CPP, FERC’s Bay, Honorable Among Losers in Trump Win

By Ted Caddell and Rich Heidorn Jr.

WASHINGTON — The U.S. just elected a president who has said he will tear up the Paris Agreement, block the Obama administration’s Clean Power Plan, “save the coal industry” and loosen the regulatory reins on the energy industry.

Like the entire country, the electric industry is still trying to get its head around how President-elect Donald Trump will convert his rhetoric into policy.

Trump offered little detail on the energy policies he would pursue beyond vowing to revoke EPA’s climate rule and supporting Republican calls to ease restrictions on oil and gas exploration and fuel pipelines.

There were some obvious winners and losers as a result of the Republicans’ capture of the White House and their continued control of the House and Senate, however.

In addition to the Clean Power Plan, other losers are likely FERC Chairman Norman Bay, Commissioner Colette Honorable and the Department of Energy.

One other likelihood, based on the defiant responses from environmental groups Wednesday: protests and litigation over Trump attempts to roll back environmental rules.

Edison Electric Institute President Tom Kuhn issued an anodyne statement Wednesday that nonetheless betrayed the industry’s uncertainty about what a Trump administration means to utilities. The trade group said it is looking forward to working with the new administration to “navigate the many challenges and opportunities facing our industry.”

“We want to ensure that we are communicating with the incoming administration, policymakers and key stakeholders about the investments our members are making and the projects they are undertaking to benefit their customers and our energy future.”

Reshuffle at FERC

Bay, a Democrat, will presumably lose the FERC chairmanship, and Commissioner Colette Honorable, whose term expires next June, will likely be replaced by a Republican.

Although the commission has not traditionally been marked by partisan divisions, the president gets to appoint members of his party to three of the five seats and pick the chairmanship. Since Republicans Philip Moeller and Tony Clark left, the five-member panel has been all Democrats: Honorable, Bay (whose term expires in June 2018) and Cheryl LaFleur (June 2019).

what does a donald trump ferc commission look like - and what does that mean for energy policy — Donald Trump will get to fill two Republican vacancies on FERC and replace Democrat Colette Honorable when her term expires in June 2017. Chairman Norman Bay, a Democrat, will have to hand the gavel to one of the three Republican commissioners. | *FERC*

Because Republicans maintained their control of the Senate, Sen. Lisa Murkowski (Alaska) will remain chair of the Energy and Natural Resources Committee, the gatekeeper for FERC nominees.

A subdued Bay, who made an appearance at FERC’s technical conference on energy storage Wednesday, declined to comment when asked by RTO Insider for his thoughts on his future.

Paris Agreement, Clean Power Plan

Neither the U.S. participation in the Paris Agreement nor the CPP were approved by Congress, so President Obama’s target of reducing U.S. greenhouse emissions by up to 30% by 2025 is clearly in peril.

Trump — who has called climate change a hoax created “by the Chinese in order to make U.S. manufacturing noncompetitive” — has promised to “cancel” the agreement, which aims to limit global warming to 1.5 degrees Celsius above preindustrial levels and went into effect Nov. 4. Trump also promised to stop U.S. payments to the U.N.’s Green Climate Fund.

According to an analysis by Climate Central, an organization of scientists and journalists whose mission is to communicate the effects of climate change, Trump would have three ways of withdrawing the U.S. from the Paris Agreement. The first is to invoke an article to withdraw from the agreement a year after it takes effect by declaring the abandonment of a 1992 treaty — the United Nations Framework Convention on Climate Change, on which it is partly built.

Another section of the agreement allows a signatory to withdraw three years after it is signed, with an additional one-year waiting period after that.

Or, in what many see is the most likely scenario, he could just abandon any of the voluntary rules and incentives to reduce emissions.

Most in the industry and regulatory bodies overseeing it believe the goals set by the agreement would not be obtainable without slashing greenhouse gas emissions from electric utilities’ use of coal.

Trump will appoint a new EPA administrator. He also could order the Justice Department to stop defending the Clean Power Plan in court should the D.C. Circuit Court of Appeals overturn it — preventing the possibility of the order being reversed by the Supreme Court (for which Trump will nominate a replacement for the late Justice Antonin Scalia). (See Analysis: No Knock Out Blow for Clean Power Plan Foes in Court Arguments.)

If the rule is upheld by the D.C. Circuit, Trump’s EPA would need to establish another rule revoking the CPP.

“It’s virtually certain that the Clean Power Plan will be revoked. The question is how,” Jeff Holmstead, a partner at the law firm Bracewell and a former assistant administrator at the EPA, speaking at a post-election conference call.

“I’m quite confident that they do intend to make good on that promise. The question is how they will do it — and will they do it in a way that will withstand legal scrutiny,” he said. “Any action to revoke the plan will also be litigated, just like the plan itself.”

Congress attempted to kill the CPP last year through the Congressional Review Act, which allows Congress to disapprove regulations that have an economic impact of more than $100 million. Those disapprovals, however, must be signed by the president or his veto overridden by a two-thirds majority. President Obama vetoed Congress’ CRA rejection of the EPA rule last December.

The GOP will retain control of the Senate by 51-48, with a December runoff election in Louisiana. Republicans will control the House by 239-193, with three races (two in California and one in Louisiana) still undecided.

Environmental Groups Vow Resistance

The reaction from environmental organizations was a mix of shock and defiance.

350.org came out of the blocks with a message calling Trump’s election “a disaster.”

“But it cannot be the end of the international climate process. We’re not giving up the fight and neither should the international community,” the group said in a statement attributed to Executive Director May Boeve. “In the United States, the climate movement will put everything on the line to protect the progress we’ve made and continue to push for bold action. Our work becomes much harder now, but it’s not impossible, and we refuse to give up hope.”

The Environmental Defense Fund’s political arm, EDF Action, said in a statement Wednesday that Trump’s positions are “in complete contradiction to the realities of climate science. Mr. Trump should listen to the scientific experts on climate change and recognize that a clean energy transition is already underway. America’s economic future depends on embracing this trend,” EDF said.

The Sierra Club called it “a deeply disappointing day for the United States, and the world.”

“For people all over the country, the pain, anger and fear at the prospect of a Trump presidency are very real,” Executive Director Michael Brune said in a statement that was nearly a call to man the barricades.

