November 1, 2024

PJM MIC Briefs: May 10, 2023

PJM Proposes Creation of Fifth CONE Area

VALLEY FORGE, Pa. — PJM last week proposed creation of a new cost of new entry (CONE) area for the Commonwealth Edison (ComEd) zone during discussions about how to account for local factors in calculating net CONE.

PJM’s Gary Helm said the discussion arose out of concerns raised in the RTO’s quadrennial review filing at FERC about the impact of the Illinois Climate and Equitable Jobs Act on net CONE. An issue charge and problem statement were adopted following the approval of that filing to evaluate how asset life and net CONE are determined. (See “Amortization Period,” FERC Approves PJM Quadrennial Review.)

“What we are looking at proposing here in this package is addressing that specific item through making ComEd, that [locational deliverability area], its own CONE area. So we currently have four CONE areas; this would be a fifth,” Helm said. He added that PJM is also considering what other areas could be impacted by approved state and local legislation or other localized factors.

Stakeholders Continue Discussion on Co-located Load Packages

Several packages seeking to create new rules for generators with co-located load were discussed by the Market Implementation Committee during its May 10 meeting. PJM’s Tim Horger worked with package sponsors to create a comparison of the five current proposals. (See “Discussion on Co-located Load Packages,” PJM MIC Briefs: April. 12, 2023.)

Much of the ongoing discussion of the proposals has centered on configurations in which the co-located load isn’t directly connected with the grid and whether those loads should be considered FERC jurisdictional or falling under state regulation. The discussion has also focused on whether generators should be permitted to retain their full capacity interconnection rights (CIRs) for the balance of their output consumed by the load and what service fees, if any, should be allocated to the load or generator.

The Independent Market Monitor proposal would follow the status quo of requiring generators to reduce their CIRs corresponding to the co-located load consumption, while the other four would not. The PJM, Constellation/Brookfield and Exelon packages specify that CIRs can be retained so long as the load is capable and willing to curtail within 10 minutes and that output be able to shift over to the grid.

The Advanced Energy Management Alliance (AEMA) package considers all co-located load to be FERC jurisdictional and as taking services from the grid. It would permit generators to retain their full CIRs.

The Constellation/Brookfield proposal is the only one to not charge any grid services to the configuration. The PJM package would assess regulation, reserve and black start fees to the entire load by assigning them to the generator. Exelon’s would consider the generator to be a load-serving entity for the co-located load and levy all LSE credits and charges. The Monitor proposal would include charges for regulation, reactive power, frequency control, reserves and black start via the generator, and the AEMA proposal includes all firm point-to-point transmission charges.

All proposals except the Monitor’s would permit the inclusion of curtailment costs in their market-based energy market offers, but not their cost-based offers. The monitor would not permit any inclusion.

The Constellation/Brookfield and Exelon proposals are silent on configurations in which the load is receiving service from the grid, while the AEMA proposal has the same rules for all configurations.

Under configurations with grid service, both the PJM and Monitor proposals would require CIRs to be reduced and consider the load to be FERC-jurisdictional. The Monitor also applies all LSE charges and credits, while PJM does not.

Exelon presented minor changes to its proposal since its last presentation, clarifying that the co-located load could participate as either demand response or price-responsive demand, incorporating PJM feedback to lengthen the initial public notice to 10 days and adding a provision to grandfather PJM’s market rules for co-located load configurations that were approved by the relevant electric retail regulatory authority prior to 2024.

MIC Chair Foluso Afelumo said the committee will likely be continuing first reads at the June meeting to accommodate a data center developer that plans to present an additional package at that meeting. Voting on endorsement could begin at the July meeting.

PJM will also give additional thought to how voting will be structured, as four of the proposals have separate provisions for co-located load with and without service from the grid, while the AEMA proposal addresses both.

