NY Task Force Examines Carbon Pricing Market Impacts

By Michael Kuser

The impact of a carbon price would likely reverberate throughout New York’s wholesale electricity markets, industry experts said Monday.

Carbon pricing could be “a real game-changer in terms of likely impacts on the market,” Couch White attorney Michael Mager said during a June 18 meeting of the state’s Integrating Public Policy Task Force (IPPTF), the group charged with exploring how to price emissions into NYISO’s markets. Mager represents a coalition of large industrial, commercial and institutional energy customers.

During the meeting, NYISO presented its proposed approach to analyzing the effects of a carbon charge on various wholesale market processes, including its Installed Capacity (ICAP) market and related demand curve reset.

NYPSC demand curve reset carbon price ipptf
| NYSEG

NYISO may have to adjust ICAP rules to reflect carbon pricing if it believes the carbon charge is not appropriately reflected in prices, said ISO staffer Nathaniel Gilbraith.

Capacity prices are generally expected to make up for “missing money” from the energy market, and it’s important for capacity rules to capture relevant energy market revenues when setting prices, Gilbraith said.

Issue of Timing

The ISO’s estimation of the energy and ancillary services revenue offset is a key component of its annual process for updating its demand curve. (See FERC OKs NYISO Demand Curve Reset.) But Mager pointed out that if the ISO’s annual update considers only rolling historical revenues and neglects to factor in carbon prices, it will miss the mark.

“One issue is timing. If carbon pricing is implemented, when is it implemented vis a vis the demand curve reset process?” Mager said. “The second is how do you deal with the [energy and ancillary services] revenues in light of a dramatic change like this.”

Power Supply Long Island Director of Wholesale Market Policy David Clarke said, “We would prefer the demand curve to ramp smoothly … consistency would be sensible with what’s assumed in the [locational-based marginal price] and what’s assumed in the bid for demand curve reset purposes.”

Transmission Planning

Ethan Avallone, NYISO senior market design specialist, explained that the ISO performs economic analyses of new transmission facilities in its Congestion Assessment and Resource Integration Study (CARIS) studies and as needed for its Public Policy Transmission Needs Planning Process. Those analyses include production cost simulations and already account for the Regional Greenhouse Gas Initiative price, and would similarly incorporate the carbon charges on suppliers, he said.

Representing New York City, Couch White attorney Kevin Lang said, “We don’t really build transmission on a CARIS basis or on an economic basis in this state, and I’m not sure when — or if — we ever will. … So in terms of priorities, this is a much lesser issue than grappling with the demand curve.”

“If you’re accounting for RGGI you should be accounting for the carbon price; that just makes sense,” Lang said. “From our view, we’d like to see the transmission response of how we’re going to encourage more transmission to be built, and I don’t know whether that’s economic, or whether it’s public policy, or potentially reliability planning.”

Clarke said there is a potential disconnection between the marginal carbon component price in the LBMP and the actual change in carbon emissions associated with a new transmission line.

“For example, suppose wind is on the margin before and after a transmission line is added, but the line also unbundles some additional wind that can be added into the market,” Clarke said. “There would be a circumstance where you don’t have a price difference associated with that — the marginal unit hasn’t changed — but you have changed the amount of low carbon resources that are able to enter the market. The change in the carbon may not be reflected in the marginal price.”

IPPTF Chair Nicole Bouchez, the ISO’s principal economist, said such deep transmission planning “is probably a bit beyond what we’re doing here,” adding that the group is “just looking at the impact of a carbon price on the market, not evaluating different transmission opportunities and what the consequences of them are in a carbon adder world.”

Customer Impacts

Timothy Duffy, the ISO’s manager for economic planning, presented three separate planning scenarios. The first case — the reference case — was modeled for three different years (2020, 2025 and 2030), and the remaining two for 2030 only.

The reference scenario presumes 226 MW of offshore wind by 2020, with the state’s full commitment of 2,400 MW calculated into the 2025 and 2030 iterations. All scenarios consider coal plants retired and include western New York and generic AC transmission upgrades.

The scenarios vary on the nuclear component, considering that Indian Point will retire in stages over 2020/21, and that the state’s zero-emission credits supporting nuclear will expire in 2030.

Erin Hogan, representing the Department of State’s Utility Intervention Unit, asked what would happen in 2023 when Indian Point will be retired and the AC upgrade will not yet be completed.

“We didn’t feel that there would be much information gleaned from that particular scenario that wouldn’t be gleaned from running, for example, 2025 with both high and low energy loads,” Duffy said.

The ISO’s broad analysis “captures the bookends of what would be the LMP impacts [and] load-shaving impacts associated with a carbon price,” Duffy said.

Hogan disagreed.

“People talk about price signals, and then the reality is that people have choices with price signals,” Hogan said. “If we are going to have a year with exceptional high price signals with the congestion, not having [Indian Point] and not having the AC transmission, we need to know that. That could go beyond what you’re characterizing as the high load scenario.”

Catch-22

Lang questioned the ISO’s professed need to fit the carbon price analysis into “the allotted time frame.”

“There’s no Tariff requirement, there’s no statutory requirement for that, and we’ve had lots of other cases where things have been delayed because the analysis takes longer than expected,” Lang said.

“I’m extremely troubled that we’re looking at something that could have a very significant consumer impact — we don’t know yet because we haven’t seen the analysis — and all I keep hearing from the ISO is ‘we can’t do the broad analysis that folks are asking for because we don’t have the time to do it.’”

Duffy said the situation was a catch-22.