“What we know is that it would be extraordinarily difficult for Trump to remove the U.S. from the Paris Agreement,” Brune said. “His position is already causing international blowback abroad, and in very pointed ways that are in some respects unprecedented. If Trump does try to undermine climate action, he will run headlong into an organized mass of people who will fight him in the courts, in the states, in the marketplace and in the streets.”

Earthjustice, a nonprofit environmental law organization, said Trump “might be the most anti-environment president in history” and suggested that Trump’s EPA may face court fights from environmentalists akin to those the Obama administration had to fend off from industry and coal states.

“He has publicly stated that he does not believe in the overwhelming amount of evidence supporting climate change and his record on all matters involving justice, equity and human rights is troubling,” Earthjustice President Trip Van Noppen said in a statement. “Therefore, Earthjustice will be working overtime in the courts to hold President-elect Trump and his administration accountable under our nation’s laws, which protect Americans’ right to a clean and healthy environment.”

Wind

Trump has called wind turbines expensive eyesores and decried their impact on bird populations.

Nevertheless, the American Wind Energy Association proclaimed itself “ready to work with President-elect Donald Trump and his administration to assure that wind power continues to be a vibrant part of the U.S. economy.”

“An unstoppable shift to a cleaner energy economy is underway, and the fundamentals of wind energy in America are strong,” AWEA said in a statement, in which it noted that the wind industry has 88,000 jobs, “a quarter of them made-in-the-USA manufacturing jobs.”

“In his victory speech early this morning, the President-elect said, ‘We’re going to rebuild our infrastructure, which will become, by the way, second to none. And we will put millions of our people to work as we rebuild it.’ Wind power is some of the best infrastructure America has ever built and we are on track to doubling it from today’s levels by 2020.”

Coal

In his campaign visits to coal country, Trump promised to put miners back to work. Regardless of what happens to the CPP, however, it’s hard to imagine any utility board of directors authorizing construction of a new coal-fired plant when existing plants are having trouble competing with natural gas.

“Forget the Clean Power Plan. You cannot build a coal plant that meets existing regulation today that can compete with $5 gas,” Charles Patton, president of Charleston-based Appalachian Power, told a state energy conference earlier this year, as reported by American Public Media’s Marketplace. “It just cannot happen.”

The Labor Department reported coal mining jobs have declined from about 84,600 in March 2009, after Obama took office, to 56,700 in March. At least six publicly traded U.S. coal companies have entered Chapter 11 bankruptcy proceedings since 2015.

Goldman Sachs issued a report in February saying that declining demand for thermal coal is “irreversible.”

donald trump giving victory speach (what's his energy policy) — Trump

It followed a report last year that concluded “The industry does not require new investment given the ability of existing assets to satisfy flat demand, so prices will remain under pressure as the deflationary cycle continues.”

The investment bank’s conclusion contradicts the International Energy Agency, which predicted last year that coal consumption would rise by about 2.1% annually through 2019.

“This is a great day for America,” Murray Energy CEO Robert Murray said in a statement. “I have personally spent time with Mr. Trump, and I know that he will surround himself with the very best people to fix the many problems facing our country. Indeed, Mr. Trump will finally implement a national energy policy whereby all energy sources will compete on a level playing field.”

One of those people could be Myron Ebell, a climate skeptic and executive at the Competitive Enterprise Institute. Trump has vowed to take away EPA’s regulatory powers and make it an advisory council. Ebell has been running the EPA working group for the Trump transition team and is seen as a contender for the EPA administrator post.

Trump has also said he wants to open federal lands to oil and natural gas drilling and coal mining. Forrest Lucas, cofounder of Lucas Oil, has been mentioned as a candidate for secretary of the Interior Department.

Nuclear Power

Despite Trump’s opposition to the CPP — which could provide support for the carbon-free generation of nuclear power — the Nuclear Energy Institute said his election is good news for the industry.

“Despite a tepid economy, the Department of Energy forecasts a 23% growth in electricity demand by 2040, the equivalent of more than 200 large power plants,” said Maria Korsnick, NEI’s incoming CEO. “Couple this with Mr. Trump’s all-in approach to energy and it’s apparent that the low-carbon, reliable electricity that nuclear energy facilities provide must continue to be a key part of the nation’s energy portfolio.

“Throughout the presidential campaign, nuclear energy was a bipartisan issue and one of the few areas of general agreement between the candidates. Additionally, public polling shows that the importance of nuclear energy to this nation’s energy mix is one thing voters could agree on, irrespective of their candidate preference.”

Department of Energy

Trump’s appointee to head the Department of Energy is sure to be less enamored than the Obama administration in investments in renewables and energy efficiency.

“Off the bat, it’s likely to be a fairly antagonistic transition given the overall dynamics in the election and given his stances on energy,” Teryn Norris, a former special adviser to the department, told Greentech Media. “Trump has repeatedly expressed disdain for renewables, and seems likely to gut those programs in” the Office of Energy Efficiency and Renewable Energy.

November 8, 2016

Federal Briefs

Six days after an explosion in Alabama shut it down, Line 1 of the Colonial Pipeline began shipping gasoline from Houston to New Jersey again on Sunday morning.

Colonial said it would take three days for the gas to arrive at the Linden, N.J., terminal. The explosion and ensuing fire, near Helena, Ala., was the result of a backhoe punching a hole in the pipeline, sending 200 feet of fire into the air, killing one worker and injuring five others.

The pipeline’s shutdown disrupted the wholesale gasoline market and raised retail prices in the Southeast.

More: Reuters

Obama: US Considering Ways To Reroute Dakota Access

The U.S. Army Corps of Engineers is considering ways to reroute the controversial Dakota Access pipeline so that it doesn’t intrude upon Native American cultural sites, President Obama said last week.

“I think as a general rule, my view is that there is a way for us to accommodate sacred lands of Native Americans, and I think right now the Army Corps is examining ways to reroute this pipeline,” Obama said in an interview with news organization Now This.

But that was news to pipeline constructor Energy Transfer Partners, spokeswoman Vicki Granado said. “We are not aware that any consideration is being given to a reroute, and we remain confident we will receive our easement in a timely fashion,” she said.

More: Dallas Business Journal

NRC Approves Plant Expansion While FP&L Cleans Up Leak

As Florida Power & Light works to clean up leaking cooling canals at its Turkey Point Nuclear Power Plant, federal regulators have partly cleared the way for the plant to build two new reactors.

Following a seven-year environmental study, the Nuclear Regulatory Commission found the use of cooling towers to operate the new reactors — located on the shores of Biscayne Bay between two national parks — would not damage the already fragile ecosystem.

