SPP’s Board of Directors and Members Committee on Tuesday approved a set of conditions that will guide Mountain West Transmission Group’s pending membership into the RTO.
SPP said the board’s endorsement during a special meeting in Dallas represents “a vote of confidence in the value of Mountain West’s membership and the benefits it will bring to SPP’s existing members, the Mountain West entities” and their customers.
COO Carl Monroe, who has been leading the RTO’s team during the negotiations, told RTO Insider he has been pleased with the work so far.
“We have been able to alleviate some of [Mountain West’s] concerns with joining SPP,” Monroe said Wednesday. “We’ve been able to work together and move forward. We’re pleased to come to this point, where we have general agreement of the things that are required to have Mountain West join SPP.”
The board approved 18 policy statements and directed staff and stakeholders to begin revising SPP’s Tariff, bylaws, membership agreement and other governing documents. The RTO’s Corporate Governance Committee and working groups will coordinate the work through the normal stakeholder process.
Changes to SPP’s Governing Documents Tariff will be presented for approval by stakeholder groups prior to going to the Members Committee and board.
The policies govern the terms of SPP membership, governance, the cost to operate the four DC ties in the SPP footprint, transmission planning and resource adequacy, and rates and revenue. SPP’s Regional State Committee would be expanded to include state commissioners from the Mountain West region.
SPP has scheduled a webinar on March 22 to provide further detail on the policies.
SPP and Mountain West members have been meeting behind closed doors since October to discuss the move. Monroe told stakeholders in January that a small negotiating team had been working to resolve a subset of “real contentious” issues. The Mountain West entities have suggested several governance changes important to their side of the footprint. (See SPP, Mountain West Resolving ‘Contentious’ Issues.)
Mountain West has said studies have shown participating in SPP’s markets and efficiently using the DC ties between the two footprints would yield annual savings of $80 million to $154 million for its members. The entities also expect to realize additional benefits from regional transmission planning and SPP’s other services.
SPP has estimated its current members could receive more than $500 million in total net benefits over the first 10 years of Mountain West’s membership through reduced administrative costs because of a larger customer rate base, adjusted production cost savings from east-west energy exchanges and capacity cost savings from increased load diversity.
The RTO projects it will take about two years to fully integrate the Mountain West entities as members, but it plans to begin reliability coordination services in late 2019.
SPP currently serves a 546,000-square-mile, 14-state region. Mountain West’s membership would add 165,000 square miles, 16,000 miles of transmission lines, 21 GW of generating capacity and parts of three more states (Arizona, Colorado and Utah) to the RTO’s footprint.
Mountain West, which primarily services Colorado, Wyoming and Nebraska, began discussing RTO membership in 2013. It announced in January 2017 it was pursuing membership in SPP, and discussions entered a public phase in October. (See SPP, Mountain West Integration Work Goes Public.)
New York stakeholders on Monday wrestled with the complex issue of how to evaluate the impact of a carbon charge on the dispatch of energy resources — especially in neighboring regions.
It was part of an ongoing effort by the Integrating Public Policy Task Force (IPPTF) to determine how to price carbon emissions into NYISO’s wholesale electricity market.
The group, a joint effort between NYISO and the state’s Department of Public Service, also discussed a method for calculating marginal emission rates, the allocation of carbon revenues and the effect of carbon pricing on customer bills — all part of “Track 5” of the carbon pricing initiative.
| PJM
The group also touched on issues related to “Track 4,” which covers the interaction of carbon pricing with other state and regional programs, such as the renewable energy credit and zero-emissions credit programs, as well as the Regional Greenhouse Gas Initiative.
Assumptions and Metrics
“We are interested in looking at not just the financial impacts but also at what happens to emissions,” said task force co-chair Nicole Bouchez, NYISO market design specialist.
“How do we assume the cases?” Bouchez asked. “Do we assume there’s a change in RGGI or not? In realization that we’re not going to be able to run dozens of permutations, what are the key assumptions?”
If the group “ends up modeling emissions in neighboring regions, for example in Ontario, which trades with MISO, then you have to model all of MISO’s resources,” she said. “While Ontario may look like a low-carbon import … if all it’s doing is causing MISO coal use to go up, then not so much.”
Marc Montalvo, representing the DPS Utility Intervention Unit, said, “If we’re designing a policy and implementation, if success is highly dependent on having perfect or near-perfect information about our neighbors’ emissions rates and those kinds of things, then it’s probably not a good policy in the first instance.”
Bouchez said the group’s May 7 and 21 meetings would focus “on how to structure the analysis, what questions, what metrics we’ll be reporting, etc.”