“You’re telling us that you need to know the results of the analysis before you can decide to move forward, but you’re not letting us get the analysis because we’re debating the assumptions we would use in the analysis,” Duffy said. “We’re trying to get to the point where actually we can run the analysis and present the results.”

If at that point there’s a consensus to continue the analysis, “that’s fine, but please let us get to the point where we start presenting results so we can start talking about those as opposed to what-ifs and maybes,” he said.

The task force next meets July 9 at NYISO headquarters.

Louisiana Regulators Approve AEP’s Wind Catcher Project

By Tom Kleckner

American Electric Power on Wednesday announced that Louisiana’s Public Service Commission has approved its proposed mammoth Wind Catcher Energy Connection project.

AEP’s Louisiana operating company, Southwestern Electric Power Co., would own 70% of the $4.5 billion project, a 360-mile, 765-kV line to Tulsa from a 2-GW wind farm being built by Invenergy in the Oklahoma Panhandle. AEP affiliate Public Service Company of Oklahoma would own the other 30%. The two utilities would purchase the wind facility upon its completion, scheduled for the fourth quarter of 2020.

AEP’s Wind Catcher site | Invenergy

SWEPCO agreed to a cap on construction costs, qualification for 100% of federal production tax credits and minimum annual production goals, among other commitments.

“Wind Catcher is a major investment in clean energy that will produce long-term savings for Louisiana customers and further diversify our energy resource mix,” AEP CEO Nick Akins said in a press release. “The Louisiana Public Service Commission’s decision recognizes the benefits Wind Catcher will bring to Louisiana customers.”

AEP Wind Catcher Project LPSC
Galvez Building housing the Louisiana Public Service Commission | LA.gov

AEP says it expects to save its customers more than $4 billion over the 25-year life of the wind farm, primarily through a reduction in the fuel portion of their bills that begins in 2021.

The PSC joined Arkansas regulators in approving the project. The Oklahoma and Texas commissions have yet to weigh in, but AEP appears to face longer odds before those two agencies.

The head of the Oklahoma Corporation Commission’s Public Utility Division and the state’s attorney general have indicated in regulatory filings that they remain opposed to the project, and landowner opposition to the transmission line has been running high. The OCC has scheduled a public comment hearing for July 2.

Texas’ Public Utility Commission staff has disagreed with an administrative law judge’s preliminary decisions approving Wind Catcher, saying “the evidence presented does not support a sufficient probability of improvement of service or lowering of costs to ratepayers.”

Staff recommend that the commission condition its approval on a requirement that SWEPCO guarantee tax credits in the amounts represented by the utility, and that it guarantee some level of net benefits to customers over and above the annual revenues that customers are obligated to pay for the project’s base rate costs. The PUC will take up the issue at its July 12 open meeting (Docket No. 47461).

Lott, Breaux Join Push for Baker-Schultz CO2 Dividend Plan

By Rich Heidorn Jr.

Former Senate Majority Leader Trent Lott (R-Miss.) and former Sen. John Breaux (D-La.) have joined a new organization to build political support for the carbon dividend proposal offered last year by Republican party elders James A. Baker III and George P. Schultz.

carbon dividends trent lott john breaux
Lott | Bipartisan Policy Center

Lott and Breaux are co-chairing the advisory board of Americans for Carbon Dividends, which announced itself Wednesday with financial backing from Exelon, First Solar and the American Wind Energy Association, along with a poll it said shows wide bipartisan support for the Baker-Schultz proposal.

Baker and Schultz’s Climate Leadership Council, formed last year, proposed a carbon fee of $43/ton starting in 2021 that would return the funds to Americans as monthly dividends. Backers say the plan would provide net payments to 70% of Americans while reducing emissions more than the U.S. commitment under the Paris Agreement.

Escalating the fee by 3 to 6% per year would reduce carbon emissions by 34 to 36% from 2005 levels by 2025, they say, and eliminate the need for existing carbon regulations such as the Clean Power Plan. (See Baker’s Carbon Dividends Plan Reaches Across Aisle.)

A carbon fee beginning at $43/ton in 2021 and escalating at 4% annually would reduce emissions by 32% from 2005 levels. | Climate Leadership Council

“This is the inevitable climate solution and the most likely to lead to a grand bipartisan climate compromise,” said Hill+Knowlton Strategies Managing Director Richard Keil, the newly formed group’s spokesman in a press conference Wednesday. Keil noted that former Federal Reserve Chairs Ben Bernanke and Janet Yellen and former EPA Administrator Christine Todd Whitman have signed on to the plan as founders of the CLC.

Keil said the new group was formed to signal the move to an “inside the Beltway strategy” after the CLC spent last year on policy development and working outside the Beltway.

carbon dividends trent lott john breaux
Breaux | Squire Patton Boggs

Breaux acknowledged Congress is unlikely to embrace the plan any time soon. “This is an educational program that we’re embarking upon … which means we will be talking to leaders in the Congress in both parties. … This is not a sprint. It’s going to be a marathon.”

“I think that both parties are desperate … to find something that they can agree on,” he added.

“I took quite some time to look at this issue and think about it,” Lott said. “I’m convinced this is the solution that we have been looking for as a country and, frankly, in the world.”

Ted Halstead, CEO of the carbon dividends group and the CLC, said Republicans’ views on climate change have shifted over the last five years. “[There’s] no real differences numerically between where younger Republicans and younger Democrats are on this. I don’t want to overstate it because I don’t have a side-by-side comparison of numbers to do this, but it at least in general reminds me about how … attitudes within the Republican Party shifted on issues like gay marriage over the last 10 years. The next generation of Republicans thinks about these and other things differently than some of their older peers.”

