SPP Seams Steering Committee Briefs

SPP stakeholders agreed on Wednesday to amend a two-year-old policy paper and clarify when FERC approval would be needed to allocate costs for some seams projects between 100 kV and 300 kV.

The Seams Steering Committee voted 6-1 in favor of the change.

The change clarifies that the RTO will recover costs for seams projects greater than 300 kV under its regionwide highway cost allocation methodology. Costs for projects lower than 300 kV would also be allocated under highway funding unless the project meets certain criteria. In those cases, the Regional State Committee or Markets and Operations Policy Committee could recommend costs be allocated using SPP’s highway/byway methodology.

The highway/byway methodology considers facilities of 300 kV or above as highway facilities, with their costs allocated on a regionwide, postage stamp basis. Facilities between 100 kV and 300 kV are categorized as byway facilities, with two-thirds of the costs assigned to the host zone and one-third allocated regionwide. Projects below 100 kV are allocated entirely to the host zone.

Under the revised language, projects or tie lines of 100 kV or higher within a seams partner area could be allocated regionwide. Alternatively, based on the results of a seams project study, the RSC and the MOPC may recommend the Board of Directors approve cost allocation under the highway/byway cost allocation methodology, with the byway costs assigned to a zone expected to receive at least 60% of the project’s benefits. If the board approves such cost allocation, it would seek FERC approval on a project-by-project basis.

Within SPP, projects and tie lines of 100 kV or higher could also be allocated regionwide subject to FERC approval on a project-by-project basis, potentially expanding the number of projects that can be funded through the highway/byway methodology. FERC approval would be required only if the Tariff does not already allow such cost allocation.

Otherwise, based on the seams project study, the MOPC and/or the RSC can recommend the board approve highway/byway cost allocation if a single zone will receive at least 60% of the benefits. No FERC approval would be required.

SPP defines seams projects as non-interregional projects of 100 kV and above that benefit the RTO and one or more neighbors with a minimum cost of $5 million, and usually require a benefit-cost ratio of at least 1.0. SPP and the seams partner must agree to cost sharing.

ITC Holdings’ Marguerite Wagner cast the lone dissenting vote. Wagner and ITC contended the revisions would carve out seams projects from FERC’s Order 1000 process “without justification.”

Wagner expressed a preference for FERC-enforceable joint operating agreements to determine project cost allocation. David Kelley, SPP’s director of interregional relations, noted that would require the negotiation of a series of JOAs with multiple seams partners.

“I don’t know whether there’s a one-size-fits-all formula we can put down,” he said.

Two other committee members, the Northeast Texas Electric Cooperative and Xcel Energy, abstained.

The FERC filings would be necessary because the SPP Tariff does not currently allow highway/byway cost allocation of seams projects.

The policy changes reflect input from the board and RSC since the paper was originally approved in 2014. Staff said the paper will remain separate from SPP’s business practices and other governing documents and not require a revision request.

The revisions struck previous language that would have required seams projects greater than 300 kV to be recovered according to the highway/byway methodology. Those projects below the 300-kV threshold would have been recovered regionally through highway funding.

The committee will now send the policy paper to the Cost Allocation Working Group for its review. It hopes to have a finalized document for approval by the April meetings of the board, MOPC and RSC.

SPP-AECI Joint Study Recommends Two Projects

SPP and Associated Electric Cooperative Inc. staff are proposing two joint projects addressing thermal overloads and high-voltage issues along their seam in southern Missouri, according to a draft version of the biennial SPP-AECI Joint and Coordinated System Plan report released Friday.

The report identified a reactor in and/or around SPP’s 345-kV substation in the Brookline area and a new 345/161-kV transformer at AECI’s Morgan substation, along with an uprate of the 161-kV line between Brookline and Morgan, as being “mutually beneficial” to both entities.

Kelley told the committee the Morgan portion of the projects is “effectively” on the AECI system and will still have to undergo a regional review.

SPP and AECI evaluated 56 different potential transmission solutions to address the Brookline area’s needs. Staff looked at five targeted areas in all but determined one was no longer an issue and agreed the other three could be managed without joint projects.

Any final solutions will be coordinated with the SPP 2017 Integrated Transmission Planning’s 10-year assessment.

The joint study focused on predetermined target areas “to concentrate study resources on the geographic areas along the SPP-AECI seam most likely to benefit from mutually beneficial transmission projects.” Those areas were determined by historical analysis, operational experience, recent regional planning efforts and stakeholder feedback.

The SPP-AECI joint operating agreement requires a joint study be conducted every two years to ensure “reliable, efficient and effective operation[s]” along the seam.

Stakeholder comments on the report are due to SPP’s Adam Bell or AECI’s James Vermillion by Friday. That feedback will be incorporated in the final version of the joint study, which will be posted on SPP’s website.

Based in Springfield, Mo., AECI is owned by six regional generation and transmission cooperatives.

MISO M2M Payments Total $1.2M in November

spp seams cost allocation

Staff’s monthly market-to-market update once again showed a large flow of dollars from MISO to SPP, primarily attributed to temporary flowgates between the two RTOs. MISO sent $1.15 million to SPP in November, with $879,305 coming from temporary flowgates, and it has now compensated its seams neighbor more than $12.4 million for M2M since March 2015.

Temporary flowgates incurred 265 hours of binding M2M, with permanent flowgates accounting for 92 hours binding.

– Tom Kleckner

MISO Aims for Improved Frequency Response Modeling

By Amanda Durish Cook

MISO is seeking stakeholder input on how to address declining frequency response capability within the RTO.

“Frequency response has deteriorated in the Eastern Interconnection over the years,” Michael McMullen, MISO director of regional operations, said at the Jan. 5 Reliability Subcommittee meeting. “It’s currently adequate, but we want to make sure it doesn’t get any worse.”

System operators must maintain the grid at a frequency of 60 Hz in order to maintain network stability. An uncontrolled drop in frequency increases the threat of cascading blackouts.