Other MIC Business

  • The committee endorsed by acclamation a PJM problem statement, issue charge and proposal to clarify that smoothened supply curves will only be generated after Base Residual Auctions and not Incremental Auctions. Tariff revisions will move on for consideration at the Markets and Reliability Committee and the Members Committee. The proposal was brought under the quick fix process, allowing solutions to be voted on simultaneous with the problem statement and issue charge. (See “First Read on Smooth Supply Curve Quick Fix,” PJM MIC Briefs: April. 12, 2023.)
  • Stakeholders endorsed revisions to Manual 11 to allow PJM to reduce the Transmission Constraint Penalty Factor under a set of circumstances when it is believed the penalty cannot incentivize actions that would reduce constraints. The proposal codifies a package previously approved by stakeholders and a FERC order in March. (See FERC Approves PJM Proposal to Reduce Congestion Penalty During Grid Upgrades.)
  • The MIC endorsed revisions to Manuals 11, 27 and 28 to add market rules for hybrid resources. The proposal will go before the MRC for endorsement on May 31, followed by a FERC filing with a requested effective date of June 1.
  • Stakeholders endorsed revisions to Manual 15, which PJM’s Glen Boyle described as minor updates to clarify current processes related to heat input guidelines and the IMM Opportunity Cost Calculator.
  • The Consumer Advocates for PJM States gave a first read on a proposal to amend the issue charge for the Reactive Power Compensation Task force, reducing the items considered out-of-scope to permit discussion of “any existing FERC approved or pending reactive service rates.”

Overheard at IPPNY 2023 Spring Conference

ALBANY, N.Y. — The Independent Power Producers of New York’s (IPPNY) annual Spring Conference on Wednesday highlighted the challenges New York faces as it decarbonizes.

Some prominent figures in the industry shared their thoughts on how New York can achieve its ambitious energy and climate goals.

Doreen Harris 2023-05-10 (RTO Insider LLC) FI.jpgNYSERDA President Doreen Harris | © RTO Insider LLC

“We are literally experiencing this transition in every way across our economy every day,” said Doreen Harris, president of the New York State Energy Research and Development Authority. “We got our work cut out for us” because “when it comes to climate action and clean energy, all eyes are on New York. …

“But I am truly optimistic about the ways we can achieve [New York’s] goals and build a truly inclusive energy economy that sets the example for others to follow,” she added.

“We’re entering the period in our transition when it feels like a marathon,” New York Public Service Commissioner Diane Burman said, so in the near term, the state must “focus on being prepared and getting the right resources in place.”

“We need to look at every technology, because wind and solar aren’t going to get the job done,” State Sen. Mario Mattera (R) said. Constituents must demand more answers from their policymakers “about how this transition will get done and paid for” because “we want to make sure we’re creating jobs, not losing them.”

Didi Barrett 2023-05-10 (RTO Insider LLC) FI.jpgNY Assemblymember Didi Barrett | © RTO Insider LLC

New York State Assemblymember Didi Barrett (D) agreed, saying, “This [transition] cannot be done on the back of ratepayers,” adding that the state “needs to be open to new technology opportunities” while “educating the public about the realities they’ll face.”

Keynote speaker Alexis Glick, CEO of biomethane producer Nature Energy, discussed the benefits from biofuels, saying, “We need an all-of-the-above approach because it’s what New Yorkers do really well.” They “recognize that innovation, investment, fresh thinking and an inclusive approach is critical to our combined success.”

Bart Franey, vice president of clean energy development at National Grid, noted the benefits from energy storage resources and how they can enable New York to connect other renewables to the grid at scale without the need to make as many transmission and distribution system upgrades.

Rudy Wynter, president of National Grid, commented on the importance of workforce training and development, saying, “We want to make sure that all the jobs that will be created during the energy transition are secure, because we know in previous [historical] transitions communities have been left behind … so [National Grid] works directly with communities to make sure they understand that those jobs are coming, and we help them get prepared for those jobs.” (See In Climate Leader NY, Energy Workforce Rising from Ground Up.)

