort to ensure adequate fuel supplies for gas-fired generators.

MISO filed with FERC last month for approval to share hourly burn estimates with select gas operators (ER17-1556).

The RTO doesn’t have a fixed target date to begin sharing the profiles, but staff would like to begin before winter hits and gas usage spikes, Thomas said during the June 1 Reliability Subcommittee meeting. MISO will await FERC approval before sharing any data.

Thomas stressed that MISO will only communicate aggregated data, but he also said sharing nonpublic operational information is “consistent with FERC Order 787.” He added that the RTO will “execute nondisclosure agreements and notify gas pipelines and utilities of existing FERC rules which enforce protection of nonpublic information.”

In April, some stakeholders voiced reservations about the pilot, saying the sharing of estimated day-ahead data could harm reliability if gas operators begin to make burn rate decisions relying solely on partial data. (See MISO Stakeholders Question Electric-Gas Info Sharing.)

Work Group Produces MISO Resilient Operations Plan

MISO is putting emphasis on resilient operations in the response to stepped-up NERC Critical Infrastructure Protection standards.

MISO Reliability Subcommittee frequency response — Sperry | © *RTO Insider*

Kim Sperry, liaison to the Resilient Operations Work Group (ROWG), presented the RSC with a work plan outlining short-term reliability goals . In one to two years, MISO wants to establish better threat procedures for areas under greater risk for outages and work with local balancing authorities to specify alternatives for balancing during extended outages. She said that the ROWG will submit the balancing authority resiliency topics to the Steering Committee for issues assignment.

By 2019, the RTO also hopes to automate the entry of large volumes of data and identify alternative methods of communications when traditional means are not functional, Sperry said.

MISO’s outage restoration plans will focus on “black sky” outage situations — larger regional outages that last considerably longer than average operational or weather outages, she said.

The work plan also states that in two to five years, MISO will expand training on high-impact, low-probability events. Ongoing resiliency efforts expected to last beyond five years include cybersecurity improvements and gas-electric coordination, Sperry said.

MISO: Frequency Response Modeling Needs Work

MISO has performed a review of its reliability modeling in order to study the decline in its frequency response capability. One result: The RTO has learned there’s room to improve its dynamics modeling, according to Resource Adequacy Manager Durgesh Manjure.

Preliminary results show that seven of MISO’s 35 local balancing authorities contain generators that do not appear in the dynamics model, accounting for about 1% of generation, Manjure said. In addition, 31 local balancing authorities contain generators that do have governors appearing in the model, totaling 25%. Dynamics modeling, along with power flow modeling, is a key component of the RTO’s transmission planning.

Manjure said MISO will reach out to individual generators to confirm the absence of equipment or determine if the RTO is overlooking the equipment in its modeling inventory.

“This is a very preliminary review,” Manjure said. “We’re trying to get to a point where our models are useful.”

MISO earlier this year committed to studying its deteriorating frequency response and will later this year review performance based on collected data and compare results to actual events. (See MISO Begins Study on Declining Frequency Response.)

MISO’s Steve Swan shared the frequency response statistics supplied to NERC. Frequency response averaged -563.30 MW/0.1 Hz in 2014, -477.39 MW/0.1 Hz in 2015 and -336.30 MW/0.1 Hz in 2016. MISO’s current frequency response obligation under NERC’s frequency response reliability standard (BAL-003-1) is -211 MW/0.1 Hz.

“We’re getting to a point where this is real and our margin isn’t as big as it was a few years ago,” RSC Chair Tony Jankowski said. “I think we need to keep this a focus. It’s getting risky.”

Manjure also said MISO cannot use frequency measurements from supervisory control and data acquisition (SCADA) software for study data as originally hoped because the measurements aren’t produced quickly enough, despite the ability for SCADA to produce one measurement every four seconds. He said the RTO is investigating other means of data collection.

MISO Says Solar Eclipse No Big Deal; Energy Storage Meeting Planned

This summer’s total solar eclipse will not threaten MISO’s operations, but it can provide lessons for the future, according to RTO staff.