The RTO says it needs better modeling and is considering more in-depth data collection to support its efforts to improve response to frequency disturbances.

miso, frequency response

“There is something in the model that isn’t right,” McMullen said, adding that stakeholder involvement is “critical” to more accurate modeling.

McMullen said that MISO’s current post-disturbance modeling is too conservative in estimating the occurrence and length of frequency dips because of its reliance on inaccurate inertia parameters, which factor in the collective ability of generators to automatically respond to frequency changes based on the pull of load. Simulations show the system recovering too quickly when compared with real events, indicating “a need to fix overall governor parameters,” McMullen said.

MISO currently measures the frequency response of every generator within its system at 24 seconds and 60 seconds following a deviation by polling a megawatt change in output per 0.1 Hz of a frequency deviation. McMullen said the RTO could collect more measurements, including collecting frequency values themselves in addition to megawatt output, gathering data more frequently at two- to four-second intervals and cataloging local balancing authority and MISO frequency response events in order to identify trends.

Hwikwon Ham, a staffer with the Minnesota Public Utilities Commission, asked if the effort would require major software changes, or if the RTO simply needs to capture more data for better frequency response modeling.

Gathering more data is the first step in determining whether program improvements are needed, McMullen said.

“It’s getting enough data to be able to talk with entities,” he said.

MISO is also exploring incorporating its phasor measurement units — devices installed across the Eastern Interconnection to measure the electrical waves on the grid at a specific point in time — in the effort. Those devices can isolate a frequency event and identify specific responses by generators, although their use for model validation is currently in the “embryonic” stage.

The RTO is continuing its efforts to capture data and correlate the numbers to a disturbance, McMullen said. It must also work on providing phasor measurement unit data to member companies.

MISO agrees with FERC’s recently proposed rule mandating that all new resources connecting with the grid have frequency response capability as a precondition for interconnection, McMullen said (RM16-6). (See FERC: Renewables Must Provide Frequency Response.) However, he noted that the new rule is not tailored to an energy market and does not propose any compensation mechanisms for providing frequency response.

MISO Consulting Advisor Terry Bilke said MISO consistently performs above NERC’s frequency response standard (BAL-003-1).

“We don’t anticipate any frequency problems as long as there’s not a change in fleet,” Bilke said. “The [Notice of Proposed Rulemaking] requiring new interconnection agreements to [have a governor] will ensure there’s no backsliding.”

Responding to a request by RSC Chair Tony Jankowski that MISO release its 2016 frequency response data, McMullen said the RTO must first determine what information can be shared publicly.

In 2015, MISO met NERC’s frequency response requirement at an average of -475 MW/0.1 Hz, more than doubling the NERC obligation of -211 MW/0.1 Hz. Still, the results were not as good as in 2014. (See “MISO Frequency Response Doubles NERC Requirements,” MISO Reliability Subcommittee Briefs.)

McMullen said he would update the subcommittee on MISO’s progress on the matter in April.

Supporters Seek to Overturn Md. Governor’s Increased RPS Veto

Sponsors of a bill to increase Maryland’s renewable portfolio standard joined environmental advocates Jan. 5 in calling for the General Assembly to override Gov. Larry Hogan’s veto.

maryland renewable portfolio standard
Hogan | Official Website of the Governor of Maryland

Rallying on the steps of the Maryland State House, Sen. Brian Feldman and Delegate Bill Frick, both Democrats representing Montgomery County, attempted to link Hogan’s veto of the measure — dubbed the Clean Energy Jobs Act — to the anti-environmental sentiment of President-elect Donald Trump.

“We’re here because the administration decided to play politics,” Frick said.

Hogan vetoed the bill last year because it would increase rates to cover the costs of additional wind and solar generation.

The legislature returns next week for its annual 90-day session and could consider the measure then. The bill would increase Maryland’s RPS requirements from 20% by 2022 to 25% by 2020, improve access to capital for small, minority and women-owned renewable energy businesses, and commission an industry workforce-needs study.

Frick said the bill has 70% public support.

Renewable industry representatives were supportive as well. Kevin Sheen, spokesman for Empower, promised the wind and solar company would continue investing in the state and said increasing the RPS was “imperative.”

Dana Sleeper, executive director of the Maryland/D.C./Virginia chapter of the Solar Energy Industries Association, said there are about 4,000 solar industry workers in Maryland making an average of $21/hour. It’s important to have such low-skill jobs in the state, Sleeper said.

– Rory D. Sweeney

FERC Accepts MISO’s 2nd Try on Queue Reform

By Amanda Durish Cook

FERC approved MISO’s second attempt at new interconnection queue rules, conditioned on the RTO allowing refunds for “significant” changes in upgrade costs and providing more detail on late-stage restudy scenarios.

MISO’s new queue process is designed to last 460 days and meant to reduce multiple unscheduled restudies by including mandatory restudies in each stage of the new three-part definitive planning phase. FERC said the design should minimize the backlogs that dogged the old queue by studying project withdrawals “on a more structured basis.”

m2 milestone plan ferc miso

FERC’s Jan. 3 order said that while the new queue proposed a longer official timeline than the old process, “the proposal is an improvement compared with MISO’s current study process that can take nearly two years due to unscheduled, ad hoc restudies.” MISO said the old queue process averaged 589 days. The changes formally took effect Jan. 4 (ER17-156).

In its transition plan, MISO plans to grandfather some late-stage interconnection requests. FERC said MISO’s transition “avoids the creation of an unwieldy study group.”

Two ‘Off Ramps’

The new queue creates two designated off-ramps for interconnection customers to withdraw projects; smaller but more frequent milestone payments that can be applied to an initial payment for the interconnection agreement; and a restriction on restudies after a generator interconnection agreement is executed. If a project is unexpectedly withdrawn, MISO can use milestone payments to fund network upgrades that would have otherwise been needed, lessening the financial burden on other projects that rely on the upgrades. After an initial $4,000/MW initial payment, the two subsequent milestone payments are based on a percentage of upgrade costs. (See MISO: Stakeholders Behind 2nd Queue Reform Attempt.) The changes also preserve the ability for MISO to enter provisional GIAs with customers for limited operation “at any time in the interconnection process.”