Zach Smith, NYISO vice president of system and resource planning, commented on how dispatchable emissions-free resources are “not some unicorn technology.” New York can attract future resources with certain desirable attributes by sending the right price and market signals that encourage investment in new technologies.

In reference to the increasing risks posed by extreme weather events, Chris Wentlent, chair of the New York State Reliability Council’s Executive Committee, said the state needs to understand how every grid resource is impacted and correlated to natural disasters because without this knowledge, the state will struggle to successfully transition.

Aaron Markham 2023-05-10 (RTO Insider LLC) FI.jpgAaron Markham, NYISO | © RTO Insider LLC

Aaron Markham, NYISO vice president of operations, said, “We need to keep our eyes open to how [New York’s] transition is progressing” because there is a concern that as the state decarbonizes, its energy supplies could become compromised and the ISO will find itself unable to reliably meet growing electricity demands.

Eastern Generation CEO Mark Sudbey said, “We need to be realistic to people about decarbonization’s timelines because I am concerned that our goals are too aspirational” and, in attempting to transition too quickly, the state may end “up doing something foolish.”

IPPNY President Gavin Donohue closed out the meeting by saying the challenge for New York will be to transition in a reasonable manner while ensuring that innovation is not compromised, investments are not discouraged and that environmental justice concerns are still considered.

IPPNY Panelists Urge Collaboration, Coordination in Transition

ALBANY, N.Y. — There was no shortage of ideas on how to overcome the well known challenges to carrying out New York’s clean energy transition last week at the Independent Power Producers of New York’s 37th Spring Conference.

Much of the conference built on themes discussed last year, such as how to best implement New York’s climate legislation, the need to expand the grid without compromising reliability or hurting ratepayers, and that everyone needs to be involved in the transition. (See Overheard at IPPNY 2022 Spring Conference.)

Since New York passed the 2019 Climate Leadership and Community Protection Act (CLCPA), the state has set itself on an aggressive decarbonization timeline: 70% renewable electricity by 2030, 100% zero-emission electricity by 2040 and net-zero emissions statewide by 2050. The Climate Action Council (CAC) recently approved a Scoping Plan that laid out a roadmap for how New York can meet CLCPA goals. (See New York Climate Scoping Plan OK’d.)

These deadlines are fast approaching, and panelists agreed that New York needs to act quickly, but methodically. Many of New York’s fossil fuel plants are due to retire soon, and if the state has not installed enough reliable renewable capacity to replace that baseload generation, then those emissions-producing plants may need to stay online, which means that the state will not meet its objectives.

Gavin Donohue 2023-05-10 (RTO Insider LLC) FI.jpgGavin Donohue, IPPNY | © RTO Insider LLC

IPPNY President Gavin Donohue opened the meeting saying, “The purpose of this conference is to work together to identify innovative technologies that are zero-emitting and, ultimately, are going to bolster both reliability and affordability.”

Common refrains heard during the conference were that New York needs to encourage more collaboration and be more open to innovative ideas or resources because this will better position the state to achieve its mandates.

Corinne DiDomenico, director of regulatory affairs at NextEra Energy Resources, said “the state has very discrete goals with very rigid timelines” and as those deadlines approach, “things start to get messy, and so with that in mind, we need flexibility to address incoming challenges.”

Corinne Didomenico 2023-05-10 (RTO Insider LLC) FI.jpgCorinne DiDomenico, NextEra Energy Resources | © RTO Insider LLC

The state’s grid currently has 37,520 MW of total installed capacity, according to NYISO, and about 70% of that capacity is fossil fuel, the majority of which are dual-fuel systems for downstate zones; many will retire soon.

NYISO’s 2022 Reliability Needs Assessment found that these retirements are leading to tightening transmission security and resource adequacy margins that could become deficient by 2025 if critical emissions-free projects — such as the Champlain Hudson Power Express, an immense transmission project to import hydroelectric power from Quebec to New York City — experience delays. (See Champlain Hudson Power Project Receives Landmark Delivery.)

New York is walking a tightrope between its lofty aspirations and reality on the ground.