“It does cross through MISO’s footprint, but it’s not expected to be a significant reliability event,” RSC liaison Mike McMullen said.

Solar installations from Oregon to North Carolina will be in the path of the Aug. 21 eclipse, and portions of Illinois within MISO will be affected, McMullen said, adding that the RTO will monitor distributed energy resources during the event. He said this eclipse can serve as a learning experience in preparation for the next total solar eclipse on April 8, 2024, when he expects there to be greater solar penetration in the footprint.

“Certainly, we’ll see changes to the system between now and then,” he said.

McMullen also noted that MISO has set a tentative date of July 24 to hold a common issue meeting on energy storage.

At the April Steering Committee meeting, Consumers Energy, DTE Energy, Ameren, Xcel Energy and Indianapolis Power and Light, which all own storage resources, submitted a joint request that MISO create a model for storage’s participation in the market and track its growth using the RTO’s Market Roadmap list of market revisions. Staff also said a task team dedicated to energy storage could follow the common issues meeting. (See MISO’s Next Step on Storage: ‘Common Issues’; Task Team?)

MISO Ends Manitoba Hydro Reserve Support

MISO successfully carried Manitoba Hydro’s usual contingency reserves throughout May during the utility’s spring maintenance outages, Swan reported.

Swan said three separate contingency events occurred during the month while MISO cleared the utility’s 150-MW share of contingency reserves. The RTO stopped carrying Manitoba’s reserves May 29, when the Canadian utility’s dams returned from the outages that reduced its transfer capability. (See MISO to Make Up Manitoba Hydro Reserves During Spring Outages.)

— Amanda Durish Cook

June 6, 2017

LaFleur Ready to Welcome New Members as FERC Backlog Grows

By Rich Heidorn Jr.

CARROLL, N.H. — Acting FERC Chair Cheryl LaFleur expressed relief Monday that the restoration of the commission’s quorum is within sight.

FERC cheryl lafleur NECPUC — LaFleur | © *RTO Insider*

“What we know for sure is we’ll have a different FERC at the end of 2017 than we did going into the year,” LaFleur told the New England Conference of Public Utilities Commissioners’ (NECPUC) 70th Annual Symposium at the Omni Mount Washington Resort.

The Senate Energy and Natural Resources Committee is scheduled to vote June 6 on approving nominees Robert Powelson and Neil Chatterjee to two Republican vacancies on the commission. The committee questioned the two nominees at a mostly cordial hearing May 25. (See No Fireworks for FERC Nominees at Senate Hearing.)

In addition, LaFleur said, there are “rumblings” that Trump will name a Democrat to replace Commissioner Colette Honorable along with a third Republican nominee.

The five-member commission has been without a quorum since February, when then-Chairman Norman Bay resigned after President Trump stripped him of the chairmanship and promoted LaFleur.

LaFleur said the commission has issued only a fraction of the 100 commission-authorized orders it averages a month. Without a quorum, FERC staffers have been able to issue only delegated orders. Contested dockets and rulemakings have been at a standstill.

“So we are piling up quite a few cases for potential voting when [new] folks come in,” LaFleur said. “On some of these bigger policy issues … it’s not a matter of striking up an order. We’re looking to shape the policy choices in as transparent a way as possible for the incoming commissioners.

“We do have several dozen open rulemakings or generic dockets … multiple rulemakings on price formation in the electric markets, interconnection rules, [the Public Utility Regulatory Policies Act], hydro licensing terms, taxation [and] master limited partnerships in the pipeline area are some of the big ones that come to mind.

“But nothing’s higher on the mind than the issue du jour of harmonizing wholesale market rules and state policy initiatives,” she added, citing an issue that was the subject of a two-day technical conference in May. (See RTO Markets at Crossroads, Hobbled FERC Ponders Options.)

LaFleur said Trump’s decision to pull the U.S. from the Paris Agreement “could only accelerate the extent to which climate policy is increasingly being made in the states.” More than a dozen states — including Connecticut, Massachusetts, Rhode Island and Vermont in New England — have joined the U.S. Climate Alliance, with pledges to meet the Paris commitments on carbon emission reductions. (See related story, Trump Pulling U.S. Out of Paris Climate Accord.)