FERC had rejected MISO’s first queue proposal in March, saying the higher milestone payments could create barriers to entry and that the RTO placed too much blame for the queue’s gridlock on “speculative projects.”

“We find that MISO’s proposed changes to the Tariff address the commission’s previous concerns by implementing more transparent timing and cost information to enhance accountability in preparing timely interconnection studies, providing for more involvement of the interconnection customer in the study process and providing for earlier coordination with affected systems,” the commission wrote.

FERC also agreed with MISO that it should weigh stakeholders’ feedback before considering a provision that allows projects to withdraw penalty-free if substantial queue delays occur in the future.

Refunds for ‘Significant’ Changes

The commission ordered MISO to create a provision allowing refunds of milestone payments if “significant change” affects cumulative network upgrade costs while the project is in the queue’s definitive planning phase. It told the RTO to define the degree of change needed to trigger the refund and address the risk of “cascading withdrawals” that penalty-free exits could cause when crafting the provision. MISO’s revised filing proposed refund of milestone payments only if the network upgrade cost estimates increase 25% or more between the queue’s system impact study and the facilities study of the definitive planning phase.

Additionally, MISO must provide FERC semi-annual informational reports for two years describing the number and types of customers that experience changes in cost estimates for network upgrades greater than 25%. FERC also told MISO to clarify that the RTO does not intend to separately bill withdrawing interconnection customers for another interconnection customer’s restudies.

More Detail Required

| © RTO Insider

The commission gave MISO 60 days to clarify what events could initiate a restudy for customers with GIAs. FERC said the RTO did not maintain the “existing language regarding restudies related to other types of upgrades or contingencies and has not explained why such existing language is no longer necessary.” The commission rejected the argument of MISO’s generation developers, who said restudies after an executed agreement should be banned altogether.

Per FERC’s order, MISO also has 60 days to add language to make scoping meetings mandatory for transmission owners. The RTO had only proposed mandatory scoping meetings for interconnection customers. FERC said transmission owner attendance is “essential to the purpose of that meeting, which is to discuss alternative interconnection options, to exchange information including any transmission data that would reasonably be expected to impact such interconnection options, to analyze such information and to determine the potential feasible points of interconnection.”

FERC OKs New Rule on Milestone Payments

In a related order also issued Jan. 3, FERC accepted MISO’s revised plan that applies the M2 milestone payment across all classes of interconnection customer, including external customers (ER16-1817-001).

“The Tariff changes will ensure comparable treatment for all customers, external or internal, existing or new,” FERC said.

After revising a service agreement last spring for the Louisiana Energy and Power Authority, MISO proposed that external customers should be exempted from interconnection milestone payments because the fees serve to deter speculative projects, and such generators are either in-service, under construction or have an executed interconnection agreement with the transmission provider to which they directly interconnect. MISO also pointed out that the fee is refunded once a generator begins commercial operations. FERC rejected MISO’s stance in October, saying it amounted to preferential treatment. (See FERC Orders MISO to Levy Interconnection Fees Equally.)

MISO said the new queue rules makes it “clear that the M2 milestone payment assessed to any customer is not zero.”

California Tx Policy Must Foster Resource Diversity, Report Shows

By Robert Mullin

California will require improved transmission access to a diverse set of renewable resources throughout the state and the broader West to cost-effectively meet its renewable energy and greenhouse gas reduction targets, according to a report released by the state’s Energy Commission.

renewable resources california
Windy Flats, Klickitat County, WA | © RTO Insider

Increasing solar generation will lead to rising costs stemming from the need to curtail surpluses during periods of high output and shore up system, and flexible, capacity during other times of the day, the report found.

A technologically and geographically balanced portfolio of resources would help offset the technical risks of California’s growing reliance on in-state solar generation, while the upgraded transmission required to access those resources could enable the state to export surplus solar outside the state.

The study was conducted on behalf of the multiagency Renewable Energy Transmission Initiative (RETI), a collaboration that includes CAISO, the state’s major municipal and investor-owned utilities, the Western Area Power Administration and the California Natural Resources Agency.

The outcome of a yearlong effort, the RETI report provided a “high-level visioning process about what it might take” for California to meet its 2030 mandates for generating 50% of the state’s electricity from renewable resources and reducing GHG emissions to 40% below 1990 levels, RETI project director Brian Turner said during a Jan. 4 call to discuss the report.

Turner was careful to point out that the report did not represent “a projection or goal for any total quantity of renewable energy statewide or in any specific areas” or advocate for any specific transmission or generation projects.

And while the study focuses on the potential for utility-scale renewable development in California and the rest of the West, Turner noted that it is not intended to express a preference for utility-scale energy over other strategies to help the state meet its goals.

“The overall flavor — objective — here is really one big, ‘What if?’” Turner told RTO Insider.

The RETI project poses a set of interrelated questions: “To meet [the state mandates], what might it require in terms of renewables? And, if it requires [a certain] level of renewables, what transmission might be required? And if that transmission were required, what cost, environmental and land-use implications might it entail?”

The report is the most comprehensive effort to date to draw on available information to scope out the most cost-effective transmission solutions for meeting California’s goals. It relies on information about the most promising areas for renewable development, environmental and local land-use policies within California and the potential for collaboration with the wider West.

“One of the questions to ask is: ‘Did we get the synthesis right?’” Turner said during the Jan. 4 CEC call, soliciting feedback from industry participants.

The study assumes that for California to meet its 50% renewable portfolio standard, the state will need to tap an additional 25 to 53 TWh of renewable energy between 2020 and 2030. Based on a 30% capacity factor, that translates into a need for 9.4 to 20.3 GW of new renewable capacity. That figure spikes to 76 TWh (29 GW) under a scenario of accelerated vehicle electrification in the state.

While low-cost utility-scale solar is already cost-competitive throughout California, its continued growth will become costly without the integration of other types of renewable resources to balance out the generation profile for solar.