The group released a poll showing 81% of likely voters, including 71% of moderate Republicans and 58% of conservative Republicans, agree the government should act to limit carbon emissions. It said the tax-and-rebate strategy is favored by a 2:1 margin overall.

“Members of Congress pay attention to polls,” Breaux said.

In addition to bringing on Hill+Knowlton to handle communications, Americans for Carbon Dividends has hired Squire Patton Boggs — where Lott and Breaux are senior counsels — as lobbyist and Margaret Lauderback, an ally of Rick Perry and House Majority Leader Kevin McCarthy, to lead fundraising. Political consultant Mark McKinnon, a former advisor to Sen. John McCain (R-Ariz.) and former President George W. Bush, and Joe Lockhart, White House press secretary under President Bill Clinton, have signed on as senior advisers. Former Bush aide Karen Hughes is of counsel.

Senate Committee Advances CAISO Regionalization Bill

By Jason Fordney

SACRAMENTO, Calif. — A California State Senate committee advanced a bill Tuesday that would allow CAISO to be transformed into a Western RTO, a major change in the electricity market that has been met with heavy opposition.

Sponsored by State Assemblyman Chris Holden (D), AB813 garnered the six necessary votes in the Senate Energy, Utility and Communications Committee to move on to the Judiciary Committee for review. The Assembly approved the bill on June 1, and with Gov. Jerry Brown a strong supporter of regionalization, the bill is likely to get his signature if approved on the Senate floor.

Holden, second from right, discusses AB813 with committee Chairman Ben Hueso, second from left. | © RTO Insider

Proponents say the law would help the state export excess renewable energy and create a more efficient regional market, lowering costs.

“This is an opportunity for California to expand our good policies across state borders and to expand upon that,” Holden told the committee. The recently amended bill was carried over from last year’s session. (See Calif. Energy Bills Move Forward, but Big Ones Stall.)

The bill creates a Western States Committee with three representatives from each state with a participating transmission owner, which would provide input on RTO matters that affect more than one state. Left open is the question of whether state voting power would be weighted by electricity load. It also specifically prohibits the creation of a capacity market.

But memories of California’s 2000/01 electricity crisis remain strong in the state, and many interests have expressed concerns about increased oversight of the market by the federal government. CAISO is already regulated by FERC, but some worry California would lose control of clean energy goals to the federal government and other states.

caiso regionalization western RTO

Hertzberg | © RTO Insider

Committee member Robert Hertzberg (D) said that he “generally likes the notion of regionalization” but added that “I am very unhappy as to how this bill has proceeded.” He said he had many concerns about repeating the mistakes of the electricity crisis and negatively affecting the economy by moving jobs out of the state.

“There is an underlying issue that is legitimate with respect to California jobs,” Hertzberg said. “I am deeply concerned across the board.”

The bill has a long list of opponents, including labor groups worried about exporting energy-related jobs to other states and environmental groups, such as Sierra Club and Earthjustice, who say the changes will make California subject to imports of fossil-sourced generation. More than 12 California cities, the Port of Oakland, Sacramento Municipal Utility District, the Utility Reform Network and other groups oppose regionalization.

Former FERC Chairman Jon Wellinghoff addressed the committee, attempting to ease fears about the commission’s oversight. Wellinghoff said FERC acts independently, pointing out it recently dispensed with the Department of Energy’s proposed Grid Resilience Pricing Rule.

caiso regionalization western RTO

Sen. Henry Stern asks former FERC Chairman Jon Wellinghoff about federal jurisdiction over California. | © RTO Insider

“They are really going after PJM … where most of these coal plants reside,” he said of the Trump administration’s effort to bolster coal.

While the regionalization debate continues, CAISO has proposed bringing its day-ahead energy market to the Western Energy Imbalance Market. That measure would allow more energy trading across the region but does not create a new RTO with new multi-state management as envisioned by AB813. (See CAISO Day-ahead Could be Tailored for the West.)

Salem Harbor Plant Facing FERC Action

By Michael Kuser

FERC on Monday ordered Footprint Power to refute a finding that the company violated ISO-NE Tariff rules and federal regulations by filing “false and misleading supply offers” for its Salem Harbor Power Plant in June and July 2013.

Footprint has 30 days from the June 18 order to show cause why it should not forfeit $2,049,571 in Capacity Supply Obligation (CSO) payments for a period during which FERC’s Office of Enforcement staff found that Unit 4 at the plant could not provide capacity. The company must also demonstrate why it should not be assessed $4.2 million in civil penalties.

Footprint power salem harbor ferc
Salem Harbor Power Plant | Tetra Tech

Enforcement staff allege Footprint submitted supply offers that Unit 4 could not satisfy because Salem Harbor lacked usable fuel. Staff found the company not only failed to report the lack of fuel to the RTO but also “omitted material information from and/or misrepresented the fuel status of Salem Harbor and related operational status of Unit 4.”

Background

In 2012, Footprint bought Salem Harbor, a 748-MW coal- and oil-fired plant with four units, from Dominion Resources Services. Two units at the plant had been retired in 2011, while units 3 and 4 were operational at the time of purchase. Both units had a CSO for both ISO-NE’s Forward Capacity Auction 3 (FCA 3) Capacity commitment period (June 2012 through May 2013) and the FCA 4 commitment period (June 2013 through May 2014).