Over the years, the plant’s aging cooling canals sent an underground plume of saltwater miles inland, threatening drinking water supplies, and leaked tainted water into the bay. FP&L is conducting a massive cleanup.

More: Miami Herald

November 8, 2016

White House Announces Nationwide EV Charging Network

By Ted Caddell

The federal government will create 48 “charging corridors” across nearly 25,000 miles of interstate highways in 35 states and D.C. — the beginning of what it hopes will become a nationwide web of stations that will eliminate “range anxiety” and spark broader acceptance of electric vehicles.

Under the plan announced last week by the White House, EV owners will be able to find charging stations every 50 miles on designated highways. Most of the charging stations are to be installed by the end of 2017. The Department of Energy is offering $4.5 billion in loan guarantees to aid financing for multi-outlet, commercial-scale charging stations.

The electrification of transportation could provide a jolt to power producers dismayed by flat load growth. But there are only about 520,000 EVs on the road today — 0.2% of the 250 million vehicles in the U.S. fleet — little more than half of the 1 million plug-in EVs target President Obama set eight years ago for 2015.

Sales of EVs have been hampered by low gasoline prices, high battery prices and limited range and charging infrastructure. U.S. EV sales declined 5% in 2015 over 2014 but increased 19% in the first half of 2016 over the year before, according to FleetCarma.

According to the Energy Department, there are about 14,600 public charging stations for plug-in vehicles, with 37,000 charging outlets, now in the U.S.

Charging Speed

Charging speed also is a challenge. While the new network would make it possible to drive coast to coast, there could be a lot of waiting along the way. Depending on the vehicle and charger type, it can take between three and six hours to fully recharge a plug-in EV.

The Energy Department is working with the National Laboratories and others on a study expected by the end of the year on developing direct-current chargers capable of 350 kW, which could provide a 200-mile charge in less than 10 minutes.

Nissan says its LEAF can restore up to 80% of its charge in 30 minutes with a “fast charger,” but there are only 1,840 of them nationwide. Tesla Motors’ Model S and Model X can charge to a 170-mile range in 30 minutes using a 120-kW “supercharger” available at 734 stations.

Increasing the Range

Vehicle manufacturers also are responding to the desire for more range. The Chevrolet Bolt EV, expected to be released later this year at less than $30,000 (net of federal tax credits), will run for more than 200 miles on a full charge. Tesla’s Model 3, due in late 2017, also will have a range of at least 200 miles.

The Obama administration also is attempting to help make technological advances to reduce battery costs, which exceeded $500/kWh in 2012.

Bloomberg New Energy Finance says lithium-ion battery costs have dropped 65% since 2010, falling to $350/kWh last year. It issued a study in February predicting costs will drop below $120/kWh by 2030.

It projects that worldwide EV sales will hit 41 million by 2040, representing 35% of new light duty vehicle sales. EVs would comprise a quarter of the cars on the road, consuming 2,700 TWh of electricity — equal to 11% of global electricity demand in 2015.

Partners

A public-private partnership of 28 states, utility companies, vehicle manufacturers — including BMW, Nissan and General Motors — and other organizations have agreed to accelerate the installation of chargers and other infrastructure needed. Among the utilities signing on to the project are Pacific Gas and Electric, Ameren Missouri, Portland General Electric, Public Service Company of New Mexico, Eversource Energy and Southern California Edison.

Car manufacturers and utilities will accelerate installation and hookup of charging stations throughout the U.S. Vehicle manufacturers are redoubling production commitments and working to coordinate installation and help fund some of the charging stations. Some of the companies have vowed to increase access to EV stations for their employees.

State and local governments are also making additional commitments to plug-in vehicles. Thursday’s announcement included the details of 24 state and local government plans to purchase 2,500 new EVs in 2017. Los Angeles, for instance, is spending $22.5 million on EV charging stations by June 2018, with 500 additional public EV vehicle charging stations scheduled to be completed by the end of 2017, for a total of 1,500.

Alternative Fuels

The Department of Transportation also is seeking nominations from state and local officials in the creation of alternative fuel corridors for vehicles powered by hydrogen, propane and natural gas. A Federal Highway Administration website offers maps of current EV and alternative fuel infrastructure.

plans for an ev charging station every so many miles on interstate highways — EV Charging Corridors | *Federal Highway Administration*

“Alternative fuels and electric vehicles will play an integral part in the future of America’s transportation system,” Transportation Secretary Anthony Foxx said. “We have a duty to help drivers identify routes that will help them refuel and recharge those vehicles and designating these corridors on our highways is a first step.”

“Working together with the private sector, these actions can help to combat climate change, increase access to clean energy technologies and reduce our dependence on oil. Expanding the infrastructure that supports plug-in and fuel cell vehicles is key to achieving these national energy and national security imperatives,” said Genevieve Cullen, president of the Electric Drive Transportation Association.

‘Tipping Point’

Jim Sholler, 52, who drives about 40 miles from his home in Hillsborough, N.C., to his financial services job in Raleigh, has just reserved a Tesla. “First of all, it’s a much cleaner solution [to greenhouse gas emissions]. You can’t tell me that a large power plant is less clean than a six-cylinder car,” Sholler said in an interview Sunday after learning the details of the government plan.

He said his “tipping point” came when he realized that the EV charging stations at his work were always in use. “And I realized I saw more and more charging stations.”

Sholler noted that the worry that either the vehicle’s range or the dearth of charging stations available on long trips is what holds many prospective owners back.

But improving battery technology — the latest Tesla model boasts a range of 300 miles on a charge, versus the typical range of the first generation of production plug-in electric cars of about 100 miles — and an expanding system of EV charging stations helped him to finally decide to order an electric car.

“Range anxiety is gone,” he said.

November 8, 2016

MISO Market Subcommittee Briefs

MISO said last week that it is ready to begin introducing improved modeling of its combined cycle generating fleet.

The RTO will use a configuration-based combined cycle model that can mimic different combinations of combined cycle units and their dependencies, Yonghong Chen, MISO principal advisor of market development and analysis, said during a Nov. 1 Market Subcommittee conference call.

Currently, MISO’s roughly 40 combined cycle unit “groups” are subject to an aggregate model in which they must either bid as a single generator or bid as separate combustion or steam turbines; dependencies between the units are not modeled. A generator with two combustion turbines and one steam turbine would constitute a “group.”