Defining Impacts
During a discussion of the impact of carbon pricing on consumer costs, Bouchez said the ISO’s locational-based marginal pricing (LBMP) represents “only the beginning of impacts on consumers because we’re also going to be looking at the return of these residuals associated with a carbon charge to consumers, so you can’t just look at the LBMP increase on its own.” The “residuals” refer to leftover money refunded to load under a carbon pricing scheme.
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Representing a coalition of large industrial, commercial and institutional energy users, Couch White attorney Michael Mager said his clients were seeking “two big things” from the impact analyses. First, “a thorough, unbiased analysis” of the impacts on market prices and what consumers are paying.
“And the second piece is, what are the emission reductions, if any, that reasonably could be anticipated if this were to be done,” Mager said.
New York could see some really material carbon reductions if it starts retiring unused RGGI allowances, he said.
“On the other hand, if nothing is being done to RGGI whatsoever, and it’s just going to simply reduce the price of allowances that are going to be then used up by other states such that there’s little to no reduction in carbon throughout the RGGI region, then this whole effort strikes us as somewhat symbolic and not getting much for any price impacts,” he said.
Howard Fromer of PSEG Power New York asked, “Consumer impacts compared to what?
“And the what is not identified here,” Fromer said. “Obviously, the what, in my mind, has to include the fact that New York state right now is already spending and writing checks on a monthly basis and potentially, over the period that we’re talking about, could be spending billions of dollars.”
Fromer said that, aside from considering dispatch issues, the task force process also needs to consider the impact of a carbon charge on price signals, demand response and investment in the state’s 40,000-MW generation fleet.
No Pot of Money
Stakeholders asked how the trend of increasing electrification — in the transportation sector, for example — should affect pricing carbon into the wholesale market.
Bouchez said many experts have told her the price of electricity has very little to do with electrification.
Bob Wyman of Dandelion Energy countered that electricity prices definitely affect consumer choices in New York City, where Consolidated Edison learned that city residents who install heat pumps use them for air conditioning but simply turn them off in winter because of high electricity prices for heating.
“Whether this approach is complementary or designed to supplant the mandated programs [such as the state’s Clean Energy Standard] … to the extent that you are supplementing the existing programs, the issue is always about what are the incremental benefits, does it affect dispatch, new investment, how are the effects by zones, and you have to address those transition overlap and windfall revenue questions as part of the impact analysis,” said James Brew of Nucor Steel Auburn.
| NYISO
He said New York is relatively unique in trying to pursue both mandated and market programs, which means any analysis has to examine how the two programs interact.
David Clarke, director of wholesale market policy at the Long Island Power Authority, said carbon revenue collections within RGGI states would be a useful metric for examining the cost of abatement.
“I know we’re going to be looking at how much folks are paying for carbon allowances within New York as kind of the pot of money that we’re going to be splitting, but it would also be useful, depending on what scenario you are running, to find out what folks are collecting in terms of RGGI revenues within the other RGGI states,” Clarke said.
“There will be no pot of money,” Bouchez said. “I’ve been talking about them as residuals, which is how NYISO sees them, residuals being the difference between what we collect and what we pay out. How you allocate that within the wholesale settlements is a question. Do you give it back on a per-megawatt-hour basis? Do you give it back based on the impact of the increase in the LBMP?”
Warren Myers, DPS chief of regulatory economics, said that the joint staff are “nowhere near having an answer” on how to integrate multiple analyses into something useful but that “the work would get done by rolling up our sleeves” over the next few months.
The task force will next meet on March 19 to discuss Track 5 at NYISO headquarters.
FERC on Monday approved MISO Tariff revisions allowing the RTO to gather more information about proposed energy resources before they enter the interconnection queue.
Key among the changes is a requirement that a developer provide clearer upfront information about who will own a generating unit once its clears the queue.
In its ruling, FERC agreed the changes will “provide greater clarity to interconnection customers and greater transparency to all parties in the interconnection process” (ER18–636). The new measures became effective March 1.
Under the new rules, interconnection customers must provide MISO upfront documentation of “legally binding relationships” with parties that may claim ownership rights to a facility during the interconnection process.
MISO said the change will reduce the time it spends confirming ownership changes and will be necessary only when an interconnection customer “reasonably anticipates” another entity may claim ownership rights. The documentation would be limited to “that necessary to confirm the legal status and relationship of the relevant entities,” the RTO said.
Interconnection customers associated with a project can sometimes change during the definitive planning phase (DPP) of the interconnection queue, MISO said in its filing. In those cases, the RTO must confirm the legal status and relationship between the original and newly designated interconnection customers, creating an “administrative burden … that hinders the ability of MISO staff to administer other aspects” of the DPP.
“Requiring documentation proving legally binding relationships with entities that the interconnection customer reasonably anticipates may claim rights under the interconnection request upfront in the interconnection request form will ease administrative burden if a facility changes ownership later in the interconnection process,” FERC said, adding the change will help expedite projects moving through the DPP.
