October 30, 2024

FERC Likely to Increase Pressure on PJM-MISO Joint Market Talks

By Rich Heidorn Jr.

WASHINGTON — The Federal Energy Regulatory Commission signaled today that it will increase its scrutiny of the PJM-MISO Joint Common Market process amid complaints that PJM is improperly limiting MISO generation from full participation in its capacity market.

FERC commissioners indicated their concern in comments following presentations by representatives of PJM, MISO and state regulators at today’s commission meeting.

RTO representatives and state regulators made their cases before the Federal Energy Regulatory Commission in a dispute over capacity deliverability across the PJM-MISO “seam.” Facing the camera from left: Joseph Bowring and David Patton, independent market monitors for PJM and MISO, respectively; Commissioner Greg White, Michigan Public Service Commission; Chairman Phil Montgomery, Wisconsin Public Service Commission; Kari Bennett, Indiana Utility Regulatory Commission; Andy Ott, PJM executive vice president for markets, and Clair Moeller, MISO executive vice president for transmission and technology. (Source: FERC)
RTO representatives and state regulators made their cases before the Federal Energy Regulatory Commission in a dispute over capacity deliverability across the PJM-MISO “seam.” Facing the camera from left: Joseph Bowring and David Patton, independent market monitors for PJM and MISO, respectively; Commissioner Greg White, Michigan Public Service Commission; Chairman Phil Montgomery, Wisconsin Public Service Commission; Kari Bennett, Indiana Utility Regulatory Commission; Andy Ott, PJM executive vice president for markets, and Clair Moeller, MISO executive vice president for transmission and technology. (Source: FERC)

The commission ordered the presentation as part of a docket it created last June to determine whether it needs to get more involved in a long-standing dispute between PJM and MISO over PJM’s rules for determining the volume of capacity that can be imported across the PJM-MISO “seam.”

PJM: No Artificial Barriers

Andy Ott, PJM executive vice president for markets, told the commission that MISO’s complaints are belied by PJM’s 2016/17 capacity market auction, in which 4,700 MW of MISO capacity bid, all of it clearing. That was more than double the volume that bid in last year’s base auction; about one quarter of the total came from territory new to MISO, including the Entergy transmission system.

“We really haven’t seen barriers” to MISO generation, Ott said. Ott said the commission should not set deadlines for a resolution of the dispute but continue monitoring the JCM stakeholder process through its staff, calling it a “very powerful” force in ensuring the talks progress.

But Commissioner Tony Clark was unconvinced that what he called the commission’s “benign neglect” stance had been effective:  “Staff has monitored [JCM] for the last six or seven years,” he said. “It stalled.”

Other commissioners also signaled impatience with the status quo.

Commissioner Cheryl LaFleur said that since FERC’s ill-fated attempt at imposing a Standard Market Design, the agency has allowed regional transmission operators to develop different market structures and operating procedures. While PJM and MISO have done the most work of any two RTOs on seams issues, she said, “There’s still a long, long list of things to work on.”

Deadline `Discipline’

Commissioner Philip Moeller said the resumption of the JCM process last year was “overdue” and that the talks could benefit from the “discipline of a deadline.”

“To the extent that this becomes a reliability issue, it’s absolutely something we can’t ignore,” he said, referring to MISO’s concerns that its current capacity surplus may become a shortage in several years, requiring it to seek capacity imports from PJM.

Commissioner John R. Norris said MISO may be correct in its complaint that PJM rules are artificially restricting capacity imports below physical transport limits. “My sense is, there is a there there.”

PJM and MISO have been holding monthly JCM meetings since July but MISO says the talks have made little progress in addressing capacity deliverability. In a filing in January, MISO asked the commission to set deadlines for resolution of the issue. PJM responded that the commission should reject MISO’s request and close the docket.

State Regulators’ `Blueprint’

Commissioner Clark said the commission should follow the “blueprint” proposed by state regulators last week. The joint filing by the Organization of PJM States (OPSI) and the Organization of MISO States (OMS) called for fact finding to identify methodologies for: determining transfer capability between MISO and PJM; the feasibility of potential revisions to existing rules and a way to compare the costs and benefits of such changes.

The states said the JCM should consider hiring an independent consultant to help mediate if PJM and MISO are unable to agree.

“It is not helpful for either RTO to insist upon an end-result or outcome without having supportive documentation and analysis,” the groups said. “Without collaborative involvement from both RTOs the output of any fact finding and subsequent analysis would likely be unreliable.”

Links to Presentations

PJM Faces Resource Limits

By Rich Heidorn Jr.

Is PJM in danger of eating itself to death?

That existential question was raised at Wednesday’s Market Implementation Committee meeting by Customized Energy Solutions’ Bill Schofield who has been voicing concerns for months about the growing stakeholder workload.

