In its complaint against PJM and MISO (EL13-88), the Northern Indiana Public Service Co. proposed the following changes:
The MISO-PJM cross-border planning process should run concurrently with the MISO Transmission Expansion Plan (MTEP) and PJM Regional Transmission Expansion Plan (RTEP) planning cycles, rather than after those regional planning cycles. NIPSCO proposes a schedule to have the interregional planning process run concurrently with the regional planning process.
There should be consistency between the PJM and MISO planning analysis. While the RTOs have regional differences, both entities should be consistent in their application of reliability criteria and modeling assumptions.
MISO and PJM should have a common set of criteria for the approval of cross-border market efficiency projects. The current and proposed changes to the JOA do not streamline the process but instead add delays, complications, and further administrative hurdles.
The criteria for approval of a cross-border market efficiency project should be amended to address all known benefits including, more specifically, avoidance of future market-to-market payments made to reallocate short-term transmission capacity in the real-time operation of the system.
MISO and PJM should be required to have a process for joint planning and cost allocation of lower voltage and lower cost upgrades for cross-border projects.
MISO and PJM must improve the processes within the JOA with respect to new generator interconnections and generation retirements.
MISO began running the nation’s biggest Regional Transmission Organization by geography with the integration last week of Entergy’s transmission system and those of six smaller transmission owners.
The addition of territory in Arkansas, Mississippi, Louisiana and southeastern Texas gives the RTO control of transmission in 15 states from Canada to the Gulf of Mexico. MISO’s transmission system grew by nearly one-third (to 65,787 miles), while it added more than 30,000 MW of generation capacity, to almost 197,000 MW. MISO’s 900,000 square miles makes it the nation’s largest RTO by area.
In addition to Entergy’s six operating companies, the new MISO South region includes Cleco Corp.; Lafayette Utilities System; Louisiana Energy and Power Authority; NRG Energy’s Louisiana Generating; South Mississippi Electric Power Association and East Texas Electric Cooperative.
Generation, Load Diversity
(Sources: PJM Interconnection, LLC & MISO)
The MISO South “cutover,” which was completed Dec. 18, provides more diversity for MISO, with summer peaking regions in the south offsetting winter peaking areas in the north.
It also provides the Midwest easier access to natural gas and nuclear generation in the south, reducing the RTO’s dependence on coal, from 51% of capacity to 46%. A recent survey of MISO market participants projects a capacity shortage of 7,500 to 8,500 MW in 2016. (See MISO to PJM: We Need Capacity)
In theory, the transition also will make it easier for Midwest wind generators to move power to the south. But the lack of renewable portfolio standards in the region means wind power will have to compete on price alone.
Savings for Entergy
Entergy said the access to MISO’s market and the RTO’s economies of scale and transmission cost allocation will save its consumers $1.4 billion in the first decade. It also is expected to help Entergy escape a U.S. Justice Department inquiry into complaints by independent power companies, who have complained about what they called Entergy’s anti-competitive behavior for more than a decade.
ITC Merger Cancelled
Although the MISO integration was completed as expected, Entergy was forced to cancel its plan to sell its transmission system to ITC Holdings Corp. The $1.78 billion deal, announced two years ago, was scotched after the Mississippi Public Service Commission ruled Dec. 10 that the transaction was not in the public interest. The regulators said they feared state ratepayers’ costs would increase by $300 million over 30 years.
Entergy shareholders would have controlled about 51% of ITC after the transaction.
Power Trading
With the completion of the integration, MISO started reporting prices for trading hubs in Arkansas, Louisiana and Texas.
Don Miller, an engineer whose career wove in and out of PJM since the late 1980s, attended his last PJM meetings last week.
FirstEnergy Corp.’s RTO policy manager, Miller retires effective Friday after 30 years at FE and its predecessor, General Public Utilities. He will be replaced by Jim Benchek.
Miller, 60, first worked on PJM activities in the late 1980s when he was doing transmission planning for GPU. He returned several years ago as part of FE’s FERC and RTO support team, serving on several PJM committees.
In between he helped smooth ATSI’s integration into PJM, helped FE prepare for the mandatory reliability standards authorized by Congress in the 2005 Energy Policy Act and participated in various projects related to industry restructuring.
Several of his former FE colleagues now work at PJM, including Andy Ott, Steve Herling and Jeff Bastian.
Don Miller
Miller said the basic PJM stakeholder process hasn’t changed much over the years. “We have always had equity issues, with a lot of spirited discussion among participating companies,” he said in an interview last week. “It’s the same now except there’s a lot more companies involved.”
He rarely spoke publicly at meetings. “My philosophy,” he said, “was to work on issues behind the scenes.”
Miller, who lives in Lancaster County, Pa., plans to remain there after retiring. He’s looking forward to spending more time hunting, fishing, traveling, visiting family and doing volunteer work through his church with his wife of 35 years.