MISO said the new modeling will increase bid accuracy and prevent infeasible scheduling. Chen said the RTO performed a rough analysis using eight sample cases and found the new model could have saved $47 million in annual production costs in 2014 and $16 million in 2015. The analysis studied MISO’s 20 combined cycle groups with reliable configuration data and assumed other combined cycles would stick to the aggregated model.

Chen said the modeling can be used with the current 40 combined cycle generator groups in MISO’s system, but doubling or tripling the number of groups under the model would create computational challenges.

She also said MISO will look for further improvements and continue to study the benefits of the new modeling throughout 2017 using more updated offer data from resource owners and optimization software from programming firm Gurobi Optimization.

Jeff Bladen, executive director of MISO market services, said the RTO “expects to spend meaningful resources on combined cycle generators” in 2017 given the potential benefits.

MISO May Tweak Emergency Pricing Floors

Following a summertime emergency pricing event that resulted in depressed prices, MISO is considering changing its emergency offer floor calculations to expand the pricing logic to more emergency power.

July 21st Emergency Pricing | MISO — MISO predicted load would hit 130 GW on July 21 based on a forecast that temperatures would hit a record of 91. The load didn’t materialize because of thunderstorms that lowered temperatures. | *MISO*

MISO had been monitoring performance of its two emergency pricing floors since July 21, the first maximum generation event since the 2014 polar vortex. Based on a forecast that average temperatures in the footprint would hit a record of 91, load on July 21 was predicted to hit 130 GW. But the load didn’t materialize because of thunderstorms that lowered temperatures. (See “New Emergency Pricing Floors Undergoing Monitoring,” MISO Market Subcommittee Briefs.)

Michael Robinson, principal adviser of market design, said MISO is mulling five possible approaches, all of which require Tariff changes:

Implementing an offer cap to the emergency offer floors, which unlike the other solutions would not require a software change;
Allocating the commitment costs of offline fast-start units into the minimum run time when calculating the offer floor;
Expanding the emergency pricing logic to allow emergency-committed units dispatched at their economic minimum prices to set emergency prices, similar to how fast-start resources can set prices under extended locational marginal pricing;
Applying emergency pricing to non-firm export curtailments; and
Evaluating the need to further compensate deployed emergency resources when LMPs, make-whole uplift and capacity credits are not sufficient.

Robinson said MISO could consider further changes as well. MISO is asking for stakeholder input through Nov. 18.

“We want to make sure we’re sending the right prices to as many generators called up as we can,” Bladen told stakeholders.

— Amanda Durish Cook

November 8, 2016

Generators Appeal Lower NY Capacity Cap

By William Opalka

New York’s generators have appealed to the NYISO Board of Directors to reject a rule change that would effectively cap capacity payments received by generators in a constrained zone.

nyiso ippny capacity payments — | *Independent Power Producers of New York*

The Independent Power Producers of New York filed its appeal Nov. 1 seeking to overturn the Management Committee’s Oct. 25 vote capping capacity payments in the Lower Hudson Valley and New York City zones to protect consumers from higher prices. (See NYISO OKs Capacity Export Fix Over Generators’ Opposition.)

Responses to IPPNY’s appeal are due Nov. 8; the board is expected to take up the appeal at its next meeting on Nov. 14-15.

Supporters of the rule change concede that the cap is not justified by any analysis done by NYISO staff.

“Because [the cap] is unsupported, will distort market signals, will harm reliability and will set a dangerous precedent that will embolden load interests to use the stakeholder process rather than the competitive markets based on sound and efficient market design to set prices, it cannot be found to be just and reasonable,” the petition says.

The appeal will be a “paper proceeding” unless a party requests oral arguments, NYISO spokesman David Flanagan told RTO Insider on Friday. “No such request has been received at this time,” Flanagan said.

The proposed rule change is in response to FERC’s Oct. 17 order accepting ISO-NE’s changes to its annual capacity reconfiguration auctions. The motion was carried with a 63% vote in favor, above the required supermajority of 58%.

FERC’s ruling allows Castleton Commodities International’s 1,242-MW Roseton 1 generator, located 43 miles north of New York City in NYISO’s capacity import-constrained G-J locality, to supply 511 MW of its capacity to ISO-NE beginning next June for the 2017/18 delivery year.

Appeals of committee motions are rare and reversals are even rarer. According to the NYISO website, there have been 28 appeals since 2000, with 20 being denied, three motions reversed and five sent back to either the committee or staff for further action.

November 8, 2016

SPP Ponders Congestion Rights as Z2 Solution

By Tom Kleckner

SPP stakeholders are considering the use of incremental long-term congestion rights (ILTCRs) to help solve some of the complexity with the RTO’s Z2 crediting process, a contentious issue that dates back to 2008.

Meeting in Kansas City last week, the Z2 Task Force spent considerable time discussing ILTCRs — a form of financial transmission rights used by most other RTOs and already included in SPP’s Tariff — as part of the transmission-congestion rights market.

SPP Ponders Congestion Rights as Z2 Solution — The top 10 creditable upgrades represent $89.4 million, more than three-quarters of the total Z-2 assessments. | *SPP*

In lieu of cash compensation, upgrade sponsors would be eligible to receive ILTCRs as credit for their financial contributions to grid improvements, as the upgrades increase the available transfer capability on the system.

SPP’s outside legal counsel, D.C.-based Wright & Talisman, provided the results of its research on how other RTOs’ Tariffs compensate entities that sponsor network transmission upgrades. CAISO, ISO-NE, MISO, NYISO and PJM all apply some form of compensation through congestion rights or incremental auction revenue rights, according to the report.

“While the terminology, form, amount and duration varies from RTO to RTO,” the report said, “most RTOs provide these incremental ARRs on a long-term basis based on the incremental transfer capability provided by the upgrade.”

SPP’s TCR “market is still a little bit different than MISO or PJM’s, because SPP models on point of delivery, whereas in other markets it’s financial,” said Denise Buffington, Kansas City Power & Light’s director of energy policy and corporate counsel, and the task force chair.

The task force will continue its discussion with an educational session in Dallas on Nov. 29, during which it will bring in several subject matter experts to help the group examine SPP’s TCR market and its generation interconnection and aggregate study processes, among other items.

“I want more information. I don’t want to go into the weeds, but I want to know the pressure points and how one impacts the other … and begin connecting the dots,” Buffington said. “The problem we still face is an education problem. Every time we talk about [Z2], we learn something new — or about something else that touches it.”