“Without integration solutions, continued growth in solar PV resources will lead to increased costs from a surplus of generation during high solar periods and a shortage of system and flexible capacity at other times,” the report said. CAISO late last year incorporated into its real-time market a mechanism for procuring upward and downward flexible ramping capability in order to respond to variability from renewable sources, the costs for which are borne by load-serving entities and ultimately ratepayers. (See FERC OKs Ramping Product for CAISO, EIM.)

To counter that effect, California will require access to low-cost renewable resources both inside and outside the state, “especially wind and geothermal resources with generation profiles complementary to California solar generation.” The state’s power producers will also need access to energy markets outside California to offload excess generation and reduce ratepayer costs, the study said.

While California has a “substantial amount” of non-firm capacity to interconnect new generators as “energy-only” resources subject to curtailment, the state falls short in the availability of full-capacity interconnections equipped to ensure that output is “fully deliverable” — capable of reaching its load sink without hitting potential constraints.

That distinction is important because under California Public Utilities Commission rules, only fully deliverable resources can be counted toward a utility’s resource adequacy requirements.

The distinction also underlies the RETI report’s assumptions about the hypothetical potential for development of wind, solar and geothermal development in eight transmission assessment focus areas (TAFAs) where large quantities of resources could be constructed to meet the state’s goals.

The Renewable Energy Transmission Initiative report examined the potential for developing renewables in eight California regions — as well as in areas around major import-export points. | Renewable Energy Transmission Initiative

In most of the TAFAs, full deliverability of new resources would require a significant investment in transmission upgrades in order to relieve constraints. (See Price Tag on Tx Needed to Meet California 50% RPS: $5B?) Development in other TAFAs could be constrained by environmental restrictions or land-use rules.

The Imperial Valley TAFA shows some of the strongest potential for development based on a “hypothetical study range” (HSR) of an additional 3,500 MW of solar and 1,000 MW of geothermal and the existence of favorable land-use planning. New transmission would be necessary to achieve full deliverability.

Development of 4,000 MW of new solar in the Riverside East TAFA would be feasible because of extensive planning on U.S. Bureau of Land Management land through the Desert Renewable Energy Conservation Plan. (See Interior Dept. Approves First Phase of California Desert Renewable Plan.) Constructing 500 to 1,000 MW of wind would be less likely because of environmental and land-use restrictions.

While existing transmission in both the Imperial Valley and Riverside East areas could accommodate the lower end of new renewable development estimates, build-out at the high end of the HSR could require up to $1 billion in transmission upgrades to relieve the so-called “Desert Area Constraint” east of the Miguel substation.

The sprawling San Joaquin Valley TAFA shows potential for 5,000 MW of new solar development, in part through the reuse of “degraded” — or disused industrial — land, but development could require “substantial” investment in upgrading the region’s low-voltage network.

Full development of Northern California’s renewable potential is considered less likely because of a lack of environmental and land-use planning, as well as limited transmission availability. Tapping an estimated 5,450 MW of wind, solar and geothermal resources could cost between $2 billion and $4 billion in new transmission.

The possibilities for development along import-export paths is a mixed bag, according to the report.

Importing an additional 2,000 MW via the California-Oregon Intertie (COI), a major import point from the Pacific Northwest, is not considered feasible without construction of a new 500-kV line from the Oregon border to Tracy, Calif. Still, new transmission built elsewhere in the West and the possibility of dynamic line ratings could result in increased capacity on the line.

Also, the largely underutilized northbound segment of the COI could transmit 3,000 MW worth of solar exports from California.

“Being in the Northwest, we’re very interested in what are the implications for us,” said Fred Heutte, senior policy associate with the Northwest Energy Coalition, an alliance including environmental organizations, utilities and businesses in Oregon, Washington, Idaho, Montana and British Columbia.

Path 46 out of Arizona has the capacity to accommodate an additional 3,000 MW of imports, although substantial resource development could eventually trigger the Desert Area Constraint, the report said.

“This is quite an impressive bit of work in quite a compressed timeline,” Carl Zichella, director of western transmission for the Natural Resources Defense Council, said of the RETI report. “This is very, very useful work.”

The CEC is seeking comments on the draft final report by Jan. 10. A final study is expected to be issued by the end of this month.

PJM Monitor Asks FERC to Act on ‘Paper Capacity’

By Rory D. Sweeney

PJM’s Independent Market Monitor urged FERC to address longstanding concerns over demand response providers and others selling “paper capacity” to arbitrage price differences between the Base Residual and Incremental auctions.

The Monitor made its request in a Dec. 30 filing that was accompanied by a report analyzing the use of replacement capacity since 2007 (ER14-1461, EL14-48).

pjm independent market monitor demand response
PJM’s Independent Market Monitor says demand response providers disproportionately replace commitments from Base Residual Auctions compared with sellers of other resource types. External generation and internal generation not in service also had high rates of replacement in some years.

“The lack of a specific requirement that all capacity resources be demonstrably physical assets when offered into PJM capacity auctions continues to provide strong incentives to offer speculative paper capacity,” the report concludes. “The pattern of IA prices being substantially lower than BRA prices, exacerbated by PJM’s preannounced sales of capacity at low prices in IAs, continues. The pattern of consistently extraordinarily high levels of replacement by DR providers and very high levels of replacement by capacity imports and planned internal generation continues.”

PJM attempted to address the issue in 2014, but FERC rejected its proposed rule changes to curb speculation in the auction, saying it created undue barriers to entry. The commission said PJM’s proposed arbitrage fix — which the RTO proposed unilaterally after failing to obtain stakeholder consensus — “will simultaneously increase risk to suppliers and costs to load, without guaranteeing equally offsetting benefits to the PJM grid as a whole.” (See PJM Wins on DR, Loses on Arbitrage Fix in Late FERC Rulings.)

Instead, the commission said it would convene a technical conference to find a solution. But FERC has not scheduled the conference, the Monitor noted, because of PJM’s request to defer action pending implementation of Capacity Performance.