Schofield, who represents the PJM Public Power Coalition, used an analogy from his horse-riding wife to make his point. Given unlimited access to food, he said, “Many ponies will basically eat themselves to death.”

FatPony
Fat Pony (Source: Minnesota Farriers Association at MinnesotaFarriers.Com)

Noting that PJM stakeholders are adding new problem statements and work groups faster than they are completing them, he observed: “We seem to be a bunch of ponies here.”

Schofield’s concern was borne out by MIC chair Adrien Ford, who said PJM was having trouble providing enough facilitators to run meetings on the problem statements.  Ford said no facilitators would be available to take on a new problem statement before late summer.

The discussion came as the MIC discussed where to slot its latest problem statement — a review of the FTR forfeiture rule for increment and decrement transactions — in its new work plan. The plan lists 14 issues under study.

Jeffrey Mayes, general counsel of Monitoring Analytics, said the FTR issue, which was assigned to the MIC May 30, shouldn’t be taken up until at least October. Mayes said the committee should focus first on a problem statement sponsored by the monitor to consider ending compensation “adders” for frequently mitigated generating units (FMU). (See “PJM Reconsiders Adders on Cost-Capped Generators.”)

David Pratzon, who represents generators, disagreed, saying the stakeholder consensus was that FMUs are a “small-dollar issue.”

“FTRs affect a whole lot more people in the market,” he said.

Ford sided with Pratzon and said the FTR forfeiture issue will be scheduled before the FMU inquiry.

Manual Changes Approved by Operating Committee on June 4, 2013

The Operating Committee Tuesday approved changes to Manuals 14 and 36. The changes go next to the Markets and Reliability Committee for final approval.

Manual 14D: Generator Operational Requirements

Reason for changes: Conforming with other manuals; revised NERC standard; updated information; and addition of Wind Unit Dispatchability Check List.

Impact:

  • Multiple sections revised to replace outdated references.
  • Section 7.1.1, Generator Real-Power Control: Revised for consistency with M-36.
  • Section 7.1.3, Notification to PJM for Reactive Power Resource Status during Unit Start-up: revised to reflect changes in NERC Standard VAR-002-2b, R1, effective July 1.
  • Section 7.3, Critical Information and Reporting Requirements: Added references to PJM peak period maintenance season and changed notification time from 30 minutes to 20 minutes for consistency with 7.4.
  • Section 7.4 Synchronization and Disconnection Procedures: Revised to include notification times for synchronizing and disconnecting generators from the system.
  • Section 8, Wind Farms Requirements: Revised to include references to Attachments L & M.
  • Attachment H, PJM Generation and Transmission Interconnection Planning Process Flow Diagram, revised for consistency with Manual M-14A/C.
  • Attachment M, Wind Unit Dispatchability Check List: New attachment.

PJM contact: Glen Boyle

Manual 36: System Restoration

Reason for changes: Annual review, incorporating suggested changes from the RFC/SERC audit.

Impact:

  • Attachment G updated to reflect revised EOP-005-2, Restoration Plan Coordination/Approval Process.
  • Attachment B updated for consistency with other RTOs (information to be exchanged prior to interconnection).
  • Updates Attachment H – Underfrequency Load Shed Tables.
  • Adds Attachment I to map manual sections to EOP-005-2 and EOP-006-2.
  • Minor grammatical changes throughout.
  • Attachment F update – Transmission Owner and black start supporting document references
    • Adds specific references to TO restoration plans
    • Allows future updates in separate file to avoid repeated manual updates requiring stakeholder approval.

PJM contact: David Schweizer

Emergency Preparedness Drill Exposed Communications Issues

PJM’s summer 2013 emergency preparedness drill exposed several communications problems and the need for additional training, PJM’s Bill Powell told the Operating Committee Tuesday. Powell identified several issues in his debriefing on the May 14 drill:

  • One company was unable to submit correct Supplemental Status Report (SSR) data in the Dispatcher Applications and Reporting Tool (eDART); two companies requested additional training on SSR.
  • Several companies complained of garbled satellite phone messages.
  • Several companies said that messages on the All Call notification system were too long.
  • Several companies identified the need to perform additional internal training or update internal processes.
  • PJM did not post the Manual Load Dump event on the Emergency Procedures posting application at the same time as the Manual Load Dump All Call. Several companies requested clarification regarding the time to be used in event of an actual load dump situation; PJM said the All Call time will be used.
  • Several inconsistencies were noted in drill sequence and accompanying All Call messages regarding loading max emergency combustion turbines first instead of steam units. All Call drill wording did not match some of Manual 13. Future drill messages will be corrected to match PJM manuals.

PJM contacts: Bill Powell, Dave Turtle
epdrill@pjm.com
610-955-2466

Lessons from Hurricane Sandy: Dispersed Staffing, Generator Cuts

Transmission owners should consider locating staff in 500 kV substations in advance of future hurricanes, and PJM should be quicker to take generation off-line as load is lost, the Operations Committee was told Tuesday.