“There always seems to be one topic that sucks a lot of the air out of the room. I remember back when it was integrated resource planning and whether it worked. When I first came to FERC it was demand response,” she said. “Well now it’s this. … I do think this is one of the bigger things that FERC will be facing when FERC reconstitutes itself.”

Powelson, a member and former chair of the Pennsylvania Public Utility Commission, is the current president of the National Association of Regulatory Utility Commissioners. Chatterjee, of Kentucky, is a senior energy policy adviser to Senate Majority Leader Mitch McConnell (R-Ky.).

Assuming the nominees clear the committee vote, how soon they join the commission will be dependent on when their nominations are scheduled for a Senate floor vote.

The commission canceled its open meeting for June 20, as it has all previous meetings since February. The July 20 meeting is still listed on FERC’s calendar.

LaFleur repeated her promise to remain on the commission until the expiration of her term in June 2019.

“I’m very optimistic that we will keep the bipartisan and collegial tradition that has really characterized the commission. I think cultures are slow to change. There’s a lot of swirl in Washington right now, but I believe that FERC is very strong.”

June 6, 2017

FERC Staff Says 2-Year Hydropower Licensing Feasible

By Jason Fordney

Developers of certain hydroelectric projects can feasibly get federal approval within two years under current regulations, FERC staff said last week.

With the passage of the Hydropower Regulatory Efficiency Act of 2013, Congress directed FERC to study the feasibility of implementing a two-year process for issuing hydropower licenses to non-powered dams and closed-loop pumped storage projects.

After conducting a pilot program, FERC staff determined the time frame is doable, noting that “site selection, a well-defined project proposal, thorough pre-filing consultation and a complete application” are the most important elements.

Staff said that updating and improving the “small/low-impact hydropower” portion of its website would expedite the process.

“Staff also commits to providing more frequent processing updates, when appropriate, to provide additional clarity and certainty during the licensing process,” the report said.

Eligible projects under the program were required to be at a non-powered dam or closed-loop storage project, have a well-developed proposal, result in little environmental impact and be in areas with substantial information on environmental resources and effects.

FERC staff determined in August 2014 that Rye Development’s Kentucky Lock and Dam No. 11 project met the criteria and issued the project a license in May 2016. The 5-MW capacity project will generate about 19,000 MWh annually.

FERC hydropower licensing — Kentucky Dam and Lock 11 Hydropower Project | *Rye Development*

Staff also examined processing times for 83 projects that were issued licenses or small hydropower exceptions between 2003 and 2016. Evaluations of 28% of these projects were completed in two years or less, with a median processing time of 1.4 years. Projects that were not licensed in two years tended to be larger, more complex and had more issues to examine.

A majority of commenters agreed the pilot was a success and that it is feasible to implement a formal two-year licensing program, staff said. Changes to the Federal Power Act are not required, but factors outside of FERC’s control, such as the actions of other agencies, could affect permitting timelines, according to the report.

June 6, 2017

FERC Nominees Easily Advance to Full Senate

The Senate Energy and Natural Resources Committee voted 20-3 Tuesday to advance Neil Chatterjee and Robert Powelson, President Trump’s nominees for FERC.

Natural Resources Committee FERC Neil Chatterjee — Senate Energy and Natural Resources Committee

Sens. Ron Wyden (D-Ore.), Bernie Sanders (I-Vt.) and Mazie Hirono (D-Hawaii) voted no.

“Both FERC nominees failed to commit to avoiding political interference from the White House or maximizing public engagement in proposed energy projects,” Wyden said. “Given FERC’s important role in energy infrastructure in Oregon and communities across the country, I am also concerned that nominating commissioners from only one political party is a signal from the White House that it has no intention of ensuring FERC continues as the bipartisan and independent agency it has long been. I will continue to insist FERC considers local voices in its decisions and that the administration moves beyond politics to keep FERC bipartisan and independent.”

Otherwise, the nominees received bipartisan support.

“I am assured both have understood the important role that FERC plays in ensuring fair markets and guarding against market manipulation,” said Sen. Maria Cantwell (D-Wash.), the committee’s ranking member.