The Monitor’s Dec. 30 filing asked the commission to “proceed without further delay towards solutions to the issues.”

“Sellers of demand resources in [Reliability Pricing Model] auctions disproportionately replace those commitments on a consistent basis compared to sellers of other resource types,” the Monitor said in its report. “The risks to the markets associated with the sale of DR without any supporting information on the plausibility of the underlying assets [mean] … the system is less reliable than it might otherwise be because the full amount of DR that cleared the RPM auction is not actually available, the price to other capacity resources has been suppressed by the sale of the speculative DR, new entry of other capacity resources could have been forestalled by the sale of speculative DR and there may not be adequate replacement resources available with short notice prior to the delivery year.”

“There is no reason for further delay on this matter,” says the analysis, which updates reports from 2012 and 2013. “The evidence has been and continues to be quite clear.”

The filing comes just weeks after the Monitor teamed with PJM to reinstate capacity-replacement rules that had been stripped away in November through a stakeholder initiative to reduce the accounting reconciliation time for Incremental Auction capacity transactions. (See “PJM, IMM Win Approval for Reinstatement of Capacity-Replacement Rules,” PJM Markets and Reliability Committee Briefs.)

Both PJM and the Monitor had opposed the stakeholder proposal, and the Monitor filed a complaint with FERC that caused some stakeholders who had supported the proposal to reconsider their positions. The complaint was withdrawn after the PJM/IMM proposal was approved.

At issue was a rule implemented in May that could allow what the Monitor describes as “speculative” capacity offers to clear at BRAs and then be replaced without justification at lower prices with capacity in subsequent Incremental Auctions. The rule — meant to help participants avoid Capacity Performance penalties when legitimate bids into the BRA from participants like DR providers unexpectedly become unable to deliver — had been superseded by a pre-existing rule that required justification for replacement.

However, PJM stakeholders who provide financial services find it onerous because it requires them in certain situations to maintain collateral for positions they have sold out of, a situation Citigroup Energy’s Barry Trayers termed “double counting.”

Monitor Joe Bowring stated at the time that reinstating the rule wasn’t “optimal,” but it was better than allowing capacity replacements without justification.

CAISO Expansion in Question as EIM Grows

By Robert Mullin

CAISO rang in 2016 with a strong push to expand its operation into PacifiCorp’s sprawling six-state service territory, but the project hit a stumbling block by mid-year as skeptics called on the ISO to slow its regionalization effort.

A 2015 state law requires the grid operator and state energy agencies to explore ISO expansion to help California meet its 50% renewable energy mandate.

The ISO last year kicked off a set of initiatives considered to be “central” policy elements of expanding into a region with dozens of balancing areas subject to multiple state and municipal rules.

Those efforts — still ongoing — dealt with the complex and often contentious issues of allocating transmission costs, maintaining adequate regional resources and accounting for greenhouse gas emissions. (See CAISO Kicks Off Effort to Track GHGs Under Regionalization.)

But the most challenging initiative was the effort to develop governing principles that would assuage concerns about California dominating the policies and management of a Western RTO.

Particularly contentious is California’s requirement that the state’s utilities track carbon emissions from generation serving their loads in order to ensure compliance with emissions caps. CAISO’s provision of generation data is key to that effort, which means that every generator in an expanded ISO would be subject greenhouse gas reporting requirements in order to track deliveries to California — regardless of whether the unit is located in a coal-heavy state disinclined to impose such a requirement.

When industry participants across the West expressed concerns that an initial governance proposal threatened to compromise the energy policies of “non-California,” CAISO returned in July with a revised document that emphasized the preservation of state authority. (See Revised Western RTO Governance Plan Highlights State Authority.)

By late July, critics within California — fearing the loss of CAISO as an instrument of the state’s renewable and emissions goals — were calling for a slowdown in regionalization, saying that the ISO was moving too quickly to get a governance plan to the State Legislature before the end of its summer session. (See Governor Delays CAISO Regionalization Effort.)

While the ISO plans to submit a governance plan to lawmakers this winter, President-elect Donald Trump’s vow to cancel the Clean Power Plan is another roadblock for CAISO-led regionalization. Under the CPP, interior West states such as Utah and Wyoming would confront the requirement of sharply reducing carbon emissions from coal-fired generation, an objective made less costly by access to low- and zero-emission electricity made available through a regional market. With the Trump administration likely to pull the rug from under the CPP, coal-heavy interior West states contemplating an RTO will be less motivated to give ground to California’s environmental mandates in order to gain the emissions benefits of membership.

That, in turn, could prevent California legislators from signing off on a governance plan that risks the state’s ability to meet its goals.

“California will want to protect its environmental objectives,” retiring California Public Utilities Commissioner Mike Florio, a strong supporter of regionalization, told RTO Insider.

Ann Rendahl, commissioner with the Washington Utilities and Transportation Commission, said the success of regionalization will depend on how California’s lawmakers deal with the governance issue.

“It’s really in the hands of California,” Rendahl said.

EIM Accelerates Growth

The future looks brighter for the Energy Imbalance Market, the West’s only real-time energy market. Unlike in the ISO, members are not required to turn over control of their transmission and generator day-to-day participation is voluntary.

caiso eim seattle city light

The market last year extended its north-south reach with the integration of Arizona Public Service and Puget Sound Energy, expanding membership to four balancing authority areas, in addition to CAISO. The two utilities began transacting in the market in October after what officials called a largely uneventful implementation. (See Smooth EIM Transition for Arizona Public Service, Puget Sound Energy.)

“I’ve been through three sets of transitions, and I would say that each one is getting smoother,” Mark Rothleder, the ISO’s vice president of market quality and renewable integration, said during an Oct. 5 meeting of the EIM’s governing body.

Another transition is scheduled for October 2017 when Portland General Electric will join the market, the last fall entry before the ISO moves to a spring implementation schedule to avoid overlap with annual market software updates.