“We need to be able to adapt to the changes we see every day because, as exemplified by COVID, markets need to be able to react and respond,” DiDomenico said. “The state also needs a lot more coordination to happen to address the world changing around us.”

A desire for flexibility was also seen in a panel about climate change, resilience and reliability during extreme weather events, where natural gas was seen as critical to meeting current energy needs, particularly during emergencies like the December winter storm.

Chris Wentlent 2023-05-10 (RTO Insider LLC) FI.jpgChris Wentlent, New York State Reliability Council | © RTO Insider LLC

“We’ve had a surplus of fossil fuel resources, and that surplus not only offers flexibility and resiliency, but lets [NYISO] manage the grid as reliably as you see … and we don’t want to risk that,” said Aaron Markham, NYISO vice president of operations. “In New York there remain incentives to maintain dual-fuel capabilities because, particularly during high demands in the winter, we have to have fuel on site that can provide resiliency in case there is an emergency.”

The panel was supportive of renewable development but agreed that gas has a role in the transition.

“ISOs need be thoughtful about retiring [natural gas plants] too soon, because we don’t want to impact loads during the transition to a renewable future because we want to make sure we have sufficient resources available to meet resource adequacy needs,” Stephen George of ISO-NE said.

Chris Wentlent, chair of the New York State Reliability Council (NYSRC) Executive Committee, agreed. “Fortunately we went into this winter with a great fuel diversity that provided benefits when we started moving into the extremes for load,” he said.

Bart Franey 2023-05-10 (RTO Insider LLC) FI.jpgBart Franey, National Grid | © RTO Insider LLC

This flexibility and desire for New York to think more creatively was best expressed by William Acker, executive director of the New York Battery and Energy Storage Technology Consortium, and Bart Franey, vice president of clean energy development at National Grid, during a panel on “The Future of the Electric Grid.”

“There are a lot of tools in our toolbox that can optimize [New York’s] transition going forward,” Acker said.

New York “needs to think about different kinds of solutions and be more flexible, and not always be applying standard practices to its transition,” Franey added.

Flexibility was not the only thing on panelists’ minds, and frequently, they cited the need for greater cooperation.

Franey said the state “needs to do a better job coordinating land use very purposefully” and engage with communities directly because New York does not have vast tracts of land to install large-scale renewable projects.

This call for greater cooperation was most observable during the fireside chat between State Sen. Mario Mattera (R) and Assemblymember Didi Barrett (D).

Mattera, the ranking minority member on the Senate’s Energy and Telecommunications Committee, said that “when I’ve worked with developers, they always come up to me saying that we need to get the local community involved, that we need to have open forums, and we need to involve everyone, because when you don’t do that, that’s when you have problems.”

Barrett, chair of the Assembly’s Energy Committee, concurred. “We’re not going to get to our goals by bullying people, by shaming people, by calling people names or lying, so my goal is to make sure that we do bring all of our communities, all of our producers and all of our businesses together, since they are important to our decarbonization”

Some still expressed skepticism about New York accomplishing its near- to medium-term goals, though they thought it was not too late to learn from any early mistakes and change course.

“I think New York has an aggressive but appropriate climate agenda,” Franey said, but he added that “with regards to 2030 goals, we got caught flatfooted, and to make sure 2040’s goals become real, we need to start thinking about planning and infrastructure that will be needed to address affordability and reliability concerns.”

Public Service Commissioner Diane Burman, agreed, saying, “We have to be clear that our near-term opportunities are not necessarily all going to be a done deal and that there will be significant challenges. …

“This transition does have fundamental risks, and we need to be open and transparent about that and work through those challenges together to figure out solutions,” she added.

Doreen Harris, president of the New York State Energy Research and Development Authority (NYSERDA), was more optimistic, saying, “We each have a critical role to play in this effort, and I believe change is not easy, but it is realizable. …

“This mid-transition point will have some messy spots on the way,” she added, but “I believe we are coming together in ways that not only get us from here to there but make our state the better in doing so.”