However, units 3 and 4 were scheduled to retire effective June 1, 2014, coincident with the start of the FCA 5 Capacity commitment period. Unit 3 was primarily a coal-fired unit and Unit 4 was a 437-MW oil-fired unit.

The units have since been demolished, and Footprint is now converting the plant to a 674-MW gas-fired, quick-start, combined-cycle generator, which is expected to go into service by the end of the year. (See “Future Locational Reserve Needs” in ISO-NE Planning Advisory Committee Briefs: June 13, 2018.)

The RTO had rejected earlier de-list bids to retire Unit 4 during FCA 3 and 4, citing reliability needs. In exchange for keeping the unit online and available, “Dominion was not paid the pro-rated capacity auction clearing floor prices in FCAs 3 and 4, but instead received the unit’s cost of service — which was approximately double the amount received by other ISO-NE capacity resources,” the commission noted.

Footprint subsequently collected CSO payments in the same amount awarded to Salem Harbor when Dominion owned the plant, which totaled about $4.4 million from June to July 2013.

Salem Harbor, at the time, had only one fuel storage tank that could hold roughly 200,000 barrels (bbl) of oil used to supply Unit 4. However, Footprint had also sold most of Salem Harbor’s fuel inventory back to Dominion, leaving only 40,000 bbl on site by December 2012, an amount the plant staff believed was less than two days’ worth of fuel.

Enforcement staff alleged that because Unit 4 burned between 14,000 and 16,000 bbl of fuel per day when operating, the plant’s managers were aware the remaining 40,000 bbl would not last longer than two days because only 29,000 bbl could be physically accessed from the tank.

‘Feasible’ Defense

ISO-NE’s internal Market Monitor alerted the commission to Salem Harbor Unit 4’s repeated inability to meet its CSO, also alleging “that false or misleading Day-Ahead (DA) supply offers and verbal communications were made to ISO-NE regarding Unit 4’s availability.”

In 2015, FERC staff and Footprint counsel discussed staff’s preliminary findings and Footprint’s claim that staff relied on assumptions rather than data to calculate Salem Harbor’s usable fuel inventory. Footprint claimed staff used the wrong data in its investigation, but “even after staff used the data source proffered by Footprint, use of that data source did not materially impact staff’s calculations,” said the commission.

In response, Footprint claimed Unit 4’s offers were “feasible” because the unit did not have to operate in accordance with its CSO due to certain environmental limitations on nitrogen oxide emissions.

In February 2018, after Footprint and staff had the opportunity to discuss the settlement, staff issued a letter providing notice of staff’s intent to recommend the commission initiate a public proceeding against Footprint.

Footprint submitted its response on March 12, 2018. “Although staff narrowed the set of violations pursued in light of the additional information it received … staff still concluded that the majority of Footprint’s arguments were not supported by the evidence and did not alter staff’s views that violations occurred,” said the commission order.

Footprint must now provide a concise statement regarding any disputed factual issues and any law upon which they rely, admit or deny each material allegation and set forth every defense relied upon. Failure to answer the order to show cause will be treated as a general denial and may be the basis for summary disposition, the commission said.

Footprint may also choose to apply section 31(d)(3) of the FPA to the proceeding. If the commission then finds a violation, it will issue a penalty assessment and, if not paid within 60 days of the order assessing penalties, it will institute an action in the appropriate United States district court.

NYISO Management Committee Briefs: June 12, 2018

COOPERSTOWN, N.Y. — As it wrestles with the increasing penetration of distributed energy resources and growing efforts to decarbonize the grid, FERC is closely watching New York’s efforts to price carbon into its wholesale electricity market.

“New York is working on carbon pricing, which is an attempt to reflect and achieve and reconcile state policy goals in the market, through the market, rather than just accommodate them as in New England and PJM,” Becky Robinson, deputy director of FERC’s Division of Economic and Technical Analysis, told NYISO’s Management Committee on Tuesday. “So the commission is watching very closely.” (See NYISO Favors Cost Levelizing on Carbon Charge.)

Staff from FERC’s Office of Energy Policy and Innovation also attended the meeting June 12 and answered questions from stakeholders.

ISO-NE’s Competitive Auctions with Sponsored Policy Resources construct “is what we term more of an accommodate approach, where the goals are to allow state-supported resources to participate in the capacity market, but put a structure in place that maintains competitive markets,” Robinson said. (See Split FERC Approves ISO-NE CASPR Plan.)

PJM has also filed two competing proposals dealing with state-sponsored resources that the commission must rule on by June 29, she said.

“The first PJM proposal, capacity repricing, is a different type of accommodate solution, and the second is what they call MOPR-Ex, which expands” PJM’s existing minimum offer price rule to bar subsidized resources from receiving a capacity commitment, Robinson explained. (See PJM Urges FERC to Act on ‘Jump Ball’ Despite Criticism.)

DERs Feedback

Speaking about the commission’s April 10-11 technical conference on distributed energy resources, Robinson said “one key takeaway is that states want flexibility. You still need to flesh out what is the role of the distributing utility relative to that of the aggregator.” (See Ready to Act on DERs, FERC Tells Congress.)

Asked about the key areas the commission is examining in market rules for DERs, Robinson said, “Coordination is a big one … and double-counting is an issue. We think there are ways — there are tools you can use — to avoid that. And jurisdiction, that has been contentious in the docket: Who does what and where?”

Couch White attorney Kevin Lang, representing New York City, said opinions differ on how to look at FERC Order 841. (See FERC Rules to Boost Storage Role in Markets.)