The commission rejected EDF Renewable Energy’s protest that MISO didn’t justify its need for the additional detail and that the changes would give the RTO more information than it needed. The company alternatively proposed that interconnection customers provide MISO with documentation “confirming a legally binding status upon requesting a name change,” rather than at the outset of the process. FERC said EDF was conflating name changes with changes in ownership status.
The Tariff revisions also require interconnection customers to provide MISO with IRS W-9 forms; banking information (including for other companies that may claim ownership in a generating facility); GPS coordinates for the point of interconnection for a project; descriptions of the number of generators, inverters, and transformers involved in the interconnection request; and additional contact information when a customer uses an agent.
They also expand the service options listed on MISO’s interconnection request form, allowing customers to specify a net-zero interconnection service request for an existing facility with no increase in capacity; indicate whether a request should be considered for the RTO’s fast-tracked process offered to small generating facilities; and inform MISO when a request for network resource interconnection service is intended for an existing facility.
The new rules additionally stipulate that net-zero interconnection customers must attach a system impact study to their requests and provide MISO with all necessary data before generator interconnection agreement negotiations can begin.
CARMEL, Ind. — MISO and its stakeholders have agreed on a plan to treat merchant HVDC lines as transmission instead of generation when physically connecting to the RTO’s system.
A year in the works, the proposed Tariff revision would subject merchant HVDC lines to MISO’s traditional transmission schedule charges and make them ineligible for interconnection service. The RTO will file the proposal with FERC by the end of this month.
Speaking at a March 14 Planning Advisory Committee meeting, MISO Director of Resource Utilization Vikram Godbole said the proposal does not prescribe any revenue plans for developers of merchant HVDC service. Developers would instead be responsible for determining the “net economic viability of their merchant HVDC project by considering their revenue streams and cost to connect to MISO transmission,” he said.
Some stakeholders asked how the RTO will treat transmission upgrades needed to connect HVDC lines in the interconnection queue.
“They’re not going to have interconnection rights,” Godbole said, adding that the lines will instead connect to the MISO system at a 0-MW status.
Under the changes, MISO will hold discussions with HVDC developers and owners before grid connection to determine whether a line is designed to withdraw or inject energy into the system, Godbole said. The RTO will require upstream generators contracting with injecting lines to procure network resource service through the interconnection queue, subject to system impact studies. Those units will be modeled like MISO’s other network resources, showing up in planning studies. Merchant HVDC customers that have secured injection rights and interconnection customers will share the costs of any needed network upgrades.
Meanwhile, merchant HVDC developers will be required to acquire MISO injection rights or a precertification that the system will be able to reliably handle the capacity and energy from proposed lines at the point of connection. (See “HVDC Interconnection,” MISO Eyes Small Queue Changes, Merchant DC Interconnections.)
Godbole acknowledged that MISO may eventually need to develop a more nuanced connection plan for merchant HVDC lines, but that, for now, it is focused on allowing such lines to connect to the system.
WASHINGTON — The Institute for Electric Innovation’s spring 2018 forum Wednesday featured a discussion on corporate renewable energy procurement and an appearance by Rep. Yvette Clarke (D-N.Y.), co-chair of the newly formed Smart Cities Caucus. Here’s some of what we heard.
Electric Industry an ‘Afterthought’ to FCC?
Edison Electric Institute Executive Vice President and former FERC Commissioner Phil Moeller told Clarke that the electric industry feels like an afterthought in the Federal Communications Commission’s discussions on the rollout of 5G cellular technology.
“We have another issue [at the FCC] with pole attachments and spectrum allocation, but particularly with [the] 5G network, our infrastructure is going to play a big role,” Moeller said. “Safety has to come first. We could probably use your help at the Smart Cities Caucus to remind the FCC that our industry should not be an afterthought but should be at the table during some of these discussions.”
“I agree wholeheartedly,” responded Clarke. “We’ve had hearings already with that in mind. That’s going to be a challenge in every corner of the nation because we’re going to be expected to utilize the infrastructure that already exists. So there has to be a collaboration. In many towns, cities, municipalities, there’s going to be a struggle about how you site these things.”
Corporate Renewable Procurements, Green Tariffs Growing
Letha Tawney, director of utility innovation for the World Resources Institute, led a panel discussion on corporate renewable energy procurements, noting that green tariff programs in 15 states have helped to bring 1 GW of new solar and wind projects to the grid since 2013.
“There’s been some successes,” said Tawney, whose organization works with utilities and customers to craft green tariffs. “How do we scale this? This is still pretty marginal. We just passed a gigawatt of transactions being signed. That’s not that much, really, in the whole U.S. market. … We need to do a lot more.”