“You want to spend as much time as you can in the go-go stage” of retirement, he said. “The longer you work the less time you have.”
The Marcellus shale formation in Pennsylvania and West Virginia will account for 18% of U.S. natural gas production this month, the Energy Information Administration reported. “Production growth in the region has driven down the forward price of natural gas at the Columbia Gas Transmission Appalachia hub below Louisiana’s Henry Hub price, the benchmark for natural gas throughout North America.” EIA said. “Natural gas pipeline expansion projects are expected to add at least 3.5 Bcf/d of takeaway capacity to the New York/New Jersey and Mid-Atlantic markets by 2015.”
U.S. Supreme Court West Facade (Source: Wikimedia Commons)
In oral arguments Dec. 10, most Supreme Court justices appeared sympathetic to at least some of the Environmental Protection Agency’s Cross-State Air Pollution Rule, which was thrown out in 2012 by an appeals court after attack by coal-state interests and others. The rule gets to a long-running fight between Eastern states with air-quality problems and Midwestern states whose coal-plant emissions the Easterners blame for a good deal of the trouble.
Challengers say EPA went beyond its authority and improperly designed the program, which limits sulfur dioxide and nitrogen oxide emissions from upwind states and allows trading of emission allowances. A high-court decision is expected by June.
A number of the downwind states, including Maryland and Delaware, have at the same time petitioned EPA to require coal states’ emission reductions under a different Clean Air Act regime (See PJM States Face Off on Pollution as Court Hearings Open).
Meade and Prettyman Courthouse (Source: DC Circuit)
Arguments lasted an exceptional four hours at the U.S. Court of Appeals for the D.C. Circuit Dec. 10 as the Environmental Protection Agency defended its Mercury and Air Toxics Standard, which some states and coal interests have challenged as unjustified and overreaching in its requirements for coal-fired power plants.
On the same day that the Supreme Court heard the Cross-State Air Pollution Rule case, the D.C. Circuit asked detailed questions of both sides about the MATS rule. An environmental-group attorney saw reason to believe the judges would uphold EPA’s regulation, but an industry attorney thought the court was likely to find the agency vulnerable on at least some provisions.
EPA De-emphasizing Enforcement; Focusing on Technology for Prevention
The Environmental Protection Agency plans to focus more on prevention and less on inspections and enforcement through 2018. “Next Generation Compliance” will use technology to keep a real-time eye on discharges and to have industry report electronically. The agency’s focus is on action “that makes the biggest difference,” an official said.
PJM’s assessment for the 2013-14 winter months identified no reliability issues, officials told the Operating Committee last week.
The annual assessment concluded the RTO has sufficient installed capacity to meet reserve requirements at the forecasted winter peak (about 136,000 MW) and that off-cost generation redispatch and switching will be sufficient to prevent thermal and voltage violations.
The assessment included a 50/50 peak load study — which assumes weather at average peak-day conditions — and an analysis of reactive transfer limits.
Last month’s GridEX II security drill was a valuable test of PJM’s emergency response procedures but lacked in realism, according to a briefing to the Operating Committee last week.
PJM’s Don Wallin said the North American Electric Reliability Corp. tried to stress the capabilities of the 200 organizations that participated in the Nov. 13-14 drill by giving them multiple simultaneous “injects.”
The scenarios included:
Denial of service attacks against shared service websites such as OATI;
Malware – similar to that which hobbled Saudi Aramco in a 2012 attack – that that exfiltrated sensitive information and locked corporate desktops and laptops;
Physical attacks against transmission and generation; and
Snipers firing at first responders.
The exercise was meant to simulate nation-state sponsored attacks against the grid. But Wallin said those who took part thought the volume of simultaneous injects undercut the verisimilitude.
“We don’t want this to be a Bruce Willis movie,” he said. Because the injects were compressed in such a short time, “it really took away from the realism and turned it into a disaster movie.”
More than 200 organizations, including 35 PJM member companies took part. Among those involved from PJM were the dispatch training team, corporate incident response team, cyber security incident response team, physical security incident response team and crisis communications.
Also involved were the FBI, Department of Homeland Security and the Electricity Sector Information Sharing and Analysis Center (ES-ISAC).
In addition to recommending the staggering of “injects,” participants said the drill should have used real-world communications channels.
GridEx III will be conducted in 2015. PJM plans a joint exercise with transmission owners in 2014.
Some are in it for the money. Others say they are motivated by environmental reasons. “For my children … for their children and their grandchildren. For the future and the planet,” says one customer.
These are among the multi-ethnic group of customers, and their very cute kids, featured in testimonials for Pepco’s Energy Wise program.
Energy Wise is Pepco’s contribution to the EmPOWER Maryland initiative, created by the legislature with a goal of reducing energy consumption by 15% below 2007 levels by 2015.