“Some people think it means we should be creating rules to recognize the differences in those technologies from more traditional types of generation resources, and other folks have assumed that we should be trying to create the same rules as much as possible between new technologies and traditional resources,” Lang said.

He asked whether an energy storage project should have to meet the same market rules as a 500-MW combined cycle unit.

“I think we tried to indicate some flexibility on that,” Robinson said. “Commission staff look for ways to rationalize the participation model. … On the DER space, I don’t think we proposed a participation model for DER aggregation.”

Adequate Summer Capacity Forecast

NYISO Vice President of Operations Wes Yeomans told the committee the ISO is prepared to meet peak demand this summer, with a total of 42,169 MW of resources available to cover an expected peak of 32,904 MW, which is 2.9% above the long-term average.

Yeomans said his report was identical to that presented to the Operations Committee and the press on May 30, except for a note explaining that that the Market Monitoring Analysis Group (MMA) had visited 22 generator sites to check their reliability readiness. (See NYISO Ready to Meet Summer Demand.)

The MMA reviewed planned maintenance outages and practices in order to reduce forced outages, and also checked that generators had adequate supplies of backup fuel storage.

2018 Master Plan Focuses on Grid Evolution

NYISO is this year preparing a Master Plan with three key themes: resource flexibility, grid resilience and price formation.

Michael DeSocio, the ISO’s senior manager for market design, told the committee that ISO staff are working on a comprehensive five-year plan to prepare for anticipated changes to the bulk power system, with a focus on projects that help prepare for the evolution of the grid.

“The addition of renewable resources expected as a result of the [state’s] Clean Energy Standard will create a more dynamic grid, where supply is heavily influenced by the weather,” the draft plan said. “This necessitates a look at the incentives for flexible resources that will be needed to balance intermittent renewables, as well as alternative market designs that preserve revenue adequacy for generators needed for reliability.”

nyiso peak demand carbon pricing

NYISO is examining how to incentivize development of flexible resources needed to balance the growth of intermittent renewables on its grid. | DOE

“Some grid operators are concerned about fuel security, but we feel pretty comfortable about fuel energy security,” DeSocio said.

Nonetheless, future changes to New York’s fuel supply mix, as well as increased demands for natural gas, may stress the grid, and the ISO recommends that it conduct a 10-year fuel security study in 2019 and, if necessary, implement market design changes in 2021.

“On carbon pricing, we got a lot of feedback,” DeSocio said, noting that stakeholders have commented that the ISO should accelerate the proposed timeline for implementing carbon pricing.

The ISO is also thinking about how to implement the market design, which they expect to have complete by Q2 2019, DeSocio said.

The revised Master Plan timeline accommodates carbon pricing implementation in 2021, which could be advanced to 2020 if stakeholders want to make it their top priority, he said.

Mark Younger of Hudson Energy Economics said he supported pricing carbon as quickly as possible, but shared the Market Monitoring Unit’s concerns about why so many of the other initiatives in the plan are listed as taking four years.

For example, transmission clearance prices: “It’s unclear why that should be hard to implement,” Younger said.

The deadline for stakeholders to submit replies to a Master Plan project prioritization survey is June 26.

— Michael Kuser

American Market Architect Reflects on Mexico’s Reforms

By Tom Kleckner

MEXICO CITY — So what drove a nice kid from Chicago — a “regular American” with a minimal knowledge of the Spanish language — to move to Mexico and not only make his home there, but help design the country’s deregulated electricity markets?

Pavlovic, | © RTO Insider

“I really had no link to Mexico,” said Jeff Pavlovic, the nice-kid-turned-40. “After looking at the whole world, I figured electricity is a very important industry, and I could make a very big impact. If you can make electricity cheaper, you can change the economy.

“I saw Mexico as a great opportunity, as a place that hadn’t embraced market principles in the electric industry,” he said in a recent interview. “It was a long shot. You’re making a big bet on major change. If I could help change the electric markets in Mexico, I thought that could have as big an impact on the world as anything. I just thought about it and came to Mexico.”

Simple as that. Pavlovic obviously has an analytical mind. The son of a teacher, he also has the academic pedigree to match his entrepreneurial spirit. He picked up economics and math degrees from Duke, an MBA from Stanford and, after moving to Mexico in 2008, a master’s in economics from the Centro de Investigacion y Docencia Economicas (Center for Economic Research and Teaching).

Pavlovic, who spent a few months studying Spanish before moving to Mexico, is now fully bilingual. “I thought my Spanish was good enough, but it took three or four years before I could really communicate,” he said.

Fortunately, Pavlovic found himself in the right place at the right time. He was in Mexico, where the state-run electric monopoly doesn’t have “51 state governments deciding the rules.”

And though he admits it was a longshot, Pavlovic’s expertise in unbundling electric utilities as a financial consultant and in generation control and dispatch for Xcel Energy landed him several different positions with the Ministry of Energy (SENER) and the Federal Electricity Commission (CFE), Mexico’s national utility. In 2011, he took a position as general director of generation, conduction and energy transformation with SENER, just as the push for electric reform, driven by the need for more efficient generation and lower prices, began in 2012.

“Very good timing. I thought it would happen six years later than it did,” Pavlovic said, referring to Mexico’s single, six-year presidential terms. “When I was dreaming of this, I didn’t think I’d be in government writing the rules. I thought I’d be on the sidelines, maybe in some private company sending suggestions that would mostly be ignored. Being in the middle of the process was better than anything I dreamed of.”