In addition to ILCTRs, the group discussed five other options staff offered to improve the Z2 process:

Base plan funding: All upgrades, regardless of their origin, would be included in the current cost allocation methodology. This would recognize that the regional planning and operational processes will optimize all the available transmission.
Reverse engineering: SPP staff has reverse engineered the Z2 process and its associated data inputs, identifying potential modifications to simplify the process, including annual Z2 billing; revising the Tariff’s transmission payment schedules; removing short-term transmission service requests (TSRs) from the process; using annual transmission revenue requirements for point-to-point credit-payment obligations; posting impact ratios for each TSR; using an alternate source for transmission distribution factors; removing short-term TSRs from stacking; and a hybrid solution combining most of the modifications.
Upgrade sponsor-facilities rider (USFR): Consistent with the current Z2 revenue crediting process, sponsors would retain responsibility for reimbursing the owner that builds the creditable-upgrade facilities and the funds used to compensate the sponsors collected from users of the facilities. The process would be simplified by substituting a USFR in part of the crediting process by recovering the facilities’ engineering and construction costs over a specified number of months. The USFR rate would be an add-on charge applicable only to customers using the creditable-upgrade facilities, and funds would be distributed to the sponsor.
Construction credits: Allows the upgrade’s sponsor to receive credits against its transmission service invoice up to, but not above, the amount of engineering and construction costs paid to the entity that built the upgrade.
Toll-road option: Similar to the approach used to fund toll roads, the funding entity is repaid over time by those who use the upgrade. Staff would calculate transmission impacts on a new facility once it is constructed, and all subsequent customers would be charged a fee for use of the line. The sponsor would receive funding from that use until it recoups to the cost of the facility.

All of the options are still in play. Buffington told her fellow stakeholders she hopes they bring their own proposals or a ranking of those on the table to a January task force meeting before the Markets and Operations Policy Committee meeting. The task force expects to finish its work by April.

In the interim, staff will review the Z2 process to identify FERC-mandated requirements and SPP’s own additions and provide the task force with background on why certain requirements were placed in the Tariff. Staff was also asked to develop an annual cost estimate for ongoing support of the Z2 system and to document how it will model fixes and improvements.

SPP’s Board of Directors formed the task force in July to address Z2 waiver requests from members for directly assigned upgrade costs and to improve the process going forward. SPP has billed members for almost $110 million in regionwide, aggregate net payable historic amounts for Z2 credits and obligations, some of which date back to 2008.

November 8, 2016

State Briefs

Don Pedro Reservoir Scheduled For Major Refurbishment in 2017

The Don Pedro Reservoir hydrofacility is scheduled for three major refurbishment projects in its Power Tunnel in 2017, costing an estimated $7 million.

The work will be completed in two phases, each taking about 45 days. The first phase, which will begin before the irrigation season in February, includes the bulkhead gate installation and turbine shutoff valve replacements. The second phase, which is anticipated after the irrigation season in October, includes the fixed wheel gate installation.

The Turlock Irrigation District is hoping to operate the dam for another 50 years after the refurbishments, Assistant General Manager of Power Supply Administration Brian LaFollette said.

More: Turlock Journal

SoCalGas Wants to Pump Natural Gas Again After Aliso Canyon Leak

With investigations still pending and wells still shut down, Southern California Gas asked state regulators last week for permission to pump pressurized natural gas again — about one year after the largest methane leak in U.S. history at the Aliso Canyon storage field.

Citing “extensive physical upgrades” and “advanced technologies,” the gas company is seeking permission to resume operations northeast of Los Angeles, at a depleted oil field now used for storage.

State environmental regulators anticipate it will take weeks to decide upon the utility’s request, as state inspections at the field are still pending and utility regulators also must agree with reopening the field.

More: Los Angeles Times

Option of Up to 100% Renewable Energy Coming to Bay Area Residents

First Solar will sell energy to Bay Area residential customers who are seeking up to 100% renewable energy under a deal with community choice aggregator Marin Clean Energy.

The energy will come from First Solar’s Little Bear project in Fresno County, scheduled for construction in 2019, with commissioning expected in 2020. In the beginning, the project will generate up to 40 MW, with plans to eventually expand to 160 MW.

Customers who opt out can receive Pacific Gas and Electric’s standard service, which is currently 30% renewable.

More: The Business Journal

CONNECTICUT

PURA Commissioners Elect Katie Dykes as Chair

Katie Dykes was elected last week as chair of the Public Utilities Regulatory Authority by its commissioners. She fills the position left vacant by Arthur H. House, who was appointed by Gov. Dannel Malloy in October to become the state’s new chief cyber security risk officer.

Malloy appointed Dykes as a PURA commissioner on Oct. 27. She previously served as deputy commissioner of the Department of Energy and Environmental Protection.

Dykes currently serves as chair of the Regional Greenhouse Gas Initiative’s board of directors and represents Malloy on the board of managers of the New England States Committee on Electricity.

More: Connecticut Department of Energy & Environmental Protection

IDAHO

Group Uses Defunct Guideline To Protest Tx Line Route

A group called the Gateway West Task Force filed a protest last week against the U.S. Bureau of Land Management’s preferred route for the Gateway West transmission line in Cassia and Power counties based upon a federal guideline on sage grouse that is no longer in effect.

The interim guideline prohibited construction near sage grouse habitat on federal land, said attorney Doug Balfour, who represents the group. The now-irrelevant guideline pushed transmission routes onto private land, which affected 40 private landowners in Cassia County, Balfour said.

Since 2015, the state has had its own sage grouse conservation plan that permits the group’s proposed construction route. Although the BLM rejected the group’s preferred route through Cassia and Power counties three years ago, it now has a responsibility to re-evaluate its decision based upon the new information, Balfour said.

More: Times-News

KENTUCKY

LG&E/KU Propose Rate Hike For Funding Advanced Meters

A proposal last week by Louisville Gas and Electric and Kentucky Utilities that would give customers new advanced electric meters comes with a rate hike that would boost LG&E’s electricity service revenue by 8.5% and KU’s revenue by 6.4%.

LG&E’s typical residential electric customers would see a rate hike of $9.65/month, while KU’s would see a $7.16/month increase.

The advanced meters would allow customers to get near real-time information on their energy use, while allowing the utilities to better detect power disruptions and make faster repairs, LG&E/KU spokeswoman Natasha Collins said.