Robert M. Blue, CEO of Dominion Energy’s Power Delivery Group, worked with customers like Steve Chriss, director of energy and strategy analysis for Walmart, in developing a new renewable generation (RG) tariff that functions as a contract for differences.
“The renewable generation tariff that we filed, a lot of it wasn’t working for a lot of customers,” Blue said. “That’s why we revised it. We heard from them what would make it work better and we expect that that will have a substantial impact.”
Last October, Dominion announced Facebook will build its eighth U.S. data center in the utility’s territory outside Richmond, Va., under a proposed new Schedule RF (renewable facility) rate structure, with which the company will offset its 130-MW load with renewables. Facebook’s goal is to power all its operations with renewable energy.
Walmart, which takes service from 1,000 utilities, has a goal of being 50% renewable power by 2025.
“We operate in a lot of states that aren’t deregulated and a lot of states where there’s not necessarily a market in place,” said Chriss. “In SPP or MISO, you can do a virtual [power purchase agreement] … but in Southern Co. or in some of the other big IOUs, there is no market, per se. So really, the market is their system and so you have to figure out structures that work within that.”
Even within Southern’s utilities, rules differ across state lines, Chriss said. “Our deal with Alabama Power [a 72-MW solar farm in southeastern Alabama that went into operation several weeks ago] … is very different from the Georgia [Power] structure.”
Nick Wagner, a member of the Iowa Utilities Board, discussed concerns over corporate procurements resulting in cost shifts to other customers.
“It’s no secret to probably anybody in this room that utility costs have been so highly socialized for a long time. It will take us some time to unwind those as we have the data” from cost-of-service studies, he said. “It’s probably a little more masked in the vertically integrated [states] than in the non-vertically integrated [states]. As we get more data, I think it’s going to become a little bit easier to separate those things out.”
Wagner said regulators’ efforts are aided by interventions by customers and other interest groups. “If nobody’s happy at the end of the day, but no one is really angry, you probably came to about the right place,” he said. “If someone’s walking out high-fiving, we know we messed up somewhere.”
VALLEY FORGE, Pa. — PJM stakeholders at last week’s Market Implementation Committee meeting approved two problem statements and issue charges presented by Exelon, over objections from the Independent Market Monitor.
Exelon’s Sharon Midgley presented both proposed investigations. The first problem statement and issue charge focused on PJM’s rule for forfeiting revenue from financial transmission rights if a market participant’s portfolio of day-ahead virtual bids creates a larger LMP spread in the day-ahead market than in real-time auctions.
Midgley argued that changes PJM implemented last year in response to FERC’s order to revise the forfeiture rule have made the rule overly restrictive, which Exelon says resulted in forfeiture of substantially more revenue from legitimate positions. A year-over-year comparison of monthly forfeitures before and after the rule changes took effect in 2017 shows as much as a $1.8 million difference in a single month.
The Monitor’s Howard Haas said that, while the rule changes have yet to be approved by FERC, they follow the commission’s guidance on the required changes. Given all the changes in the rule, he said, it was expected that the forfeiture numbers would be different than under the old rule, and the results under the old and new rule are not directly comparable. He said the observed level of forfeitures to date are in large part a result of the retroactive application of the new rule. Since information has become available under the new rule, participants have changed their behavior and forfeitures numbers are down dramatically. (See FERC Orders Portfolio Approach for PJM FTR Forfeiture Rule.)
PJM attorney Jen Tribulski agreed with Haas that the revisions the RTO filed for approval are in line with FERC’s order, but she said that Exelon’s concerns are “probably worth a discussion here” and that the commission’s order doesn’t prevent stakeholders from discussing and seeking approval for additional revisions. PJM’s Asanga Perera later noted in response to a stakeholder question that others have complained about the rule, though he didn’t have an exact number.
“It’s not only Exelon. We have seen other parties express concerns with the forfeiture rule,” he said.
Some stakeholders were unconvinced by Exelon’s argument but also reluctant to buck the tradition of supporting each other’s requests to analyze market procedures.
“I don’t know what we see that there is a problem, but I don’t know that we have much objection,” said Dave Mabry, who represents the PJM Industrial Customer Coalition.
Direct Energy’s Marji Philips said she would support the request but that it “seems premature” given the amount of work already teed up in stakeholder committees and the lack of clarity on how many market participants have been negatively impacted.
On Midgley’s second problem statement and issue charge on the exemption process for the must-offer rule, Monitor Joe Bowring said the focus of the analysis should expand to include how capacity interconnection rights (CIRs) would be handled for units that transition from capacity to energy. Midgley welcomed the revision.