Big Designs, Slow Progress

Anxious to make the sector “more efficient and reduce costs,” Pavlovic said he and the market-design team borrowed textbook principles and elements from RTOs in the U.S. “We wanted a Day 2 settlements market at least. We wanted nodal prices,” he said. “We followed MISO and PJM in letting the system operators make the commitment decisions.”

Mexico began its incremental rollout of market reforms in 2014, but progress has been slow and halting. The financial transmission rights market has been delayed until 2019, frustrating participants who have complained about a lack of liquidity. The first midterm capacity auction in February cleared only one transaction, Enel’s 50-MW purchase from Spain’s Global Power Generation, leading one observer to say, “Whenever a bilateral agreement is signed, [the market] has a party.”

Market participants have complained about the market’s lack of transparency, exemplified by the confusion around transmission retail rates that led to a new, transitory methodology. Rate increases will be phased in through 2018 while a permanent solution is developed.

Some market participants have given themselves six months to see how the market shakes out and “grows legs,” as one player said during the recent Gulf Coast Power Association market conference in Mexico City, before jumping headlong into the market.

Pavlovic left the government last year, forming his own generation asset firm, Bravos Energia, and taking his message on the speaking circuit. (See “Market Architect Calls for Increased Transparency,” Overheard at the GCPA Mexico Electric Power Market Conference.)

Asked about his reaction to how the market has developed, Pavlovic said he believes the market design “was mostly efficient.”

“A perfectionist can always find things that could have been done better, but in the big picture, I was happy,” he said. “The way the powers were separated among the government authorities was right. The implementation has had some very good early successes with the short-term market, the auctions, the capacity market. I was pretty satisfied, but always conscious of things not going as well as I had hoped.”

mexico Bravos Energia Jeff Pavlovic
Bravos Energia

Pavlovic pointed out that several market pieces — FTRs, virtual trading and a fully functional real-time market — still need to be implemented.

“Most of the [market’s] weaknesses are caused by the environment the market operates in,” he said. “How many participants are there? What kind of positions do those participants need to take?”

Pavlovic said many market participants can’t take large positions because of the lack of private generation assets in operation and uncertainty over regulated transmission rates.

“A lot of auction projects are under construction, but the market suffers from the lack of a dynamic retail market,” he said. “It’s a chain of cause and effect. With no retail market, the speed of investments is slowed down.”

A New Wave

When Pavlovic rejoined the private sector, his biggest worry was whether the market reform’s unbundling of CFE’s generation, distribution and retail businesses would hold. It hasn’t. During his GCPA keynote, he said the former monopoly continues to combine the financial accounting for its several subsidiaries.

“It’s not turning out to be as strong a separation as we had hoped for,” Pavlovic said. “They are the big player in the market, but I don’t think they have built the systems or generated the knowledge to be able to use the market as a tool to hedge their risks. If they were using those markets, then there would be a lot more liquidity, a lot more price discovery, and that would bring in a lot more participation from private companies.”

Complicating matters is the country’s July 1 presidential election. With presidents and their administrations limited to a single-six year term, governmental work naturally slows to a crawl in the months before the election. This year, populist Andres Manuel Lopez Obrador holds a 26-point lead over his two opponents from the traditional ruling parties.

Obrador’s energy platform includes increasing hydroelectric generation and preventing the retirement of 16 GW of thermal generation, without allowing their modernization, repowering or conversion to cheaper fuels. He is also calling for a million small renewable plants for residential users and the services sector.

“It’s dangerous, because those [hydro and thermal] investments could crowd out more productive and efficient investment from the private sector,” Pavlovic said. “The rest of his proposals are not going to have a big impact on the market. He’s not talking about undoing the power market, he’s not talking about the states taking over private assets. It doesn’t look like there’s a very big downside to be worried about.”

Pavlovic’s greater worry is about the industry’s regulation. The Energy Regulatory Commission (CRE) consists of seven commissioners serving staggered seven-year terms. Every New Year’s Day, a new commissioner joins.

“The big risk is whether they will nominate competent technical leaders to regulate the electrical sector,” Pavlovic said. “There’s still a lot of work to be done, in the regulation and implementation of the market. You need competent technocrats and technical leaders in the power sector.”

Still, Pavlovic draws hope from the growing number of participants in the market’s capacity auction.

“There is a new wave that will come in,” he said during the GCPA conference. “I think the market will continue to get deeper and help us exercise influence over the policy.”

New York Public Service Commission Briefs: June 14, 2018

Electric reliability in New York state declined last year compared to 2016 because of a severe wind storm in March, Department of Public Service staff told the Public Service Commission on Thursday.

Excluding weather-related outages, overall interruption frequency — the main metric DPS staff use — improved slightly, according to their annual report on reliability. However, some service areas saw longer interruptions, and others saw an uptick in tree-related outages compared to other causes (18-E-0153).

A severe wind storm in early March 2017 downed distribution lines in Rochester, N.Y. | NY PSC

But while it led to record wind generation in NYISO, the March storm, with gusts up to 70 mph, easily downed distribution lines in upstate New York. (See “NYISO Sets Wind Energy Record in March,” NYISO Management Committee Briefs.)

The three upstate utilities — National Grid, Rochester Gas & Electric and New York State Electric and Gas — collectively reported about 284,000 outages in their service territories as a result of the storm. A DPS investigation found that RG&E and NYSEG did not follow their emergency response plans, leading to longer outage times, and the utilities have filed a joint proposal with the PSC to settle staff’s alleged violations for $3.9 million.

Staff expect reliability to only worsen because of severe weather. “The weather events dominating the headlines recently indicate weather patterns are producing more frequent and powerful events,” they said. “As a result, this reliability category is expected to decline given the number of significant weather events that have occurred in 2018.”