More: Courier Journal

MAINE

Mohegan Island Group Wants Wind Project to Move Elsewhere

A group of Mohegan Island residents is asking developers to move construction of two 600-foot wind turbines — planned for 3 miles offshore — elsewhere.

The Legislature and the Public Utilities Commission already approved the project, and developer Maine Aqua Ventus anticipates construction will begin in 2019 and the generation system will be in service for the next 20 years.

Travis Dow, a spokesman for the newly formed group, Protect Mohegan, said many of the island’s 50 year-round residents were unaware of the project’s potential scope and timeline when it was approved.

More: Maine Public Radio

MASSACHUSETTS

Solar Project Underway At Hancock Shaker Village

Three separate solar arrays presently being installed on the grounds of Hancock Shaker Village could supply electricity into the Eversource Energy power grid beginning in 2017, while keeping with the living museum’s ideal of environmentally sound use of land.

The project, a partnership between Syncarpha Solar and Renewable Energy Massachusetts, consists of a 1-MW array on the Pittsfield side of the historic village and two 2-MW facilities in Hancock. It will serve customers throughout Western Massachusetts.

The project will provide lease income to Hancock for up to 30 years, while enabling residents of the Berkshires who are Eversource customers to buy net metering credits at a discount.

More: The Berkshire Eagle

MARYLAND

Tree Trimming Cuts BGE Power Outages by 35%

Baltimore Gas and Electric is crediting a new tree-trimming protocol for its 10,500 miles of overhead power lines with reducing power outages by 35% during the past four years.

The Public Service Commission’s adoption of new electric reliability standards in 2012 prompted BGE to remove more branches that overhang power lines and make other changes aimed at reducing outages.

More: The Baltimore Sun

MINNESOTA

Minnesota Power Asks for Both Immediate and Future Rate Increases

Minnesota Power is asking state regulators to approve an immediate 8% rate increase for homeowners effective Jan. 1 and a future increase of 10% after a 12- to 18-month contested case hearing process.

The utility said it needs the money to recover hundreds of millions of dollars it invested in its infrastructure in recent years, which includes monies for storm recovery and to “harden” its portion of the grid against extreme weather, and converting from a 95% coal-generated system to a 30% renewable system, Amy Rutledge, Minnesota Power spokeswoman, said.

Residential customers are paying 35% less than what it costs to get electricity into their homes, Minnesota Power officials concluded after a recent study.

More: Forum News Service

NEBRASKA

South Sioux City, Big Ox Reach Agreements on Sewage Odors

Officials from South Sioux City and Big Ox Energy reached several agreements last week addressing strong sewage odors that forced residents of 15 homes in a five-block area to take refuge in hotels.

Big Ox converts organic waste into methane gas and shares sewer lines with the affected homes.

Among the agreed-to items, Big Ox will shut down its wastewater reception, hire an engineering firm to develop and present a plan to the city to ensure that the problem is not repeated, and provide financial support for impacted residents.

More: Sioux City Journal

NEW JERSEY

ACE Customers See Rate Drop Courtesy of Most-Favored Clause

Atlantic City Electric’s half-million customers can thank utility regulators in D.C. for a drop in their electric rates.

In 2015, the state approved Exelon’s acquisition of Pepco Holdings Inc., ACE’s parent. The deal, which provided $62 million in credits for ACE customers, also included a most-favored-jurisdiction provision that ensured state ratepayers would receive equal benefits to those negotiated in other states or the district.

The D.C. Public Service Commission negotiated a more lucrative agreement for district residents, forcing Exelon and PHI to add more than $53 million in benefits in New Jersey. The state Board of Public Utilities approved the revised agreement last week.

More: NJ Spotlight

PSE&G Reaches Agreement for Solar Arrays on Brownfields

Public Service Electric and Gas has reached a tentative agreement with state regulators to build 33 MW of solar arrays costing about $80 million on brownfields and old garbage dumps — a smaller-scale version of its original proposal to spend $275 million to build 100 MW of solar facilities.

The state Board of Public Utilities still needs to approve the tentative agreement, which was reached with its staff, the Division of Rate Counsel and other parties after months of negotiations.

Gov. Chris Christie’s administration supports using former garbage dumps and brownfields as sites for solar farms, rather than undeveloped farmland and open spaces. But consumer advocates, including the Rate Counsel, have voiced concerns about allowing a regulated utility to pass the development costs to utility customers.

More: NJ Spotlight

NORTH CAROLINA

Duke Implodes Dan River Steam Station

Duke Energy imploded the long-shuttered Dan River Steam Station in the final days of October — putting an end to the 276-MW plant where a 2014 coal ash spill led to new state laws and Duke’s guilty plea to federal Clean Water Act violations.

The company used explosives to implode the powerhouse, three boilers and an electrostatic precipitator.

The plant was shut down in 2012, but in February 2014, a storm water pipe running under its main coal ash pond collapsed, sending 39,000 pounds of coal ash into the Dan River. The state adopted the Coal Ash Management Act that summer, and in May 2015, Duke pled guilty to nine misdemeanor violations of federal environmental laws and was fined $102 million.

More: Charlotte Business Journal

NORTH DAKOTA

PSC May Fine Dakota Access for Delayed Notification of Cultural Find

The developer of the Dakota Access Pipeline is facing a possible fine for failing to notify state regulators for 10 days about the discovery of Native American artifacts in the pipeline route.

Dakota Access, a subsidiary of Energy Transfer Partners, was required under its permit to notify the Public Service Commission and to receive its clearance to proceed with construction. It did, however, notify the state Historic Preservation Office and rerouted the pipeline in coordination with the state archaeologist.

The commission can issue a fine of $10,000 per day per violation, or a maximum of $200,000.

More: The Bismarck Tribune

OHIO

FirstEnergy, NOPEC Contract Battle May Impact 500,000 Customers

FirstEnergy Solutions and the Northeast Ohio Public Energy Council (NOPEC) are embroiled in a court battle over changing their long-standing contract. The 500,000 customers that NOPEC represents may lose discounts, but not electricity, as a Jan. 1 switch to a new supplier looms.

Last week, FirstEnergy argued in documents before the Summit County Common Pleas Court that it could not afford the regular fees that it agreed years ago to pay NOPEC. It additionally is seeking to prevent NOPEC from cashing a multimillion-dollar letter of credit that it issued at the start of the companies’ relationship.