PJM’s Mike Bryson briefed the committee on lessons learned from Hurricane Sandy, the results of a detailed review by the System Operations Subcommittee Transmission group (SOS-T).

Among the key lessons:

Staffing:
  • TOs that manned their 500 kV substations were able to respond to Remote Terminal Unit (RTU) failures quickly and had response crews geographically dispersed, allowing them to get to other substations more rapidly. RTUs collect data from transducers at remote locations and convert it for transmission to the Supervisory Control and Data Acquisition (SCADA) system used to monitor and control the grid.
  • Emergency staffing plans should be amended to include provisions for conditions in which control room staff cannot leave due to weather or road conditions. PJM discovered this vulnerability when fallen trees blocked the road in both directions outside its Advanced Second Control Center (AC2) in Milford, PA.
Generation planning:
  • Fearing the loss of load and large generators during the storm, PJM ran additional local generation. But while load was lost, generation remained on-line, resulting in high voltage conditions. PJM said it should have taken generation off-line more quickly. Inspections found that none of the equipment that experienced high voltage during the October storm was damaged.
500kV line switching:
  • The storm required PJM to perform 500 kV line switching for voltage control for the first time. Before implementing the switching, PJM reviewed generation on-line, potential interactions with Special Protection Schemes, transient stability and Nuclear Plant Interface Requirements. The SOS-T recommended developing a checklist for future use to ensure these studies are consistent and that switching doesn’t create unanticipated problems.
Phones:
  • Service on cell phones and landlines was unavailable or spotty but text messages were successfully transmitted. The committee recommended having text-capable phones for operators and crews.
Customer Outage Reporting:
  • PJM’s calls to TOs for verbal updates on customer outages distracted the TOs from operations and restoration. PJM plans to develop a tool to scrape the TO websites for these updates.

(See “PJM Year in Review: Storm Recovery, Lower Prices, Continued Growth.”)

Manual Changes Approved by Planning Committee on June 6, 2013

The Planning Committee Thursday approved changes to Manual 19: Load Forecasting and Analysis. The changes go next to the Markets and Reliability Committee.

Reason for changes: Integration of East Kentucky Power Cooperative (EKPC), addition of annual demand resources; and need to ensure accuracy of load shed programs.

Impact:

  • Adds EKPC to load forecast model;
  • Revises assumption for winter load management;
  • Makes minor typo fixes and clarifications for NERC audits;
  • Changes demand resources available in winter months due to addition of annual DR product; and
  • Codifies guidelines for switch operability studies for load management programs. The guidelines are designed to ensure the accuracy of load shed estimates for participants in Direct Load Control programs. The study must be designed for a minimum 90% confidence level and based on a randomly selected sample from the entire population of participating customers. No customers can be excluded.

PJM contact: John Reynolds

MIC Seeks Better Way to Draw Capacity Supply Curve

The Market Implementation Committee will consider modifying the algorithm used for publishing supply curves resulting from the annual capacity market auction.

MIC Wednesday approved a problem statement by Jason Barker of Exelon to seek improvements to the supply curve currently produced by the Market Monitor, which masks individual price-quantity offers. The practice is a compromise resulting from a 2010 Federal Energy Regulatory Commission order (ER09-1063-003) that sought to balance transparency against disclosure of commercially sensitive data.

Barker said the current curves are not accurate enough for any Locational Deliverability Area to be useful in analysis.

The FERC order resulted from a dispute over PJM’s proposal to publish price-quantity pairs after the 2010 Base Residual Auction. Constellation Energy and the monitor said that, due to the concentration of generation ownership in the SWMAAC LDA, the data could be used to reconstruct market participants’ offers.

Barker presented examples of two different algorithms that he said would improve the current methodology: a six variable polynomial and a four-period moving average. The current method, based on a single variable equation, produces a smoothed curve that passes through the intersection of the actual supply and demand curves.

Barker said an improved curve would provide “a better indication of slope inflections” that would help market participants analyze supply and regulators ensure auction results are just and reasonable.

Steve Lieberman, representing Old Dominion Electric Cooperative, supported the change. “It’s obvious almost any formula would be more accurate” than the current one, he said.

A stakeholder representing a retail marketer pushed for a one-month delay before a vote on the problem statement, saying he wanted to hear whether the monitor would oppose the change.

Marji Phillips, of Hess, grew impatient with the request for a delay on the vote. “This isn’t a complicated issue,” she said. “I can’t tell you how counterproductive and stupid [the discussion] looks.”