New York has already experienced several unusually powerful storms this year, including January’s bomb cyclone, a series of March nor’easters, a spate of severe thunderstorms on May 15 and a tornado on May 3.

Pipeline Safety Efforts Improve

Meanwhile, pipeline safety improved overall last year, as local distribution companies improved their damage prevention, emergency response and leak management efforts (18-G-0260). The number of reported damages to natural gas pipelines in the state decreased slightly, from 1,565 to 1,562.

The DPS measures LDCs’ damage prevention by tallying up damages resulting from certain actions, such as mismarking areas or contractors failing to notify LDCs of excavation activities. By this standard, damage prevention improved by 22.5%.

The LDCs’ ability to respond to emergencies within 30, 60 and 90 minutes all improved, staff said. Additionally, the utilities reduced their backlog of leaks by 2,354, or 13.4%.

Staff also presented reports on electricity safety (18-E-0279) and customer service (18-M-0267).

Separately, as part of its consent agenda, the PSC approved a $1.98 million settlement by National Grid for a 2015 pipeline explosion on Long Island that destroyed a house and severely injured two people inside (15-G-0298). A staff investigation found the company failed to disconnect gas service to the house after a resident request.

Central Hudson Rate Increase Lowered; Burman Dissents

The PSC voted 3-1 to approve a $36.4 million electric and gas rate increase for Central Hudson Gas & Electric, 57% below what the utility initially requested (17-E-0459, 17-G-0460).

Empire State Plaza, where the New York PSC meets

Under a joint proposal with DPS staff, Central Hudson agreed to increase its rates over three years, instead of all at once. Eligible low-income customers will also see a 65% rate decrease under the plan.

“The progressive plan that was adopted — endorsed with complete stakeholder support by environmental groups, large business customers and the largest municipality in the region — includes a nation-leading affordability policy that substantially lowers bills for most low-income customers,” Chair John B. Rhodes said in a statement.

Commissioner Diane Burman spoke for more than half an hour explaining the many reasons for her “clear ‘no’ vote.” But she said the single issue that tipped the scales for her was a $264 credit to customers who install geothermal HVAC systems, which the commission says are more energy efficient and emit less carbon.

“We always say that we’re fuel-neutral [and] technology-neutral … here, we would not be,” Burman said. “And there’s no explanation to me why except that it was agreed to in the joint proposal.”

— Michael Brooks

MISO Nixes LSE Load Forecast Plan

By Amanda Durish Cook

CARMEL, Ind. — MISO has called off a proposal to rely on data from its load-serving entities to compile its own long-term load forecast, stakeholders learned last week.

The RTO will instead continue to use independent load forecasts (ILFs) prepared by Purdue University’s State Utility Forecasting Group but with a twist: It will now order four versions of the forecast, each tailored to one of the futures used to inform MISO’s annual Transmission Expansion Plan.

MISO LSE load-serving entities load forecasts
Lawhorn | © RTO Insider

“After careful consideration of the comments and proposals by stakeholders, MISO will begin to use the independent load forecasts to develop futures-specific load and energy forecasts for MTEP 20 and beyond,” John Lawhorn, MISO senior director of policy and economic studies, told stakeholders at a June 13 Planning Advisory Committee meeting.

Lawhorn said “consistency and clarity, not necessarily increased precision,” prompted the decision, and he stressed that MISO will continue to use LSE forecasts to plan for resource adequacy.

The expanded independent forecast is “for transmission planning purposes only,” Lawhorn said.

“I know we’ve been talking about the ILF for the past five years, with more discussion in the past eight months,” he said.

The change to an LSE-based forecast would have required MISO’s 140-plus LSEs to annually assemble four different 20-year load forecasts to fit with each of the MTEP futures, an unpopular proposition with many stakeholders. (See Advisory Committee Steps up Criticism of MISO Forecast Plan.)

The LSEs themselves were mixed over whether they would be able produce their own 20-year forecasts. An April survey generating responses from one-third of LSEs representing about two-thirds of load showed that LSEs estimated the costs of putting together forecasts would be anywhere from “minimal” to a few hundred thousand dollars, Lawhorn said.

“Costs were all over the map from that perspective, whether they already had a load forecasting group or not,” Lawhorn said in April.

Stakeholders at last week’s meeting asked whether MISO has a plan to monitor its ILFs and compare them with actual loads after the fact.

Lawhorn said although it’s difficult for MISO to line up all variables to compare forecasted load to actual load, Purdue’s own analysis has shown its forecasts “trend well” with actual load in the long term.

Other stakeholders expressed concerns that MISO had no specific plan to hold the ILF to a standard of accuracy.

WPPI Energy’s Steve Leovy said he would have liked MISO to hold more discussion with stakeholders before deciding on the ILF, adding that a single survey of LSEs was inadequate to collect opinions. Organization of MISO States Executive Director Tanya Paslawski said she was likewise concerned about MISO’s short comment period and scant communication about its decision. She noted she would take her concerns to her Board of Directors.

‘Post-capacity’ Planning

MISO said it makes sense for the ILF to be tailored to MTEP futures because energy usage is increasingly driving transmission planning, shifting away from capacity-based planning that relies on an annual system peak. The RTO says it will increasingly experience peaks that can occur during any hour of the year.

“It’s a shift that we’re seeing from a capacity-planning paradigm to an energy-planning paradigm … as we move to more facilities that are small and local. Energy delivery is becoming the driver of a robust transmission system. Moving energy around the system becomes more important as the resource mix changes,” Lawhorn said, pointing to MISO’s 93-GW interconnection queue, which includes 80 GW of potential renewable sources. “This is portending to be a major shift in our system.”