This prompted Ted Glick, of environmental group Beyond Extreme Energy, to interrupt the meeting with shouts of protest against FERC. The hearing was interrupted two more times.

The committee also advanced Trump’s nominees for deputy secretary of energy and deputy secretary of the interior, Dan Brouillette and David Bernhardt respectively, mostly on party line votes. The committee voted 17-6 for Brouillette and 14-9 for Bernhardt.

(See LaFleur Ready to Welcome New Members as FERC Backlog Grows.)

— Michael Brooks

June 5, 2017

NYISO Management Committee Briefs

RENSSELAER, N.Y. — NYISO and adjacent grids will likely be able to serve load throughout summer based on historical performance of generation and transmission infrastructure, the ISO reported last week.

However, an unlikely scenario of extreme heat could pose challenges for system capacity reserves, if not the system itself, according to the ISO’s Summer 2017 Capacity Assessment.

Under a baseline scenario in which this summer’s load peaks at 33,178 MW, NYISO expects to have a capacity margin of 386 MW, down 746 MW from the 2016 baseline forecast. The positive margin represents the amount of surplus generation available after factoring in peak load plus a required 2,620 MW of operating reserves.

Under extreme weather conditions — the 90th percentile forecast — the ISO predicts a capacity shortfall of 1,924 MW, compared with a 1,191-MW shortfall in last summer’s forecast.

“That’s taking the 90th percentile peak forecast, which is a very large peak, adding 2,620 of reserve requirement, saying that’s the requirement on a day-ahead basis, and then comparing it to that available capacity,” Wes Yeomans, NYISO vice president of operations, said during a May 31 meeting of the Management Committee.

Despite the expected deficiency under those conditions, the ISO expects it could avoid involuntary load curtailments by relying on up to 3,083 MW of demand resources available under emergency procedures.

NYISO activated demand response during its all-time summer peak of 33,956 MW in July 2013, which would have hit 34,900 MW without DR, Yeomans said.

NYISO Management Committee regulated transmission — | *NYISO*

Yeomans explained that the 90th percentile projection slightly exceeds NYISO’s all-time high. For an extreme heatwave, the capacity requirement would reach 38,000 MW.

“If we compare that against the capacity resources assuming 4,800 MW of derates — and we may or may not have that amount in a very hot heatwave — on paper we would be short on capacity by about 1,900 MW … but we have at least 3,000 MW of emergency operating procedures we would activate to make up that difference,” he said. (See New York Geared for 2017 Summer Load.)

MC Approves Funding 2nd PAR at Ramapo

The Management Committee approved a Tariff modification to fund Consolidated Edison’s replacement and operation of the Ramapo 3500 phase angle regulator, destroyed in a fire last June, as well as the operating expenses for the existing PAR at the substation close to the New Jersey border. The estimated $5.5 million in annual costs will be allocated statewide across all New York load-serving entities, but they would be reimbursed with any monies eventually paid by PJM, PJM transmission owners or refunded by Con Ed.

Mark Younger of Hudson Energy Economics asked for a definite commitment from either Con Ed or NYISO on the timeline for installation.

Jane Quinn of Con Ed said that upon an affirmative vote, the company will begin moving the PAR into place, which should take three to four weeks. Installation should take an additional eight to 10 weeks.

“We anticipate having the PAR, absent contingencies, in place on or around September 15,” Quinn said. (See “Con Edison Gets Approval to Install 2nd PAR at Ramapo,” NYISO Business Issues Committee Briefs.)

Market Participants to Review Monitor’s Performance

Shaun Johnson, NYISO director of market mitigation, asked market participants to join in an annual review of the Market Monitoring Unit’s performance.

NYISO last year signed a three-year contract with Potomac Economics to perform monitoring functions through March 31, 2019. The MMU’s duties include ensuring that the markets administered by NYISO function efficiently and appropriately, as well as identifying market violations, market design flaws and market power abuses. The Monitor also produces annual and quarterly State of the Market reports assessing the performance of the New York electrical markets.