Exelon’s request comes in response to difficulties the company has experienced with the timing of the current exemption approval process, specifically that it may be physically impossible to install dual-fuel capability within the three months between the third Incremental Auction and the start of the corresponding delivery year. Sites without winter fuel supplies may need to construct onsite oil storage, which can’t be completed in the three-month period. Midgley said it’s unclear what documentation needs to be submitted to receive approval for an exemption on such grounds.
The proposal would have stakeholders consider revising the guidelines for documentation required by the Monitor and PJM to grant an exemption, implementing process reforms to improve efficiency and establishing a process for resources with an existing must-offer requirement to become energy-only resources.
Both investigations were endorsed by stakeholders.
Hardware to Improve Day-ahead Performance
PJM announced it had purchased several new computer servers to address issues with delays in posting day-ahead auction results. The hardware was acquired as part of an ongoing two-year cycle to upgrade equipment, so there was no additional budget impact, PJM’s Todd Keech explained.
“We’re right into one of those refresh cycles now, so it was good timing,” he said.
Chantal Hendrzak, who chairs the MIC, acknowledged requests to expand the bidding window but said the RTO is focusing on posting the results sooner rather than increasing flexibility.
Five-Minute Settlements to Begin
PJM’s Ray Fernandez reminded stakeholders that units have until March 16 to sign up for five-minute settlements, which go into effect April 1. After that, resources will have to alert the RTO at least three days ahead of the desired change-over date before submitting five-minute revenue meter data.
Maintenance in Cost-Based Offers
PJM’s Tom Hauske said the RTO is considering whether to include maintenance costs in cost-based offers. Special sessions on variable operations and maintenance (VOM) costs produced three proposals, among which stakeholders will be asked to choose at next month’s meeting.
The current rules for what can be included in cost-based offers. | PJM
Cost-based offers created through current Manual 15 rules do not allow for inclusion of any maintenance costs. PJM’s proposal would allow for maintenance attributed to running the unit and directly tied to electricity production by including FERC accounts minus labor costs. Generators could also add operating costs, such as lubricants, chemicals and other consumables, into incremental energy offers, but not VOM.
PJM’s proposed changes would allow some maintenance costs | PJM
Energy-only resources or units that didn’t clear the delivery year’s Base Residual Auction could add their avoidable cost rate (ACR) fixed costs (such as staffing, taxes, fees, insurance and fuel availability) into their VOM, but capacity resources could not because they should recover those expenses through their capacity payments.
PJM also presented another proposal that would give resources the option of using its package or default resource-class VOM values calculated using U.S. Energy Information Administration data.
The Monitor’s package would replace “incremental” with “short-run marginal” in the Operating Agreement and would operate under the premise that all maintenance and labor costs are included in a unit’s capacity offer. The net cost of new entry (CONE) for each resource class would be modified to include maintenance and labor costs. Manual 15 would be stripped of all costs except short-run marginal ones: fuel, emissions, water, chemicals and consumables. A unit’s ACR would encompass everything else, including project maintenance expenses.
The Monitor’s proposal would redefine how offers are made by allowing only short-run marginal costs to be included. | PJM
“The IMM package is based on what a competitive offer in the market should be,” the Monitor’s Catherine Tyler said. “We also think this is the most straightforward and simple to implement.”
Once a proposal is approved, stakeholders would discuss implementation and time frame, Hauske said.
PJM ICC’s Mabry said “one of the big heartburns we have” is that overhaul and major inspection costs are included in VOM rather than ACR.
“That frankly weighs into the decision … should I go buy a new resource?” he said.
PJM’s proposal operates under the theory that VOM is recovered after it’s been spent, while ACR is what’s projected to be spent, Hauske said. He pointed out that if gas prices go up and a unit decides to run — and therefore performs maintenance — less often, it would have already received recovery for the higher amount of maintenance if it was recovered through ACR.
A representative of a transmission owner who asked not to be named said the default values are “pretty conservative” and should be based on actual costs, not averages. Tyler said the Monitor publishes its own defaults, but the TO representative said they’re not explained.
The default option would allow use of these or PJM’s proposal. | PJM
Long-term FTRs Undercut Annual FTRs
The Monitor appears to have won over PJM regarding its concerns about long-term FTRs. Haas presented analysis requested by stakeholders that showed the cost to auction revenue rights holders from the long-term FTRs market construct. Among other findings, Haas showed that over the past four planning periods, FTRs sold in the long-term market have been undervalued by more than $337.2 million compared to the annual FTRs for the corresponding delivery year. (See PJM Stakeholders Decline to Change Market Path Rules.)
Buyers of long-term FTRs only paid, at most, 3.5% of the total revenue from the total FTR revenue for the past four delivery years, even though they made up between a third and half of all FTR activity each year. This shows that they sold as a substantial discount to annual FTRs, which means that buyers could make profit by selling them back during the delivery year’s annual FTR auction. | Monitoring Analytics
The current long-term market construct doesn’t allow ARR holders to directly benefit from the sale of congestion rights, despite owning the rights to congestion, Haas said.