The benefits of NV Energy’s December 2015 integration into the EIM became evident in early 2016, after CAISO officials observed that the increased transfer capacity between the ISO and PacifiCorp East unified what had previously been a fractured market; California had found a real-time export market for its surplus solar and avoided curtailing a significant amount of renewable generation. (See CAISO EIM Boosts Market for Renewables in Q1.)

Last year also saw announcements from four utilities that said they intend to join the EIM.

In April, Idaho Power signed an implementation agreement that would make it the sixth BAA to join the market in spring 2018. Inclusion of the utility will bring an additional 4,800 miles of transmission into the market while improving trading access to an area of Wyoming that renewable developers — including EIM pioneer PacifiCorp — seek to tap for wind projects intended to serve the West Coast. (See Idaho Power Inks Agreement to Join EIM.)

Seattle City Light is slated to become the first publicly owned utility to join the EIM after signing an implementation agreement in December. (See Seattle City Light Signs EIM Membership Agreement.) City Light’s membership is contingent on satisfying the concerns of the Seattle City Council, which asked the company to flesh out the findings of an EIM benefits study showing the hydropower-rich utility could earn an additional $4 million to $23 million annually as an exporter of the flexible ramping capability needed to smooth out intermittent renewables. (See Council OKs Seattle City Light Bid to Explore Joining the EIM.)

The Sacramento Municipal Utility District said in October that it would begin negotiations to join the EIM, with some of the six other members of the Balancing Authority of Northern California — all publicly owned — to follow, depending on the outcome of cost-benefit assessments. (See Sacramento Utility to Join EIM; Other BANC Members May Follow.)

CAISO and El Centro Nacional de Control de Energía (CENACE), Mexico’s grid operator, announced an agreement in October to explore having the Baja California Norte region join the market as the first non-U.S. participant. (See Mexico’s Grid Operator to Explore Participation in the EIM.) While the region has no transmission connections with the rest of Mexico’s grid, it does boast 800 MW of transfer capacity with California through two 230-kV links at the Imperial Valley and Otay Mesa substations, and also offers promising potential for wind energy development.

2016 also saw the EIM begin to chart a course more independent of the ISO with the appointment of the market’s governing body and a clearer outline of governance. (See CAISO Board Appoints Western Energy Imbalance Market Governing Body.) At the body’s first meeting, Chairwoman Kristine Schmidt noted that a decade ago, nobody in the industry would have believed that the West would produce an organized real-time market.

“We’re now seeing a regional market take shape in the West,” Schmidt said.

In December, EIM and CAISO leaders approved a guidance document that provides solutions to the overlapping authority between the ISO’s Board of Governors and the EIM governing body resulting from the EIM’s delegation of a portion of its authority over Federal Power Act Section 205 filings to CAISO. (See EIM Leaders OK Governance ‘Guidance’ Proposal.)

The document outlines how ISO staff should interact with the EIM, providing a schedule for notifying the governing body about ISO initiatives and laying out the processes by which body members and EIM participants will provide feedback on proposed policy changes.

“I think this is an important step forward,” CAISO board member David Olsen said. “It really helps to clarify the scope of responsibility of the EIM board.”

SPP Seeks to Manage Wind Riches, Improve Order 1000 Process

By Tom Kleckner

SPP and its stakeholders enter 2017 seeking ways to integrate the massive amounts of renewables in the RTO’s interconnection queue, while also completing the painful Z2 project, improving the Order 1000 competitive transmission process and implementing more sophisticated combined cycle modeling.

Expiring tax credits and reduced costs for renewable energy has led to a rush of generation projects that threaten to overwhelm RTO transmission planners.

Wind Rush

“We’re embarking on an era we’ve never seen before,” Mike Wise, chair of SPP’s Strategic Planning Committee, said during the RTO’s Board of Directors/Members Committee meeting in December. “We’re trying to figure out, one, how do we deal with the issue and, two, how do we take advantage of the issue at the same time?”

order 1000 spp wind power
Wise in the foreground with SPP’s Carl Monroe behind him | © RTO Insider

David Osburn, general manager of the Oklahoma Municipal Power Authority, agreed with Wise, saying, “It wasn’t very long ago we were arguing about how much wind might be on the system, and we’ve already blown through that.”

Whether or not the pun was intended, Osburn made his point. SPP has been able to add more wind to its system than many would have thought possible a few years ago, and now it looks to be facing the same issue with solar power.

SPP currently has 15,728 MW of installed wind energy with another 21,535 MW in the interconnection queue — adding up to more than half of the balancing authority’s coincident peak load (50,622 MW in July). The system set a new record for wind generation Friday with 12,141 MW, and for some hours in April, almost half of the generation came from wind sources. SPP expects to set new records in April 2017, with wind exceeding 60% penetration. (See Wind Growth Causes SPP to Take 2nd Look at Tx Projects.)

3,000 MW of Solar Coming

The RTO currently only has 215 MW of solar energy on the system, but more than 3,000 MW of solar is planned. That has Board Chair Jim Eckelberger sounding the alarm.

“That’s what wind looked like 10 years ago, and solar is getting cheaper and cheaper and cheaper,” he said. “We’re going to have quite a need to refocus on the mechanics of the market to make this work, or negative pricing is really to going to have a long-term change in the way electricity is used in our footprint.”

SPP says all that wind generation has a high impact on system congestion. Wind energy also causes headaches for grid operators by not showing up during high demand — or by providing too much power during periods of low demand. Wind power on the margin resulted in 160 hours of negative clearing prices in 2016. SPP staff notes some wind farms are voluntarily curtailing their production because of low prices.

“We have to figure out a way to either use the wind, control for the wind or figure out a way to allow other folks in this country to get access to this wind,” Wise said. “This is really a dilemma … a growing dilemma.”

The problem is, when the wind picks up in SPP, it’s also picking up in neighboring MISO and ERCOT, dampening demand for imports.

But SPP can point to studies that show UHVAC networks and HVDC links could deliver surplus wind power to markets in the east, helping them meet renewable portfolio standards.