Panelists offered specific recommendations about how New York could be more flexible in its approach or better coordinate the transition.

NYISO’s Markham called for greater interregional cooperation among the RTOs/ISOs, saying, “Coordination amongst all [our neighbors] and state agencies as new polices are developed is critical to ensure there is an ability in those polices to keep resources around for reliability if necessary, because, in my opinion, that will minimize disruptions.”

Wentlent cited the NYSRC’s recent creation of an Extreme Weather Working Group, which was tasked with understanding how the grid is impacted by increasingly frequent and devastating disasters.

“We, and NYISO, are only at the cusp of understanding these [extreme weather events],” he said. He advised that New York study how every resource is correlated and impacted by these events because “until we understand all these pieces, we’re just at the beginning.”

Franey recommended that NYISO “could gain a lot of interesting efficiencies if [they] integrate storage with transmission … and, in some cases, could become more economical and efficient.”

“We have to make sure that we can be creative in our transmission-distribution system buildout, and that means looking at other technologies and not just traditional transmission technologies, since we want to make this as cost-effective as possible,” he said.

More than One Way to Skin a Cat

For decades New York’s clean energy sector has been dominated by nuclear and hydroelectric power, yet they do not produce nearly enough energy to achieve CLCPA mandates, speakers said.

That emissions-free generation has been bolstered recently, particularly by wind, which will soon make up a large part of New York’s total energy production once offshore projects being planned along the coast are connected. But still more renewables are needed if CLCPA goals are to be met.

The state’s future success will also heavily rely on distributed energy resources and dispatchable emissions-free resources, both of which are nowhere near at scale to meet the energy demands being asked of them and, to many observers at the conference, have yet to be fully fleshed out.

In that context, many panelists called for a more inclusive approach to New York’s decarbonization.

Mattera was one of the most vocal, saying, “It seems like we’re not doing enough to consider other energy technologies,” citing the perceived lack of research into hydrogen, geothermal, carbon capture, storage or wastewater heating technologies.

Keynote speaker Alexis Glick, CEO of biomethane producer Nature Energy, called for greater usage of biofuels. She pointed to the EU as evidence for how there are many ways to reach net zero, noting how it was forced to think creatively about its transition after Russia’s invasion of Ukraine caused gas shortages and embrace renewable natural gas (RNG).

“RNG is seen as a key ingredient to [Europe’s] clean energy future,” Glick said. The union, via the RePowerEU program, has committed to annually produce 35 million cubic meters of biomethane to displace Russian gas by 2030. “I believe RNG needs to play a critical role in our energy transition to achieve our mutual goals,” she said.

New York currently uses 50 trillion BTU of RNG per year, according to an April 2022 report from NYSERDA, and bioenergy accounts for less than 2% of the state’s electric generation, according to the agency. Biofuels were one of the most contentious topics as the CAC was developing the Scoping Plan, as members disagreed on its environmental benefits and role in the transition. (See Natural Gas Debate Heats up Hearing on CAC Scoping Plan.)

The Scoping Plan would recognize these resources as ways to reduce state emissions, but it still faces stiff activist resistance, which is why hydrogen was also discussed during the conference and offered as alternative to fossil fuels.

During an industry fireside chat, panelists such as Tim Cortes, chief technology officer at Plug Power, which develops hydrogen fuel cell systems, noted that hydrogen can be an important piece to the transition puzzle.

“Because we are still in the early stages of this transition, it is critical that we not take any viable solutions that could decarbonize the economy off the table,” he said.

“In the long run, hydrogen gives us the ability to be part of the solution by lowering emissions while keeping generating facilities that would’ve been retired around for a longer period of time,” said Mark Sudbey, CEO of Eastern Generation.