“I think we’re on the same page with [the Monitor] about most of the issues,” PJM’s Brian Chmielewski said.
The 2nd U.S. Circuit Court of Appeals on Monday heard oral arguments in an appeal of a judge’s decision to dismiss a suit against New York’s zero-emission credits program.
In filing the appeal, the Electric Power Supply Association and members Dynegy, Eastern Generation and NRG Energy joined Roseton Generating and Selkirk Cogen Partners in arguing that some generators would lose millions in revenue because the subsidized nuclear plants would suppress NYISO capacity and energy prices.
Indian Point Nuclear Plant
Judge Valerie Caproni, of the U.S. District Court for the Southern District of New York, last year granted motions to dismiss the case by the Public Service Commission, the defendant, and intervenor Exelon, owner of the three nuclear plants that would receive ZEC payments (16-CV-8164). (See New York ZEC Suit Dismissed.)
ClearView Energy Partners issued a statement on Monday’s arguments saying that at least two of the three appellate judges appeared skeptical of petitioners’ pre-emption claims that the ZEC program infringes on FERC’s exclusive jurisdiction over wholesale markets.
Miles Farmer of the Natural Resources Defense Council said in a blog post that the 2nd Circuit will likely provide the final say on the validity of New York’s ZEC program under federal law.
New York’s Clean Energy Standard and its provisions for subsidies for nuclear plants are also being challenged in state court. The Albany County Supreme Court in January rejected the state’s motions to dismiss outright a lawsuit challenging the ZEC program. (See New York Court to Consider ZEC Challenge.)
WASHINGTON — Speakers and attendees at Infocast’s 21st Transmission Summit East last week noted that “resiliency” was the buzzword of the event.
A consensus seems to have emerged on an industry meaning of the word that distinguishes it from “reliability”: the ability to reduce the magnitude and duration of a disturbance in grid operations.
But there was little to no consensus on how regulators and utilities should measure or value it. Nor was there any agreement on whether there is even a resilience problem to solve.
Michael Spoor, vice president of transmission for Florida Power & Light, opened the conference with a presentation detailing how the utility’s hardening of its system lessened the impact of last year’s Hurricane Irma compared to Hurricane Wilma in 2005. Since 2006, FPL has spent more than $3 billion to replace its wooden transmission and distribution poles with concrete and steel structures able to withstand 145-mph winds, as well as undergrounding some of its lines.
Despite Irma making landfall in Florida as a Category 4 storm (compared to Wilma’s Category 3) and affecting 1.2 million more customers than Wilma, it took eight fewer days for FPL to restore service to its customers.
But that was a case of a utility in a non-RTO state taking the initiative itself, without market-based incentives or federal directives.
“This isn’t a new problem. We’re using a new word, maybe, to define something that we’ve doing for a really, really long time,” Katherine Prewitt, vice president of transmission for Southern Co., said in a Wednesday panel on valuing resiliency.
“I think that the bottom line with regard to the word ‘resiliency’ has a lot more to do with policy and politics than it does with operations and what we’re doing on the ground,” said Barbara Clemenhagen, vice president of market intelligence for Customized Energy Solutions. Utilities have been complying with NERC reliability standards on a nonvoluntary basis, “but certainly I don’t think there’s any utility in the room who would say they wouldn’t volunteer to address all of these standards.”
Paul Kelly, director of federal policy for Northern Indiana Public Service Co., noted that a NERC report published last year found that resilience against weather-related events has been improving. “So there wasn’t so much of an alarm bell being sounded from the reliability organization, but nationally it’s become a very politically focused issue.
“We really want to make sure we make the right decisions, and that we have a really good understanding of ‘is there truly a problem?’”
The concept of N-1 — planning for the loss of a grid asset, such as a generator or a transformer — has “served us well for over 100 years,” Mohammed Alfayyoumi, director of Dominion Energy’s transmission system operations center, said in a panel on considering resiliency in grid planning. “But in today’s environment with a focus on resilience, I think we need to go beyond N-1, where we can look at N-2, N-5, depending on the situation.” Technology has progressed so that computers can calculate N-2 across the system, he said.
Paul McGlynn, PJM senior director of system planning, said natural gas pipelines are also important for resilience. “We need to expand [N-1 contingencies] to events on the pipeline system: loss of a pipeline, loss of compressor station or whatever may also impact part of your generation fleet.”
But Clemenhagen said there was a need for discussion on “the difference between a rational economic system that makes sense for … the consumers who are paying for it and, not just a gold-plated system, but a platinum-plated system that you hear some policymakers assume that we can have; not just N-1 but N-∞ contingencies.”