If the contract is dissolved, customers would shift to buying power from Ohio Edison or the Illuminating Co. NOPEC will probably have a new supplier within 60 days, said Chuck Keiper, NOPEC’s executive director.

More: The Plain Dealer

UTAH

Rocky Mountain Power’s Subscriber Solar Program 95% Sold Out

Rocky Mountain Power’s Subscriber Solar program is 95% sold out, with residential and business customers purchasing nearly 20 MW of solar power scheduled to come online in 2017.

The utility anticipates that the last few blocks of power will be sold within two weeks. The plant, near Holden, allows customers to use solar energy without installing solar panels.

More: Deseret News

VERMONT

Wind Farm Vote Money Legal, But Residents Still See It as Bribe

The state Attorney General’s Office has found that a developer’s promise of direct payments to Grafton and Windham residents if they approve an industrial wind farm on Nov. 8 does not violate election laws. But some residents see it as an outright bribe.

For the past four years, Iberdrola Renewables has wanted to construct 16 turbines in Windham and eight in Grafton.

The idea of payments — an estimated $1,162/year to full-time adult residents of Windham and $428 for Grafton residents — came from residents, the company’s representatives said.

More: Burlington Free Press

VIRGINIA

Regulators Propose Fining Dominion $260K for 2 Oil Spills

State regulators proposed last week fining Dominion Virginia Power about $260,000 for a 13,500-gallon oil spill in Crystal City and a 9,000-gallon oil spill in Staunton — both of which polluted public waters in January.

A consent order is out for public comment for 30 days, and the State Water Control Board is expected to hear the matter at its December meeting, Department of Environmental Quality spokesman Bill Hayden said. Because of the spills, Dominion was required to monitor its wells for the last two weeks of October and must do so again during the last two weeks of January 2017.

According to Dominion, about 11,120 gallons of oil were recovered from the first spill, and all but 100 gallons were recovered from the second.

More: The Washington Post

November 8, 2016

Stakeholders Seek Clarity on CAISO Policy Initiative Process

By Robert Mullin

Stakeholders last week voiced concerns about CAISO’s annual process for determining which “discretionary” policy initiatives the ISO should pursue in the coming year.

Critics expressed confusion about the criteria CAISO uses to rank the list of prospective initiatives, of which only a few will be ultimately incorporated into the 2017 stakeholder initiatives catalog and potentially become part of the ISO’s longer-term policy “roadmap.”

They also questioned how the ISO values their contributions to the effort, which factors in stakeholder input as a key variable to rank potential initiatives but does not subject proposals to an outright stakeholder vote.

During a Nov. 3 conference call to kick off the process, Neil Huber, an energy trader with XO Energy, noted that he’s provided comments on the initiatives for the past three or four years.

“The answer seems to come back each year that there’s not enough bandwidth to work on a substantial number of projects,” Huber said.

Brad Cooper, market design and regulatory policy lead at CAISO, said the policy initiative process can be broken into two steps.

The first step consists of revising the catalog by adding new proposed initiatives and deleting those that have become obsolete. Initiatives listed for the catalog then become candidates for the roadmap, although there’s no guarantee they will immediately become action items.

In the second step, ISO management and stakeholders rank discretionary initiatives in order to elevate the most popular for development and implementation based on their feasibility and potential benefits.

Benefits include reliability and market efficiency improvements, as well the ISO’s perception of the stakeholders’ desire for the change.

The feasibility category attempts to capture how much money and ISO and stakeholder resources it will take to implement the proposal.

Most initiatives already in the roadmap are considered “nondiscretionary,” meaning that they address “significant” reliability or market efficiency issues, represent previous commitments to stakeholders or the Board of Governors, or have been mandated by FERC.

‘Bandwidth’ Issue Addressed

Just a few discretionary initiatives can be slipped into the ISO’s roadmap each year. Cooper estimates there will be room for two or three next year, depending on the scope of the initiatives selected.

Greg Cook, the ISO’s director of market and infrastructure policy, responded to Huber’s concern about the lack of bandwidth to handle more stakeholder requests for initiatives.

“There’s a lot of resource constraints we take into account,” Cook said, noting that some stakeholders have told the ISO that “they can only handle a certain number of initiatives at any given time.” Smaller stakeholders are particularly constrained because of staff limitations, he said.

CAISO also considers the timeline for implementing a policy when deciding whether to prioritize it.

prioritization-criteria-caiso-alt-fi — Some stakeholders questioned the soundness of CAISO’s scoring system for potential policy initiatives. | *CAISO*

“We don’t want to schedule a policy development on an initiative that we’re not going to be able to implement for a number of years,” Cook said. “Likewise, if there’s an initiative that’s going to have a long time for the policy development that we want to implement by a certain time — that’s going to play in as well.”

Huber countered that — even as a small market participant — he has “bandwidth to work plenty of stuff I’m interested in.” He contended that a bigger issue for his company is that some of the smaller proposals that it requests never make it to the top half of the list of initiatives.

“So it seems like each year — specifically as a smaller entity — I just don’t make much progress,” Huber said.

Stakeholders had questions about the mechanics and philosophy behind the initiative ranking process.

Under the ranking system, the ISO assigns scores — 0, 3, 7 or 10 — to various benefits and feasibility categories of a potential initiative, the sum of which determines an initiative’s place in the overall standings (see chart).

CAISO has already published “first-cut” rankings showing that the current top six initiatives concern real-time market enhancements, generator risk-of-retirement issues, congestion revenue rights auction efficiency, donation of transmission capacity for EIM transfers, multiyear resource adequacy contracts and the altering of export charges.

Stakeholders were not asked to provide their own scores but were given the opportunity to formally comment on the list of potential initiatives — input that the ISO used to inform its formulation of the scores. Some meeting participants were especially curious about one ranking criteria: “desired by stakeholders.”

“Since you didn’t have stakeholders submit rankings prior to you doing your preliminary rankings, what was the input for ‘desired by stakeholders?’” asked Bonnie Blair, a consultant representing the Six Cities municipal utilities — Anaheim, Azusa, Banning, Colton, Pasadena and Riverside. “Was it just impressionistic?”

“We get input from stakeholders all the time,” Cooper responded. “I think we’ve a pretty good sense what’s desired by stakeholders,” adding that the scoring for the category “is based on our impressions of what we hear.”

‘Not That Scientific’

Cook pointed out that the category generally reflects whether an initiative is desired by a majority of stakeholders or just a few.

“It’s not that scientific,” Cook said.