The budget for the MMU for 2017 is $3.5 million, up $400,000 over last year. Most of the additional costs cover additional work related to cybersecurity and new requirements mandated by reliability-must-run and FERC Order 1000 filings.

One participant said that Potomac sometimes shows up at FERC and protests what NYISO is doing.

“Something just seems at odds there, that we’re paying a company $3.5 million a year and we’re fighting with them at FERC,” he said.

Such action is part of the duties of an MMU, according to NYISO, and one thing FERC cited in a recent review of the SPP Monitor was the lack of reporting on disagreements with the grid operator.

Tariff Changes on Tx Cost Recovery

The Management Committee approved proposed Tariff revisions to add a mechanism to recover and remit costs associated with regulated transmission projects eligible under the ISO’s Congestion Assessment and Resource Integration Study or the public policy transmission planning process. Following board approval in July, the revisions to the cost recovery mechanism for regulated transmission projects under Rate Schedule 10 — and related amendments to the Tariff’s Attachment Y — would be filed with FERC under Section 205 of the Federal Power Act.

The Rate Schedule 10 revisions establish a new regulated transmission facilities charge (RTFC) to LSEs, with payments allocated to developers of such projects.

John P. Buechler, NYISO regulatory policy adviser, said the revisions do not in any way “affect or change the cost allocation provisions, which, relevant to our transmission planning process, are in Attachment Y, Section 31.5.”

Eligible projects include:

Regulated backstop transmission solutions proposed by a responsible transmission owner;
An alternative solution NYISO selects as a more efficient or cost-effective solution to a reliability need;
A regulated transmission gap solution proposed by a responsible TO;
An alternative regulated transmission gap solution determined by an appropriate state regulatory agency;
An approved regulated economic transmission project;
A public policy transmission project selected by NYISO;
Costs incurred by a developer in preparing a proposed transmission solution in response to a request by the Public Service Commission or Long Island Power Authority; and
The portion of an interregional transmission project selected by NYISO in the Comprehensive System Planning Process that is allocated to the NYISO region.

NYISO will calculate and bill an RTFC separately for each eligible project.

NYISO to Enhance Buyer-side Mitigation

The committee approved proposed Market Services Tariff changes to improve inflation forecasting and how mothballed units are treated in the capacity and energy forecast used to make buyer-side mitigation determinations.

The committee recommended that the Board of Directors authorize revisions to buyer-side mitigation rules in the Market Services Tariff, which would then be filed with FERC under Section 205 of the Federal Power Act.

In FERC docket ER13-1380, filed in 2013 to create NYISO’s G-J locality, the commission determined that such an enhancement was outside the scope of the docket but encouraged the ISO to work with stakeholders on the issue.

NYISO analyst Lorenzo Seirup presented the rationale for mitigation enhancements and said that, since the topic first arose in 2013, “we discussed this ad nauseam and also had a vote that failed and then a vote that passed — that’s the 30-second highlights.”

The proposal would include in the forecasts existing units as well as additional units, “which is the more complicated” category, Seirup said. Units that would be excluded are those transferring their capacity resource interconnection service (CRIS) or that have expired CRIS.

Additional units include mothballed facilities, units under forced outages, retired units and those in similar condition with unforced capacity deliverability rights. These additional units either must have CRIS or show positive indicators of repair or have a new present value greater than $0 in the “inclusion test” performed for resources that have the ability to re-enter the market under more favorable conditions.

The Tariff changes on inflation would call for use of the most recently published 10-year inflation projections from the Survey of Professional Forecasters, or if no longer available, a similar source to identify net cost of new entry projected for the mitigation study period, and the price on the installed capacity demand curve projected for such a period.

— Michael Kuser

June 5, 2017January 15, 2024

SPP Advances KCPL Cost Shift Proposal

By Tom Kleckner

DALLAS — SPP’s Strategic Planning Committee last week ended more than nine months of discussion on cost shifts within existing transmission pricing zones, agreeing unanimously to let the Markets and Operations Policy Committee take up the issue when it meets in July.