The Strategic Planning Committee created the Export Pricing Task Force last summer to evaluate the business case for exports and create a rate structure “to address the recovery of the incremental transmission and the underlying facilities necessary” to support exports. The group met twice in 2016 but has scheduled monthly meetings for this year. Its charter calls for making recommendations by the end of July.

If all the pending wind projects are brought online, SPP Manager of Operations Analysis and Support Casey Cathey told the committee, the lack of an export strategy might force the SPP Reliability Coordinator to allow more wind energy to sink within the balancing authority, while at times increasing curtailments.

Cathey’s team is also responsible for the 2017 Variable Generation Integration Study, which stressed the SPP system to a point of instability in analyzing the effect of high-wind/low-load scenarios on reliability. A workshop has been scheduled for Feb. 14-15 in Little Rock to discuss the study’s results.

spp wind power order 1000
Iowa find farm after harvest | Theodore Scott, Creative Commons

“It’s going to fall on SPP to really figure out what we’re doing in the future and how we’re going to resolve this issue,” Wise said to the board and members. “I encourage all the great thinkers at your companies to be attentive to the issue … and help us come up with solutions, because this is not an easy task.”

Z2 Project Lingers

Accommodating and planning for more wind generation is not the only difficult task facing SPP in 2017. Members and stakeholders continue to work on improving the troublesome Z2 crediting process for network upgrades, which was a bone of contention for much of this past year.

Under Attachment Z2 of the SPP Tariff, staff was to assign financial credits and obligations for sponsored upgrades. However, staff had not applied the credits for years dating back to 2008, complicating the task of trying to accurately compensate project sponsors and claw back money from members who owed debts for the upgrades.

Staff and members agreed on a process to compensate everyone properly, but it wasn’t until November that staff was able to compile the historical data from 2008 through August 2016. Members will be invoiced almost $95 million in lump sum payments, with another $15 million billed in 20 installments through August 2021.

SPP CEO Nick Brown said last January that Z2 would be “the focus of the organization this year.” That will still be the case this year, as the Z2 Task Force will meet before January’s Markets and Operations Policy Committee to evaluate staff and stakeholder proposals to improve the process. SPP has proposed using incremental long-term congestion rights as one replacement for Z2 credits.

At the same time, the legal and regulatory battles over Z2 have just begun. In November, the Kansas Electric Power Cooperative became the first SPP member to pursue legal action over the Z2 revenue-crediting process when it filed a complaint with FERC. KEPCo said in its Nov. 22 filing that SPP’s direct cost assignment of approximately $6.2 million to it violated the RTO’s Tariff, the filed rate doctrine and the Federal Power Act. The complaint seeks relief from directly assigned Z2 obligations and a refund for payments already made.

Order 1000

Staff and members are also working to improve the RTO’s competitive bidding process under FERC Order 1000. The first go-round last year resulted in one competitive project being bid out, only to have it pulled for re-evaluation shortly thereafter.

The Competitive Transmission Process Task Force hopes to change that by offering recommendations this year to improve the process. The group has already modified documents and templates while reviewing the entire competitive bidding process. Two Tariff revision requests have already begun to wind their way through the stakeholder-approval process, and more could be on the way if the MOPC and board approve changes to the scoring criteria in January.

Enhanced Combined Cycle Modeling

SPP will see one of its first major projects since the Integrated Marketplace come to a conclusion March 1 when software allowing multiple configurations of combined cycle units goes live. With the new functionality, market participants can register and submit separate offers for each configuration, leading to a more economic commitment and dispatch of the resources.

Participants completed structured testing of the software in December. The technology also played a role in SPP’s successful timeline changes for coordinated gas-electric scheduling practices in September as a result of FERC Order 809.

FERC OKs MISO Use of PJM Cost Estimates for Mitigation

By Amanda Durish Cook

MISO can use PJM’s technology-specific reference levels for market mitigation in its 2017/18 capacity auction, FERC has decided.

The commission’s Dec. 28 order said MISO’s use of PJM’s numbers “strikes a fair balance between reducing the burden of demonstrating and verifying facility-specific reference levels, and allowing a market participant to select the default technology-specific avoidable costs that best reflect its actual avoidable costs” (ER16-833-003).

Reference levels are intended to represent the non-fuel costs of operating different types of generation resources. Similar to a cost-based offer in the energy market, they will be used as a resource’s capacity offer when a capacity seller fails MISO’s market power tests.

ferc miso pjm market mitigation

MISO’s proposal was in response to FERC’s December 2015 ruling that the RTO’s use of estimated opportunity costs for exporting power into PJM resulted in excessive mitigated cost levels. (See FERC Orders MISO to Change Auction Rules.)

The commission ordered MISO to set the initial reference for offers into the capacity auction at $0/MW-day. Because the commission said the $0 default might generate more requests from capacity suppliers to establish facility-specific reference levels, the commission called for the technology-specific defaults to reduce the need to verify costs on a unit-by-unit basis (EL15-70et al.).

MISO’s staff and Independent Market Monitor agreed to base the mitigation levels on PJM’s avoided cost numbers because the generation technologies in the two RTOs are similar and PJM’s values are already FERC-approved. (See MISO Moves Forward on Auction Design; Seasonal Filing Delayed Again.)

MISO’s approach diverges from PJM on several points, including use of the monthly Consumer Price Index to update values rather than the Handy-Whitman index. Because PJM’s figures do not include defaults for wind and nuclear generators, MISO developed its cost estimates based on data from the Energy Information Administration and the Nuclear Energy Institute, respectively.

MISO also will not include the 10% “adder” PJM uses to offset the uncertainty of estimating costs three years into the future. The commission rejected NRG Energy’s request that MISO be required to use the adder. Unlike PJM’s three-year forward auction, FERC said, MISO’s prompt auction does not require the same safeguard.

FERC also mandated separate values for multi-unit and single-unit nuclear resources, despite Exelon’s comments that the two values were not materially different.

FERC ordered MISO to review the reference levels every three years, rejecting the RTO’s proposal to update values only after PJM updated its own numbers. FERC said MISO’s review of its avoidable costs “should not be contingent upon the review schedule of another regional transmission organization.”