ISO-NE Planning Advisory Committee Briefs: June 13, 2018

MILFORD, Mass. — ISO-NE forecasts a net installed capacity requirement (ICR) value of 34,000 MW for capacity commitment period 2023/24, a 275-MW increase from the 33,725 used in February’s Forward Capacity Auction 12 for 2021/22, officials told the Planning Advisory Committee on Wednesday.

| ISO-NE

The net ICR is forecast to rise by 200-MW increments each period to 34,800 MW for 2027/28 with capacity margins dropping to 15% from 16.7% for 2021/22.

The forecast uses the same capacity and transmission transfer capability assumptions used to develop ICR values for FCA 12 but with the 2018–2027 Forecast Report of Capacity, Energy, Loads and Transmission (2018 CELT) load forecast. The FCA 12 values were based on the 2017 CELT, system planning engineer Manasa Kotha told the PAC. (See ISO-NE Capacity Prices Hit 5-Year Low.)

The RTO modeled three capacity zones for FCA 12: the Southeast New England (SENE) import-constrained capacity zone comprising Northeast Massachusetts (NEMA)/Boston, Southeast Massachusetts (SEMA) and Rhode Island; the Northern New England (NNE) export-constrained capacity zone comprising Maine, New Hampshire and Vermont; and the Rest-of-Pool capacity zone comprising Connecticut and Western/Central Massachusetts.

Comparisons of the 2018 and 2017 CELT load forecasts show that while overall New England load decreased, load in the SENE sub-areas has increased, as it did last year, Kotha said.

Comparison of 2017 and 2018 Net ICR Forecasts (MW) | ISO-NE

The increase is attributable to the Massachusetts economy continuing to grow faster relative to the other New England states, she said.

As part of its review of ICR assumptions for Operating Procedure No. 4 conditions (action during a capacity deficiency), the RTO has proposed using 700 MW of minimum operating reserves in the ICR model, an increase of 500 MW over the long-term assumption of 200 MW previously used. The new 700-MW assumption will be used in FCA 13 ICR calculations, Kotha said.

Future Locational Reserve Needs

ISO-NE foresees reserve needs in NEMA/Boston to be in the range of 250 to 700 MW for summer 2019 and 250 to 400 MW for winter 2019, Fei Zeng, technical manager for resource adequacy, told the PAC.

The RTO developed future representative operating reserve needs for the current reserve zones in NEMA/Boston, Southwest Connecticut (SWCT) and Greater Connecticut for summer and winter for study period 2018-2022. The actual requirements reported for 2018 are based on historical data of the last two years.

Investment of New England transmission reliability projects by status through 2022 (numbers represent project quantities) | ISO-NE

The forecasts did not consider the impacts of Footprint Power’s new 674-MW combined cycle power plant in Salem, Mass., “which when it goes into service by the end of the year is expected to have an impact on the following year’s calculations,” Zeng said.

Together with upgrades in the greater Boston area, the new Salem Harbor Station will help eliminate the local reserve needs for the study period, Zeng said.

In SWCT, the grid operator expects Competitive Power Ventures’ Towantic Energy Center, which began generating last month, to help reduce local reserve needs to a minimum level for summer 2019. With the assumed addition of Bridgeport Harbor 5, and the SWCT transmission upgrades, forward reserve requirements are expected to be zero for the remainder of the study period. (See related story, CPV: Subsidies — not Gas Shortages — Challenge for New Plants.)

CEII Presentations Describe Aging Infrastructure

The PAC heard five presentations on regional transmission infrastructure, which collectively described the rust in New England’s rustbelt. All five presentations were classified as containing critical energy/electric infrastructure information (CEII).

However, one stakeholder pointed out that much of what the classified material detailed would be visible to any interested commuter in the region. The needed replacements range from vintage control room equipment to brown glass insulators to replacing rusting towers.

Pradip Vijayan, ISO-NE senior engineer for transmission planning, updated the PAC on results from the SWCT 2027 needs assessment, as well as one project related to an older needs assessment for Greater Hartford/Central Connecticut.

Christopher Malone, Avangrid manager for Connecticut transmission planning, presented railroad corridor transmission line asset conditions. Maintenance of century-old catenary structures over the railroad is complicated by railroad control of 22-kV feeder/signal conductors.

Eversource Energy system planning manager Shaun Moran presented on challenges with the infrastructure in Eastern Massachusetts that carries much of the load for Cape Cod.

Kelly Csizmesia presented on behalf of National Grid’s New England Power unit, which operates transmission facilities in every regional state except Connecticut.

Transmission Projects and Asset Condition Update

Jon Breard, ISO-NE associate engineer for transmission planning, presented an update on the Regional System Plan regarding transmission projects and asset conditions, noting that seven new transmission projects totaling $146.8 million have been placed in service since the last update in March.

The RTO estimates about $1.74 billion in active reliability projects are underway now, compared to $1.9 billion in March.

Regarding asset conditions, the RTO reported one new project (the $6.3 million replacement of the Montville 16X transformer in Connecticut), and three projects placed in service since the last update in March, including: the installation of two 40-MVAR reactors on the Scobie 115-kV bus in New Hampshire ($4.7 million); replacement of the Salem Harbor Substation 115-kV oil circuit breaker ($4.6 million); and the 1231/1242 structure replacement project in Massachusetts ($8 million).

— Michael Kuser