The agreement represented a victory of sorts for Kansas City Power & Light’s Denise Buffington, who has drafted a revision request that would create a process for choosing the zone for a new SPP transmission owner’s facilities, and how to submit the TO’s annual transmission revenue requirement (ATRR) or formula rate to FERC for inclusion in the Tariff.

RR172 has been sidelined since October, when it was pulled from the Regional Tariff Working Group (RTWG) and placed on the SPC’s agenda for discussion. (See SPP Moves to Head off KCP&L Measure on Tx Cost Shifts.)

While Buffington will get her long-awaited up-or-down vote on the measure, she told RTO Insider she was still disappointed RR172 had been delayed and that KCP&L’s concerns about “unnecessary and unfair” cost shifts to existing TOs were not addressed.

“I expect a robust debate at MOPC,” she said. “But I expect the ultimate resolution will need to be addressed by FERC and, potentially, the courts.”

The committee, meeting at American Electric Power’s Dallas office, accepted a motion from Heather Starnes, legal counsel for the Missouri Joint Municipal Electric Utility Commission, to conclude the discussion as it became apparent stakeholders would not agree on anything beyond directing staff to use a process document to codify previously approved steps for notifying affected parties of zonal placement decisions. The communications process was approved when the SPC last met in April. (See No Consensus for SPP on Zonal Price Shifts.)

“It’s clear there are issues we can agree upon and issues we can’t agree upon,” Starnes said, reminding the committee that KCP&L’s proposal is still “technically” on the RTWG’s agenda. “Ending discussions of those issues allows RR172 to move directly to MOPC.”

SPP COO Carl Monroe stressed the need to provide a structure for the MOPC to debate KCP&L’s request, suggesting bringing the request up through the stakeholder process and the RTWG. Among Monroe’s concerns were having the MOPC vote on Tariff language that had not already cleared a working group.

Buffington noted RR172 includes proposed Tariff language that she said would be revised to include the discussions before the SPC.

“MOPC can vote on the Tariff language,” she said. “RR172 includes not just the policy issue, but Tariff language that solves the policy problem.”

American Electric Power’s Richard Ross, who seconded Starnes’ motion, pointed out SPP’s working groups don’t decide policy but recommend it.

“There’s only one group that decides policy. It stops at the board, or it goes all the way to FERC,” he said. “I’m all for letting KCP&L have their shot at the process. … Kansas City or John Doe or whoever submits a revision request has their right … to put it through the stakeholder process. They shouldn’t be put in limbo indefinitely. If KCP&L doesn’t get their way at MOPC, they can appeal it to the board.”

“It seems like a member has been allowed to bring an issue directly to MOPC before when a working group failed to approve a request,” said the Nebraska Public Power District’s Paul Malone, who also chairs the MOPC. “I would think that’s the case here too.”

Larry Altenbaumer, one of three SPP directors present at the meeting, weighed in on the issue as well. He advocated having RR172 presented to the MOPC, “where there’s better representation and broader membership.”

“MOPC can decide where it goes,” Altenbaumer said. “I don’t think sticking it in some working group is the right answer.”

“I want a policy decision from MOPC and the board,” Buffington said. “I want an up-and-down vote, where all members have an opportunity to vote on it. If the board ultimately approves it, or through modifications, my expectation is SPP will file it at FERC. … I would ask this group complete its work so I can move forward with my proposal.”

By codifying SPP’s zonal selection criteria in the Tariff, KCP&L says RR172 strikes a balance between attracting new transmission-owning customers to SPP and eliminating the ability for them to shift costs to existing members. The revision is intended to establish a bright line between the costs of legacy transmission and new facilities planned by SPP.

The SPC’s eventual agreement helped short-circuit a series of examples for how staff would handle zonal cost shifts under various scenarios. Staff’s suggestion that there was value in walking through six more examples following a lunch break left one stakeholder wide-eyed and slack-jawed in apparent horror.

Staff has proposed zonal-placement criteria that included:

- - Whether the facilities’ ATRR is less than the minimum zonal ATRR;
  - The extent to which the facilities substantively increase the SPP footprint; and
  - The extent to which the load served by the transferring facilities received network or long-term, firm point-to-point (PTP) service within existing zones before the transfer.