Referencing the risks posed by the early retirement of many fossil fuels generators, Rudy Wynter, New York president of National Grid, said, “We’re going to need a lot of solutions to achieve our goals, and so we should keep an open mind to the many pathways to decarbonization. …

“Hydrogen can play a role in this transition, especially if you’re operating off natural gas distribution networks because it will help to decarbonize those fossil fuels,” he said. Furthermore, RNG and hydrogen “can help us decarbonize [natural gas] molecules, because let’s be clear, not everyone is going to be able to afford to electrify, and some customers may have a harder time finding alternative decarbonization fuels.”

There was some reluctance about hydrogen’s potential, however.

“I think it’s still pretty early to judge [hydrogen’s] effectiveness in New York,” Markham said, because the “the challenge is that, No. 1, we still need the infrastructure to support not only the production and transportation of hydrogen, but also the storage; and secondly, what will the cost of that hydrogen be? Because the costs vary wildly.”

Hydrogen’s fluctuating costs can be partially attributed to its many forms, where the price of blue hydrogen, which is produced from fossil fuels, and green hydrogen, which comes from the electrolysis of water to produce zero emissions, are dependent on the price of the resource that they are derived from.

More important, there is a hard push to develop technology to generate green hydrogen much more cheaply, and the degree to which it is successful will be a critical determinant of green hydrogen’s prospects for large-scale adoption as a fuel.

NYSERDA’s Harris, however, cited hydrogen as an example of the collaboration the transition can create, referring to the seven-state Northeast Regional Clean Hydrogen Hub that was led by New York but pooled everyone’s expertise. (See Vermont Joins Northeast Clean Hydrogen Hub.)

“I believe we put together not only a winning proposal, but one in which we can continue to think about this resource and the ways it can help us achieve decarbonization,” she said.

“We have to catch our breath and recognize that we’re all in this together,” Commissioner Burman concluded. “We need to keep focused on what can be helpful as we move forward and how do we accomplish our transition in a way that is helpful, and not just rip off the Band-Aid saying, ‘We got this,’ because we may not, and we cannot risk reliability, affordability or safety.”

BOEM Cites Fishing, Cultural Concerns for Atlantic Shores OSW

New Jersey’s largest planned offshore wind farm would have a “major” effect on commercial fisheries and “scenic and visual resources,” but only a moderate impact in 13 other categories, the Bureau of Ocean Energy Management said Monday in its an environmental impact statement (EIS) for the Atlantic Shores project.

The 900-page draft report on the 1,510-MW project concluded that the wind farm would have “moderate to major” impact on navigation and vessel traffic and a “major” impact on visual aspects of the sea and on cultural resources, such as historic, archeological and geographically significant areas.

The project would also have “negligible to moderate” impact on most mammals, including the endangered North American right whale, the report found. But the cumulative impact of nearby OSW projects and non-wind projects, and Atlantic Shores itself, including decommissioning of the turbines, would be “negligible to major,” the EIS reported. It said adverse impacts would “result mainly from pile-driving noise, vessel noise and presence of structures.”

The impact of OSW projects on whales has emerged as a significant issue in recent months, after several dead whales washed up on the Jersey Shore. Project opponents and two area congressmen have questioned whether the deaths were linked to preliminary marine study work underway for the projects and called for a halt to the projects while the issue is investigated.

Federal and state authorities say there is no evidence that the deaths had anything to do with OSW projects. But poll results released Thursday by Fairleigh Dickinson University suggest the unfounded reports are having an impact on public opinion.

The poll found that when the whale deaths were mentioned in the question, 35% of New Jersey residents said they favored continued offshore wind development, while 39% said development should be halted. When the whales were not mentioned in the question, 42% of those polled were in favor and 33% opposed.

The BOEM report says the impact to the whales of not approving the projects would be “negligible to major,” the same as if the projects go ahead because of issues such as “coastal and offshore development, marine transportation, fisheries use and climate change,” with a warmer ocean and strong storms affecting the sea mammals.

BOEM has scheduled two public hearing to solicit public comments on the draft on June 26 at 1 p.m. and June 28 at 5 p.m., with a 45-day comment period that ends on July 3.