The Maryland Public Service Commission’s Walter Hall and Pepco’s Gloria Godson worked doggedly to ensure PJM’s new rules on demand response would not ruin such “mass market” programs. As a result of their efforts, PJM’s new requirement for 30-minute dispatch exempts residential customers who cannot respond so quickly.
Results to Date
Three utilities and one cooperative run demand response programs under EmPOWER Maryland. In 2012, the utilities for the first time exceeded their annual savings forecasts, doing so by more than one-third. Still, they were only at 41% of their energy reduction and 51% of the demand reduction goals for 2015.
Much of the reductions to date have resulted from the lackluster economy, moderate temperatures and distributed generation. With direct load control programs beginning to reach saturation levels, officials said they will need contributions from combined heat and power and dynamic pricing to reach their goals.
The state, which spent $729 million on the program through 2012, approved an additional $95 million in funding last month. The funding comes largely from customer surcharges and capacity market revenues. The state expects to collect more than $57 million in capacity revenues for delivery year 2014/15 and $66.5 million for DY 2015/16.
Pepco’s Program
Pepco’s program includes three options for “cycling” air conditioners or heat pumps during PJM emergencies between June and October.
During an emergency, or “conservation period,” the air conditioner fan continues to circulate air but the compressor operations are reduced. Under the 50% option, the compressor operates half of the time it did in the hour prior to the conservation period, allowing temperatures to rise 1 to 3 degrees. It pays $40 a year.
There are also 75% cycling ($60/yr.) and 100% cycling ($80/yr.) options. The 100% option, which shuts down the compressor for the entire emergency, can result in temperatures rising up to 7 degrees and is not recommended for consumers with cardiac or respiratory conditions. Each program includes a one-time “installation credit” or signing bonus equal to the annual payment.
Pepco contributed about one-fifth of the state’s economic and emergency DR.
Baltimore Gas & Electric Co. runs the biggest program in Maryland, responsible for three-quarters of the state’s economic DR and 63% of emergency.
BGE’s Peak Rewards offers an air conditioning program similar to Pepco’s but with bigger savings ($50/$75/$100). BGE also offers a 100% hot water heater cycling program which pays $25 per year. It also conducted 63,000 home energy checkups in 2012.
Maryland represents nearly one–third of the 2,200 MWs enrolled in economic DR programs in PJM — more than any other state — but ranks behind Pennsylvania and Ohio in the emergency program with 15% of the 7,346 total. The top six states are responsible for more than 80% of the reductions in each of the programs.
Impacts: Updates contact information; definitions; adds model validation and benchmark tests in response to FERC audit finding 13.
Manual 13: Emergency Procedures
Reason for Changes: 2014 Day Ahead Scheduling Reserve Requirement; Updates to terms, procedures.
Impact: Sets Load Forecast Error and Forced Outage Rate effective Jan. 1. References to interruptible load for reliability (ILR), no longer a valid term, are removed. Revised order of emergency procedures so that curtailment of non-essential plant and building load is curtailed as step 6, prior to issuing a manual load dump warning (step 7) and voltage reduction (step 8).
Impact: Changes section 6.3 to increase penalties for resources that fail to provide assigned amounts of Tier 2 Synchronized Reserve. Changes section 5.2.6 to clarify the requirements that must be satisfied in order for wind resources to be eligible to receive Lost Opportunity Cost (LOC) credits.
PJM will likely approve only one of 17 congestion relief transmission proposals submitted in September, saying most failed to provide sufficient benefits or targeted problems that were already addressed.
Five of the projects were rejected because the congestion developers targeted had been addressed by other transmission projects or generation, PJM told the Transmission Expansion Advisory Committee in a briefing last week. Another nine projects failed to clear the 1.25 benefit-to-cost ratio.
(Source: PJM Interconnection, LLC)
Only three projects passed the cost-effectiveness screen. Because they all address congestion on the Hunterstown 230/115 kV transformer only one project — FirstEnergy’s proposed $8 million upgrade in the MetEd zone — is likely to be approved. Two proposals by Northeast Transmission Development (LS Power) were more expensive and had lower benefit-to-cost ratios, even under sensitivity analyses assuming a $1/mmBtu increase in natural gas prices and a 2% increase in load.
Wasted Time
It was a disappointing beginning for those who had hoped the Federal Energy Regulatory Commission’s Order 1000 would unleash competition in transmission development. Six developers and utilities submitted proposals ranging from $200,000 to $64 million, many of them targeting congestion in AP South and the Cleveland interface.
“A tremendous amount of time was spent on [these proposals] with no result,” said one stakeholder.