A former member of the British Columbia Utilities Commission, Clemenhagen said, “We need to be very careful to define [resiliency] … based on rational economics for consumer interests, because in the end, they have to pay for it. The end users are the ones who pay; I don’t care how you calculate it, whether it’s market-based costs or reliability-based costs, consumers will pay for these costs in the end.”
“We could platinum-plate the system, but I don’t think that’s what anyone wants,” Prewitt said.
“‘The ability to rapidly recover’ … looks a lot different in Louisiana that’s recovering from a hurricane event, than it does in my state of Indiana if we have an ice storm in the dead of winter,” Kelly said. “I think our standards in America are phenomenal because we emphasize reliability. And if I could take a dollar and invest it somewhere, I’d much rather invest it in reliability. I’d rather keep the lights on for my customers versus taking that dollar and shipping it over to resilience.”
Why Now?
Several moderators asked their panelists why resiliency was such a big focus of discussion lately — and each gave a somewhat different answer.
McGlynn talked about the threat of bad actors and cyberattacks. Aubrey Johnson, MISO executive director of system planning and competitive transmission, cited the reliance on electricity for almost every aspect of modern life, and that people are more aware of outages across the country. Alfayyoumi said that the grid is becoming more complex because of the rise of renewable resources. Clemenhagen, along with many other panelists and attendees, cited recent severe weather events across the country.
Barely mentioned, however, was Energy Secretary Rick Perry’s proposed Grid Resiliency Pricing Rule, which called for RTOs to pay the full operating costs for generators with 90-day onsite fuel supplies. In testimony before Congress, Perry cited the polar vortex of 2014 as evidence for the rule’s need. (See Perry Defends Call for Coal, Nuclear Supports.)
However, the proposal was apparently based on an “action plan” from coal producer Murray Energy that called for “immediate action … to require organized power markets to value fuel security, fuel diversity and ancillary services that only baseload generating assets, especially coal plants, can provide.” (See Photos Show Murray’s Role in Perry Coal NOPR.)
FERC eventually rejected the proposal, instead opening a new docket to document how each RTO and ISO assesses resilience and use the information “to evaluate whether additional commission action regarding resilience is appropriate.” The summit came on the eve of the due date for the grid operators’ responses. (See related story, RTO Resilience Filings Seek Time, More Gas Coordination.)
“Resiliency means different things to different people,” John Lawhorn, senior director of policy and economic studies for MISO, said in a Thursday panel on the status of wholesale market reforms. “From my personal perspective, I think the risk associated with overbuilds is much less than the risk associated with underbuilds. But we need to be able to quantify that information for presentation to our stakeholders and our regulators to have them weigh in to evaluate how much risk they want to take.”
“There are different ways to address [resiliency], but the definition of what it is and how you solve that and measure it, from my perspective, is very important,” said Keith Collins, executive director of SPP’s Market Monitoring Unit.
“I don’t know what FERC’s going to do with this,” PJM General Counsel Vince Duane said, sounding almost weary. “They’re going to have a tremendous amount of information, and it’s going to be leading in a lot of different directions, so I don’t envy their task. And it’s hard to offer tangible and concrete suggestions, but at PJM we’ve tried to do that in our comments tomorrow as best we can.”
CARMEL, Ind. — After almost three years of deliberation, MISO is putting the final touches on a plan to create external resource zones for its annual capacity auction by 2019.
Under the proposal, which is poised for a FERC filing at the end of this month, MISO would alter its Planning Resource Auction to include external resource zones based on neighboring balancing authority areas (BAAs). In cases of price separation, the RTO would also distribute historical supply arrangement credits from excess auction revenues as a refund to external resources with long-term and consistently used historical supply agreements.
The proposal would also establish new zonal capacity export limits in time for the 2019/20 planning year auction. Those limits would be based on the unforced capacity values for external resources participating in the auction in each external zone.
External zones would not have capacity import limits, planning reserve margin requirements or local clearing requirements. Resources in zones based on BAAs that border MISO Midwest zones will clear at one price based on a subregional unconstrained auction clearing price, while those in BAAs bordering MISO South will receive another price. BAAs that border both MISO Midwest and MISO South — Tennessee Valley Authority, SPP, Associated Electric Cooperative Inc. and Southwestern Power Administration — will receive a blended price. (See MISO Postpones External Zones Until 2019 Auction.)
Speaking at a March 7 Resource Adequacy Subcommittee, Laura Rauch, MISO’s director of resource adequacy coordination, said the RTO would provide capacity hedges only to external resources with historical capacity arrangements, despite stakeholder requests for hedges for other newer external resources.
MISO intends to tweak the proposal before filing, including adding potential penalties for external resources that don’t offer into the PRA after qualifying and registering for the auction. Under the current proposal, those resources would only face “questions” from the Independent Market Monitor but face no specific consequences for withholding, Manager of Resource Adequacy John Harmon said.