Blair maintained that scoring of the category seemed vulnerable to skewing, particularly for initiatives representing the interests of a vocal minority — such as export charges.

Carrie Bentley, a consultant representing the Western Power Trading Forum, questioned how the ISO would adjust its rankings based on stakeholder input.

“We were envisioning this year people just submitting where they differed from us on our scores, just submitting written comments on how they think the scores should be revised and then providing the rationale for why,” Cooper said.

Bentley wondered whether the ISO would change the “desired by stakeholder” number just based on what people comment on.

“For example, if I don’t really want something and think it’s stupid, should I comment on it and say it’s stupid and do a zero, or should I just not say anything at all?” Bentley asked.

“Comment on it, say it’s stupid and do a zero, and we might have other people that agree with you and revise our score down,” Cooper said.

David Oliver, a managing consultant at Navigant Consulting, wondered why the ISO hadn’t chosen a simpler 1-4 scoring scale.

“I don’t recall exactly where the scale came from, but it’s just something we’ve been using,” Cook said. “This was just trying to have a little more separation in the rankings.”

Michael Rosenberg, principal trader for ETRACOM, asked whether the input of the ISO’s Department of Market Monitoring would be given more deference than that of other stakeholders.

“We don’t give more weight to one stakeholder over another,” Cook said. “We weight it by how well the arguments are stated.”

The ISO is seeking stakeholder comments on its initiative rankings by Nov. 17. An updated roadmap will be presented to the board Feb. 15, 2017.

November 8, 2016

Westar Boosts Earnings Amid Pending Acquisition

By Amanda Durish Cook

In what may be one of its last earnings reports as an independent company, Westar Energy said it improved its third-quarter earnings over 2015 while falling two pennies short of Zacks Investment Research’s consensus forecasts at $1.09/share.

The Topeka, Kan.-based company reported net income of $155 million in the quarter, besting last year’s showing of $138 million ($0.97/share).

Westar Energy's Jeffrey Energy Center | Westar — Westar Energy’s Jeffrey Energy Center | *Westar*

Westar said the rise was due to rate increases granted by the Kansas Corporation Commission this spring and an increase in corporate-owned life insurance income. (According to its 10-K filing for 2015, Westar reports as income increases in the cash surrender value and death benefits of its policies.)

Year-to-date earnings are $40 million above the $253 million earned through the same period third quarter of 2015. But the company said the higher revenue was “partially offset by a Southwest Power Pool assessment and higher expenses due to improving long-term grid reliability.”

Westar did not host a quarterly conference call because of its pending sale to Great Plains Energy. The company said it would not hold any future earnings conferences before the deal closes. (See Great Plains Energy, Westar Shareholders OK $12.2B Deal.)

The earnings announcement comes two weeks after Kansas regulators warned that they might block the merger because of staff’s conclusion that the companies’ filing lacked information on costs savings and what operations would continue in Westar’s Topeka headquarters (Docket No. 16-KCPE-593-ACQ).

A spokesperson for the two utilities said they did not expect the commission’s concerns to alter the merger’s spring completion target. The companies filed for joint application reconsideration Nov. 2, adding testimony from two Great Plains employees attesting to future customer savings and the reasonableness of the purchase price. However, Great Plains staff said the allocation of savings as a result of the merger is unknown and no final determinations have been made on what departments will remain in the Topeka office.

Great Plains recently struck a compromise with the Missouri Public Service Commission that requires the company to keep its capital structure and credit ratings isolated from Westar’s. The agreement also bans Great Plains from seeking increases in retail rates or capital spending because of the purchase. Great Plains initially maintained that the Missouri PSC had no jurisdiction over the sale.

November 8, 2016

MISO to Use Same Sub-Regional Limit Rules for 2017/18 PRA

By Amanda Durish Cook

CARMEL, Ind. — MISO will continue its current treatment of the sub-regional transfer limit in the Planning Resource Auction, both in deciding the initial limit and subtracting firm transmission reservations, RTO officials told the Nov. 2 Resource Adequacy Subcommittee meeting.

Under that same approach, the preliminary limits for the 2017/18 PRA are 984 MW for South to North and 3,000 MW for North to South, MISO Director of Forward Operations Planning Kevin Sherd said.

The RTO said it believes its approach — which deducts firm reservations from 2,500 MW for flows South to North and 3,000 MW for North to South — curbs the curtailment risk that use of non-firm contract paths could introduce.

Some stakeholders had argued for changing the value used in the initial limit and possibly reassessing the deduction of firm flows from the limit, saying the current approach was overly conservative as not all firm reservations are used.

MISO is also at the center of a FERC complaint filed by its transmission customers, which argue the limit is too strict and traps capacity in MISO South, driving up clearing prices. (See MISO Recommends No Change to Transfer Limits.)

The RTO is expected to publish the final sub-regional import and export limits before March 1. Sherd said MISO plans to continue to evaluate the sub-regional limit methodology for future auctions.

WPPI Energy engineer Steve Leovy said MISO should still consider alternatives to the calculation of the limit.

RASC liaison Renuka Chatterjee said subtracting firm reservations in the sub-regional limit is consistent with the treatment of other capacity import and export limits. Leovy said the treatment was not equitable since the RTO considers pseudo-ties in capacity import and export limits and does not model pseudo-ties in the sub regional limit.

No Change to External Resource Treatment, Either

MISO also is electing not to change the PRA’s treatment of external resources any earlier than other auction changes set for the 2018/19 planning year.

MISO Manager of Resource Adequacy John Harmon said after careful consideration, the RTO will not introduce a locational construct in the 2017/18 PRA. Instead, MISO is seeking a permanent solution as part of a larger bundle of auction changes, including a seasonal construct and separate forward auction, in time for the 2018/19 planning year. The RTO had suggested that it could roll out six new external zones in the capacity auction next year. (See “MISO to Move Ahead with Brattle Demand Curve for Forward Auction,” MISO Resource Adequacy Subcommittee Briefs.)

“We feel strongly that changes regarding a locational construct should be part of a larger reform and not a one-off change,” Harmon said. He added that MISO is looking to do its due diligence on a more comprehensive solution and avoid the “whiplash” of adopting one interim solution then distancing itself from the temporary solution by the time it formulates permanent rules.

Dynegy’s Mark Volpe said that while he appreciated the RTO’s desire to develop a permanent solution, external resources should not be on equal footing with resources in zones inside the RTO’s footprint.

MISO will continue discussion of external zone creation in 2017.