FERC’s order also approved MISO’s proposal that market participants intending to retire or suspend a unit must use either retirement- or mothball-based default avoidable costs, respectively. FERC said market participants wishing to take advantage of the retirement-specific values must have already submitted a notification of retirement to MISO. However, since MISO only included retirement-based and not mothball-based values for nuclear and wind units, FERC ordered the RTO to provide wind and nuclear mothball-based avoidable costs or explain why they should be exempted.

New England to Charge Ahead on Clean Energy Makeover in 2017

By William Opalka

New England policymakers hope to reach agreement in 2017 on revised market rules to accommodate state clean energy policies, as three states seek to complete renewable procurements and Massachusetts readies for a new solicitation.

Although Donald Trump’s election threatens federal initiatives to reduce carbon emissions, New England is moving ahead with its plans to decarbonize through power purchase agreements, infrastructure improvements and potentially tighter emission caps under the Regional Greenhouse Gas Initiative.

Massachusetts, Connecticut and Rhode Island, which issued a joint solicitation combining their purchasing power, hope to file PPAs with state regulators in the spring, now that a temporary injunction sought by a small developer who challenged the program has been lifted. (See New England States Move Toward Renewables Contracts.)

While the initial contracts are for a modest 460 MW, Massachusetts is expected to issue another request for proposals for 2,800 MW in the spring. The state’s Energy Diversity law, enacted last summer, directs its electric distribution utilities to enter contracts for 1,600 MW of offshore wind and 1,200 MW of renewables, likely Canadian hydropower, over the next decade. (See Massachusetts Bill Boosts Offshore Wind, Canadian Hydro.)

iso-ne clean energy canadian hydropower 2017
Daniel-Johnson Dam and Manic-5 Generating Station | Hydro-Québec

Separately, Connecticut has selected 25 small clean energy and energy efficiency projects totaling 402 MW to negotiate PPAs with the state’s two electric distribution companies.

Transmission

In December, the region saw the nation’s first offshore wind farm — Deepwater Wind’s 30-MW project off Rhode Island’s Block Island — begin commercial operation. But without other, larger offshore projects to count on, importing Canadian hydropower appears to be the quickest solution for the states seeking to maintain momentum in emissions reductions.

Delivering that power will require major new transmission lines. The New Hampshire Site Evaluation Committee is expected to rule on the application by Northern Pass developer Eversource Energy in September. Opponents want the entire 192-mile route of the 1,090-MW line buried. The developers have proposed only 60 miles underground.

Two other transmission projects would import Canadian hydropower via cable buried under Lake Champlain. TDI New England’s Clean Power Link received a presidential permit in December to allow construction. Anbaric’s 400-MW Vermont Green Line is awaiting approval. All three transmission projects are expected to respond to the Massachusetts solicitation.

IMAPP

Meanwhile, the New England Power Pool’s Integrating Markets with Public Policy (IMAPP) initiative, launched last summer, is trying to find ways wholesale market rules can accommodate state policies without compromising reliability or dramatically increasing costs.

Meeting these goals has proved a daunting challenge. Officials had hoped to develop an action plan by the beginning of December that could be presented to ISO-NE for action in early 2017, but now they don’t expect to do so until late in the first quarter at the earliest.

Proposals within the IMAPP collaborative have included various methods of pricing carbon. A carbon adder would be technology-neutral and provide market signals to both supply and demand while also creating a revenue stream for the states. There is also a proposal for a two-tiered Forward Capacity Market, with one reserved for clean energy resources. (See Markets vs. Climate Goals the Subject at NECA Conference.) Any market rule changes would require FERC approval.

Also considering rule changes is RGGI, which is conducting its quadrennial Program Review. Falling prices in the nine-state compact’s CO2 allowance auctions have renewed calls from environmentalists to tighten emission limits. Allowance prices dropped to $3.55 in December, the lowest in three years and about 53% lower than a year ago. Many stakeholders say the states should reduce the cap on emissions by 5% annually from the current 2.5%. (See RGGI Carbon Auction Prices Drop 22%.)

Although New England has been a national leader in reducing carbon emissions, it would still need an additional 25% cut from 2015 levels to meet the 2030 targets under the federal Clean Power Plan. The CPP would cap emissions from new and existing sources at 29.1 million tons in 2030. In a report by ISO-NE, carbon emissions showed a slight uptick to 40.3 million tons in 2015 compared to 2014, likely caused by the closure of the Vermont Yankee nuclear plant.

Have Capacity Prices Peaked?

One worrisome development that seems to have abated is the concern about steeply rising prices in the capacity market.

Clearing prices in last February’s FCA fell to $7.03/kW-month from 2015’s $9.55/kW-month, a 26% drop and the first decline in four years. (See Prices Down 26% in ISO-NE Capacity Auction.)

ISO-NE is seeking 34,075 MW for delivery year 2020/21. About 34,505 MW of existing and 5,958 MW of new resources are qualified to participate.

Natural Gas Infrastructure

As expected, 2016 proved crucial in efforts to expand the region’s natural gas infrastructure, with two major gas pipelines projects falling by the wayside.

The 342,000-dekatherm Algonquin Incremental Market project was completed in December, but it mostly serves local distribution companies’ heating customers and did little to aid generators.

Kinder Morgan halted its Northeast Energy Direct project in the spring, citing its inability to secure enough commitments from New England power generators to reserve capacity. (See Kinder Morgan Board Suspends Work on Northeast Energy Direct Pipeline.)

The Massachusetts Supreme Judicial Court effectively killed Spectra Energy’s Access Northeast when it ruled against a subsidy by electric ratepayers. (See Mass. Supreme Court Vacates EDC-Pipeline Contract Order.) The state’s legislature appears reluctant to codify the requirement. Other states that were ready to commit to shared costs for infrastructure were dependent on the Bay State taking a leading position.

Without ratepayer-mandated support in Massachusetts, the region’s largest state, major pipeline construction appears to be at a standstill.