Rauch also said stakeholders are still asking how MISO will differentiate a “border external resource” from other external resources. In November, MISO said it identified 3,837 MW of capacity from potential border external resources, which have direct electrical connections to the RTO but are located in another balancing authority. Some stakeholders last month said that the concept of border resources amounts to preferential treatment of some external resources.
Rauch clarified that a border external resource’s point of interconnection must be a substation on the border.
“We really want these to be resources physically on the border,” she said.
MISO will rely on the volume of zonal capacity registered to participate in the auction to calculate an external zone’s capacity export limits, which will be posted each November ahead of the auction, Rauch said. Participating resources must maintain firm transmission to at least the MISO border, she noted.
“Trying to study a slice of PJM or SPP” to determine a capacity export limit is too complex a task, Rauch said.
She said MISO does not foresee any binding external capacity export limits, except in rare cases that exports fail a simultaneous feasibility test.
If FERC approves the filing, MISO will begin developing business practice manual language with stakeholders beginning in June, Rauch said.
Meanwhile, MISO will open its 2018/19 PRA offer window at 12:01 a.m. on March 27 and close it on March 30 at 11:59 p.m. Results will be posted by April 12.
SPP has scheduled an executive session of its Board of Directors and Members Committee for Tuesday to discuss admitting Mountain West Transmission Group’s members into the RTO.
The meeting is being held at an undisclosed location. SPP has often used Dallas/Fort Worth International Airport to meet for its ease of access and onsite hospitality facilities.
SPP CEO Nick Brown told the Board of Directors in January the RTO was hoping to hold a “decision meeting” for members at the end of February for those stakeholders “who need to engage outside counsel and consultants, who previously were not engaged in the debate.”
SPP and Mountain West members have been meeting behind closed doors since October. SPP COO Carl Monroe told stakeholders in January that a small negotiating team had been working to resolve a subset of “real contentious” issues. The Mountain West entities have suggested several governance changes important to their side of the footprint. (See SPP, Mountain West Resolving ‘Contentious’ Issues.)
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Brown said SPP’s primary goal for 2018 is integrating Mountain West. “Our goal is to get it over the line in early 2018,” he said.
With members primarily serving Colorado, Wyoming and Nebraska, Mountain West began discussing joining or creating an RTO in 2013. It announced in January 2017 it was pursuing membership in SPP, and discussions entered a public phase in October. (See SPP, Mountain West Integration Work Goes Public.)
The two entities are working on an Oct. 1, 2019, target date for membership.
Record $6.9M in January for Market-to-Market Payment
SPP’s Riverton-Neosho-Blackberry flowgate — quickly becoming recognized by just its 5375 ID — was binding for 350 hours in January, resulting in a record $6.9 million market-to-market (M2M) payment from MISO. The Kansas-Missouri border flowgate was responsible for $6.2 million of the charges, more than all the flowgates combined in any other single month.
SPP has accumulated almost $44 million in M2M payments since the two RTOs began the process in March 2015. MISO has not had a month in its favor since last July and only nine overall.
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SPP staff told the Seams Steering Committee on March 7 that they have been implementing an “enhanced shadow price override” non-monitoring RTO process on swing-related flowgates since Jan. 4. The two RTOs are also considering implementing a “monitoring RTO reverse role,” where MISO would control the physical flow on a flowgate and SPP control the market flow.
Permanent and temporary flowgates were binding for 632 hours in January, SPP staff told the committee.
Staff also briefed the committee on FERC’s April 3-4 technical conference related to how SPP, MISO and PJM coordinate generator interconnection studies on projects near their seams. The commission called the conference to address issues raised in an October complaint by EDF Renewable Energy, which contends that inconsistencies and a lack of clarity in the RTOs’ rules for “affected systems” interferes with developers’ ability to judge the commercial viability of proposed projects. (See FERC Orders Review of PJM, MISO, SPP Generator Studies.)
SPP, AECI Wait on Joint Study Scope
SPP and Associated Electric Cooperative Inc. last week failed to reach an agreement with their stakeholders on a scope for a 2018 joint study during an Interregional Planning Stakeholder Advisory Committee meeting. Another IPSAC will likely be scheduled in a few weeks, giving members a chance to review the draft scope with their companies and providing staff additional time to revise its models.
SPP staff said they had drafted a scope that identified needs from its 2018 near-term assessment that are “electrically significant to the SPP-AECI seam.”
The RTO plans to use its near-term assessment models, which have already been approved by its stakeholders. AECI regularly participates in the near-term model-building process, which allows the two entities “to explore a broader set of projects which could potentially provide benefit to both systems,” SPP staff said.