“PJM needs to educate stakeholders about how we calculate these values,” PJM’s Tim Horger told the Transmission Expansion Advisory Committee last week, citing one of the “lessons learned” from PJM’s first competitive window for “market efficiency” projects. “They’re not getting the same results we’re getting.”
“I’ll take the fault in that,” he added. After PJM conducts its training next year, he said, developers are “not going to spend a month developing a proposal that’s getting thrown out.”
Evaluating the proposals also consumed substantial PJM staff and computing time. Each proposal took 30 to 40 hours of computing time to evaluate, according to Vice President of Planning Steve Herling.
Cleveland Congestion Clears
PJM told the TEAC in June that the Cleveland Interface – the location of three proposed projects – was projected to have $15.5 million in annual congestion costs in 2017, growing to $38.3 million by 2023.
But Horger told the TEAC that the updated Regional Transmission Expansion Plan (RTEP) model showed “there’s no more congestion … or minimal congestion” in the area. “The model is constantly changing” due to new generation and transmission reliability projects, Horger explained.
Jung Suh, of Noble Americas Energy Solutions, noted that a $62 million FirstEnergy project rejected by PJM included a static VAR compensator. “Maybe you’re missing out on an opportunity to reduce reactive costs,” he said.
“That’s certainly something we could look at,” responded PJM’s Paul McGlynn, general manager for system planning.
Auction Revenue Rights
Dominion Virginia Power’s $24.6 million proposal to address constraints at AP South was rejected because it reduced Auction Revenue Rights (ARRs) more than it did Locational Marginal Prices – thus resulting in negative benefit-cost ratios.
“There was no information provided along with the models regarding ARRs,” said another stakeholder.
Horger said PJM had provided developers only information on ARRs from previous years because the Tariff requires a six-month lag before release. He said the values “don’t change much from year to year.”
“I agree it’s surprising to see negative values,” he added.
Moving Target
Herling said he hoped the next round of proposals would fare better. But he and Horger said developers will still face the risk of having proposals rejected because of the dynamics of the grid.
PJM will begin a new two-year planning cycle in January. Planners will conduct analyses through the spring and summer and release results in October, in time to open the next market efficiency window between November 2014 and February 2015. At the same time, however, PJM will be proposing upgrades to address reliability problems identified in their analyses.
PJM will consider relaxing rules for up-to congestion transactions under a problem statement approved last week.
Noha Sidhom, of Inertia Power LP, requested the inquiry, saying that the $50 bid cap and restrictions on the nodes that are eligible are inhibiting use of UTCs as a hedge.
The Market Implementation Committee approved the request over the objections of the Market Monitor’s Howard Haas, who said expansion of the UTC product would be “premature” and should not be considered until UTCs are subject to the FTR forfeiture rule and pay uplift charges.
Issues with UTC Rules
A UTC combines a day-ahead offer to sell energy at a source with a bid to buy the same quantity at a sink. The transaction is only executed if the difference between the Locational Marginal Prices at the source and sink are under a threshold set by the bidder. Current market rules limit such bids to differentials of $50 or less.
The proposed rules also limit such transactions to nodes historically available for interchange transactions, excluding those load buses below 69 kV and buses for generators below 100 MW.
Sidhom said traders are not able to place “price sensitive” bids due to the bid cap and are substituting paths because their preferred paths are unavailable. The bid limit can prevent prevailing flow transactions from clearing on peak days while allowing counterflow bids, causing a risk of a “biased market,” Sidhom said.
The limitations can result in excessive bidding on some paths and prevent asset owning stakeholders from using UTCs to hedge, she said.
Monitor Opposition
Haas said there was no evidence that current rules are impeding the use of UTCs. UTCs represent one-third of injections and withdrawals in the day-ahead market and are on the margin 70% to 90% of the time. UTCs have “a dramatic and influential effect on this market,” he said.
Haas cited an analysis by the Monitor that simulated market results with and without UTC bids for a five-day sample in May. The analysis found that UTCs affect unit commitment and dispatch in the day-ahead market, increase the number of day-ahead binding constraints and contribute to negative balancing congestion. (See Bowring: UTCs Boost FTR Shortfalls.)
In its 2012 State of the Market report, the Monitor called for eliminating UTC transactions or making them responsible for day-ahead and balancing operating reserve charges.
PJM officials disagreed with the recommendation. Instead, PJM requested “a broad discussion of operating reserve costs and allocation methods.”
Sidhom said she did not oppose addressing the Monitor’s concerns. “We’re fine with the FTR forfeiture rule being applied to UTCs. In fact we voted for it,” she said. “I think it’s more a debate between PJM and the [Monitor] that has to be resolved.”
Dave Pratzon, who represents generators, said PJM and the Monitor need to reach agreement on a way to measure the impact of UTCs. He urged inclusion of the measurement issue along with Sidhom’s concerns. “Let’s try and take care of this issue once and for all,” he said.