If not placed in a new zone, the facilities would be placed in an integration zone according to:

- - The extent to which the facilities are embedded within an existing zone;
  - The extent to which the facilities are already integrated with an existing zone; and
  - The extent to which the load served by the transferring facilities received network or long-term, firm PTP service within each existing zone prior to the transfer.

Staff will continue working on assessments to determine whether a new member’s facilities meet minimum system reliability requirements, and whether they are similar in design to the integration zone’s facilities and are eligible for inclusion in the existing zonal TO’s ATRR.

June 5, 2017

MISO Asks FERC for Pseudo-Tie Technical Conference

By Amanda Durish Cook

CARMEL, Ind. — MISO is asking FERC to schedule a technical conference to clarify the rules governing the implementation and use of pseudo-ties.

The RTO made the request in a May 26 filing under two dockets: PJM’s proposal to apply more stringent requirements on external capacity resources (ER17-1138) and MISO’s proposed pro forma pseudo-tie agreement (ER17-1061). FERC sent deficiency notices seeking more information in response to both initiatives.

MISO said a technical conference could “provide a foundational understanding of pseudo-ties, their application, and the challenges they pose” and help FERC “better understand the benefits of pseudo-ties, the potential impacts pseudo-ties have on reliability and efficiency of market operations, and the current status of coordination between neighboring RTOs.”

pro forma pseudo-tie agreement miso ferc — Zwergel | © *RTO Insider*

“We talked about these things for two years now, and there are still questions,” MISO Senior Director of Regional Operations David Zwergel said at a June 1 Reliability Subcommittee meeting.

MISO’s Independent Market Monitor, who wants FERC to eliminate PJM’s requirement that external resources be pseudo-tied, joined in the call for a technical conference. “What we would like the technical conference to make clear is … there are potential alternatives that should be considered to pseudo-ties. What we hope comes out of this conference is a full hearing of the cost and the benefits,” said Michael Wander of IMM Potomac Economics.

The request comes as PJM and MISO are still working on draft joint operating agreement changes to create a standard pseudo-tie definition and rule set. (See MISO, PJM to Try Again on FERC Pseudo-Tie Filings.)

The joint language, which has not been released to stakeholders, will remove the need for MISO to sign off on PJM’s proposed pro forma pseudo-tie agreement. Late last year, MISO staff said there was no need to write standardized pseudo-tie definitions into the RTOs’ JOA; by early spring, the RTOs had agreed to add coordinated pseudo-tie policies to their JOA.

Zwergel said MISO is hoping to file the JOA in the next few months. “Good progress has been made,” he said.

While it awaits FERC’s decision on a technical conference, MISO will respond to the deficiency letter on its pro forma filing by June 12, he said.

June 5, 2017

NESCOE Defends Role in Identifying Public Policy Tx Needs

By Michael Kuser

State officials in New England said last week that only they should have the ability to identify public policy-driven transmission needs for evaluation by ISO-NE.

“The plain language of [ISO-NE’s Tariff] designates NESCOE as the entity that identifies whether there are state or federal public policies driving transmission needs and, in turn, whether a public policy transmission study should be commenced to evaluate potential solutions,” the New England States Committee on Electricity said in a June 1 rebuttal to the Conservation Law Foundation.

CLF Senior Attorney David Ismay asked ISO-NE on May 16 to conduct a study to determine public policy transmission needs despite NESCOE’s contention that there are currently no such needs. (See CLF to ISO-NE: Override States, Order Public Policy Tx Study.)

Ismay said a D.C. Circuit Court of Appeals ruling in April confirmed the responsibility of ISO-NE, “not the states, to evaluate transmission needs and potential solutions as part of its Regional System Plan process, regardless of whether those transmission needs arise from state public policy requirements or any other source” (Emera Maine v. FERC, No. 15-1139). (See Court Rebuffs New England TOs, Upholds FERC ROFR Order.)