Jeffrey Mayes, general counsel of Monitoring Analytics, told the committee the monitor wouldn’t oppose changes to the formula as long they could not be “reverse engineered” to reveal actual offers. Yesterday, however, he told PJM Insider that Market Monitor Joseph Bowring is “convinced that [Exelon’s suggested  alternatives] do reveal the offer data that we’re concerned about.”

The statement was approved by acclimation, with 16 abstentions. MIC will consider the Issue Charge at its next meeting. Barker said the work should be completed by December to enable analysis of the 2016/17 supply curves under the revised algorithm before the 2017/18 auction. Any change will require FERC approval.

PJM: We’ll Sue

Settlement Near?

By Rich Heidorn Jr.

We started publishing PJM Insider a few months ago to provide comprehensive and objective news coverage and analysis of the PJM Interconnection. In this article, we won’t pretend to be objective, because this involves us – and you.

Those of you who have attended or listened in to PJM meetings in the last few months have gotten used to me introducing myself with the statement: “PJM Insider is neither associated with, nor endorsed by, PJM Interconnection, LLC.”

A number of you whom I’ve gotten to know personally have shaken your head in disbelief when I told you that — despite the ubiquitous disclaimers on our website and newsletter — PJM has been threatening since February to sue us over our name.

On Thursday, PJM sent a draft of that long-threatened suit to our lawyer. Central to PJM’s claim is that we are confusing you into thinking we’re connected with PJM. PJM also accuses us of “unfair competition.”PJM-draft-lawsuit-header-only

Since receiving the suit, our lawyer has spent hours on the phone with PJM’s counsel in an attempt to settle this matter without litigation.

As we will explain later, we feel very strongly that the use of “PJM” in our title is protected by both the fair use doctrine and the news reporting/news commentary privilege. We are confident that we would win in court.

But as a small, very new publication, we have to pick our fights. We have agreed to pursue settlement discussions to avoid the distraction and cost of litigation and keep our focus on providing PJM’s stakeholders with the best quality journalism and analysis.

This is a service PJM deserves – and more importantly – needs. Hundreds of you tell us every week that you agree, by opening our emails and visiting our website.

The final details of this settlement should be worked out over the next couple days. The outlines are the deal are that we will agree to transition to a new title and new URL using our corporate name, RTO Insider.

So, sometime soon, you may see “RTO Insider/PJM.” Same intensive coverage, less contentious name.

We’ll provide more details in a couple of days. The less said now — in the middle of negotiations — the better.

In the meantime, know that we remain: “Your Eyes and Ears at the PJM Interconnection.”

Alternative Wind Capacity Calculations Yield Murky Results

Proposals to eliminate the impact of curtailments on wind generators’ capacity calculations create many losers as well as winners, according to data presented to the Planning Committee Thursday.

Two proposals are being considered under a problem statement approved in April to protect intermittent generators from being assigned artificially depressed capacity values as a result of curtailments directed by PJM.

Wind-generator-curtailments-2012

 

Under current policy, when wind generators are curtailed by PJM for any portion of a peak summer hour, the hour is excluded from the generator’s capacity credit calculation.

PJM staff conducted an analysis of the two alternative calculations using data for summer 2012, when 33 of 50 wind generators had at least one curtailment.

Alternative 1

Impact-of-Alt.-1-on-Curtailed-UnitsAlternative 1 removed from the calculations only the five-minute periods in which a curtailment occurred rather than the full hour, as in current practice.

It increased capacity factors for 21 of the 33 units that experienced curtailments (64%).  Changes ranged from an increase of 2.6 percentage points to reductions of almost 2 points with a median increase of 0.2 points.

The biggest increases in capacity factors went to units curtailed most frequently — a 2 percentage point boost for most units with more than 150 curtailed five-minute periods.

Alternative 2

Alternative 2 reduced capacity factors for 21 of 33 curtailed generators. It estimates what the generator’s output would have been during curtailment by interpolating data between the five-minute periods before and after the interruption.Impact-of-Alt.-2-on-Curtailed-Units

Alternative 2 showed a more normal distribution of impacts, with little correlation to the number of curtailment periods. It reduced capacity factors by a median of 0.2 percentage points, with some units losing almost 2 points while others increased by 2 points.

No Robust Solution

Steve Herling, PJM vice president of planning, said PJM limited the analysis to 2012 because data from prior years was not as reliable or complete.

“With only one year of data it’s going to be very difficult to come up with a solution that’s really robust,” Herling said. “That doesn’t mean we shouldn’t try to do something.”

The committee will be asked at its next meeting to decide whether to choose one of the alternatives or to leave the methodology unchanged.

PJM’s current procedure uses hourly integrated metered data. The two alternatives would use five-minute data from PJM’s state estimator. Because the hourly integrated data is more accurate, PJM plans to continue to use that data for the units with no curtailments, said PJM’s Tom Falin.

See “MRC Action: Calculating Capacity Values for Intermittent Resources.”