Misreading of Order 1000

NESCOE responded that “CLF misunderstands the Order 1000 process … and has conflated the process for evaluating solutions to policy-driven transmission needs with the process of identifying if there are any needs in the first place. Emera imposes no requirements on ISO-NE to determine public policy requirements driving transmission needs and directed no changes to the [Open Access Transmission Tariff].

“CLF mistakenly claims that Emera requires ‘ISO-NE to make its own determination … regarding the existence of [public policy requirements] that are driving, or may drive, transmission needs relating to the New England transmission system.’”

NESCOE said that ISO-NE’s rules on the identification of policy needs have never been in controversy, were not before the court and that FERC itself had affirmed to the court NESCOE’s role in that process. “If anything … Emera affirms the process reflected in the current OATT whereby NESCOE must first identify a state policy driving a transmission need before ISO-NE begins expending consumer dollars on evaluating a need. As Emera plainly states, ‘ISO-NE has no role in setting public policy for the states.’”

The organization closed its response by bemoaning CLF’s request as “precisely the kind of after-the-fact market participant action that causes the states serious pause in using a FERC-jurisdictional tariff to achieve their clean energy requirements.”

ISO-NE Director of Transmission Planning Brent Oberlin had told the Interregional Planning Stakeholder Advisory Committee for New England, NYISO and PJM on May 19 that if the RTO decides to conduct a public policy transmission study, it will need to provide a scope to stakeholders by Sept. 1.

June 2, 2017

California Senate Passes Bill Mandating 100% RPS

By Robert Mullin

California has moved a step closer to adopting a 100% clean energy standard.

The State Senate on Wednesday passed a bill that would require California load-serving entities to obtain all of their electricity deliveries from renewable resources by 2045 (SB 100).

california renewable portfolio standard rps — de León

Sponsored by Senate President pro Tempore Kevin de León, a Los Angeles Democrat, the bill passed 25-13 along party lines. It now moves to the State Assembly.

“When it comes to our clean air and climate change, we are not backing down,” de León said in a statement. “Today, we passed the most ambitious target in the world to expand clean energy and put Californians to work.”

De León said it is now critical for California to “double down on climate leadership” given President Trump’s announcement today that the U.S. would withdraw from the Paris Agreement on climate change. (See related story, Trump Pulling U.S. Out of Paris Climate Accord.)

“We are sending a clear message to the rest of the world that no president, no matter how desperately they try to ignore reality, can halt our progress,” he said.

The new bill would accelerate the timeline for California’s current 50% RPS from 2030 to 2026, with an interim 45% goal put in place for 2023. The 2030 requirement would increase to 60%, and the bill gives the California Energy Commission discretion to establish “appropriate” three-year compliance periods subsequent to 2030.

The bill also directs state agencies to incorporate the planning goal into any energy and climate programs subject to their jurisdiction, which would include the utility integrated resource plans administered by the PUC.

Passage of the bill got expected support from environmental groups and advocates for renewable energy.

“Getting 100% renewable is 100% possible and 200% necessary,” said Kathryn Phillips, director of Sierra Club California. “SB 100 responds to what survey after survey shows that Californians want: clean energy, clean air and a future for the next generation.”

Strela Cervas, co-director of the California Environmental Justice Alliance, said the proposed law would move California away from fossil fuels that that have a disproportionate impact on disadvantaged communities and communities of color.

“The bill charts a pathway for the public health and economic benefits of local renewable energy to reach communities that need it the most,” Cervas said.

“Transitioning to a 100% carbon-free future in an economy the size of California’s requires persistence, commitment and vision,” said Bernadette Del Chiaro, executive director of the California Solar Energy Industries Association.

renewable portfolio standard — Solar Field | *Sunworks*

In urging his colleagues to vote against the bill, Republican Sen. Jeff Stone warned that the state might be getting ahead of its ability to actually implement a 100% RPS.

“If we don’t have the science to back up the methodology to get to 2030 with 60% coming from renewables, then it’s going to increase costs for our constituents,” Stone said. “We need to let the technology drive the innovations in alternative energy and not put mandates out there that may be unachievable.”

If it becomes law, the bill would make California the second state after Hawaii to require LSEs to rely on 100% renewables by 2045.