Assessing Impacts

The New Jersey Board of Public Utilities picked the Atlantic Shores project in the state’s second OSW solicitation in 2021, when it also backed the 1,148-MW Ocean Wind II project being developed by Denmark-based Ørsted. The BPU picked Ørsted’s Ocean Wind I project in the state’s first solicitation in 2019. (See NJ Awards Two Offshore Wind Projects.)

The Atlantic Shores EIS covers the project’s first phase, which has been approved by the BPU, and a second phase for an additional 1,327 MW, which has not. Together, the two projects would involve installation of 200 wind turbines.

Monday’s EIS follows by a year BOEM’s release of the draft EIS for Ocean Wind I, which largely made similar assessments. (See BOEM Draft EIS Finds Potential Major Impacts from 1st NJ OSW Project.)

The BPU in March opened the state’s third OSW project solicitation, seeking projects totaling 1.2 GW to 4 GW. (See NJ Opens Third OSW Solicitation Seeking 4 GW+.)

The draft EIS for Atlantic Shores, a joint venture between EDF Renewables North America and Shell New Energies US, assesses the potential biological, socioeconomic, physical, cultural and other impacts of the project, which at its closest is 8.7 miles from the Jersey shoreline.

The study assesses impacts of six different scenarios if the project is approved. These included approval of the entire proposal, along with several scenarios in which the project is modified, including a reduction in the number of turbines and offshore substations to minimize the impact on certain habitats; a reduction of the number of turbines to reduce the visual impact; modification of the project to create a “setback” between the project and neighboring Ocean Wind I; and an adjustment in the type of monopoles used in the foundation to reduce the impact.

The draft EIS then assesses the impact of each scenario and defines them as negligible, minor, moderate or major.

The EIS, for example, concluded in all the scenarios that the impact was either moderate or lower for air; water; birds, coastal habitats and fauna; fish, invertebrates and essential fish habitat; sea turtles; wetlands; demographics, employment, economics; environmental justice; land use and coastal infrastructure; and recreation and tourism.

Increased Vessel Traffic

The study found that the commercial and recreational fishing sectors would be impacted by increased anchoring of boats working on the turbines, marine disturbance caused by cable emplacement and maintenance, and the additional noise generated by construction. Those factors could disrupt fishing trips and make it difficult to fish, as well as prompting some commercial companies to avoid fishing in certain areas — all of which could reduce revenue, the report said.

The effect might also be to push all commercial fishing operations into the same, smaller fishing area, resulting in smaller catches, the report concluded.

“BOEM expects that increased vessel traffic associated with the proposed action would cause long-term, localized, moderate impacts on commercial and for-hire recreational fisheries,” the report concluded. BOEM also found that the overall impact on commercial fishing operations could be “major” in many scenarios.

The study found that the area’s cultural resources would be affected whether BOEM approved the wind projects or not and labeled the impact in the long term “major” in all scenarios, but only “moderate” if the projects were not approved.

“The primary sources of onshore impacts from ongoing activities include ground-disturbing activities and the introduction of intrusive visual elements, while the primary source of offshore impacts includes activities that disturb the seafloor,” the report found. “While long-term and permanent impacts may occur as a result of offshore wind development, impacts would be reduced” through a consultation process to reduce the effects on historic properties, the study concluded.

Navigation and Visual Impacts

The study found that navigation and vessel traffic would experience moderate impact regardless of whether the projects went ahead, in part because of rising traffic in the area and also traffic generated by other offshore wind projects. New Jersey’s OSW projects, if approved, would have a moderate to major impact when added to the cumulative impact of vessel traffic from nearby OSW projects and general water transportation traffic.

“Impacts from the proposed action alone would include increased vessel traffic in and near the project area and on the approach to ports used” by the OSW vessels, the report found. Vessels in the area would also experience “obstructions to navigation” caused by the projects.

During construction, the project would cause “short-term increase in project-related construction vessel traffic, short-term presence of partially installed structures, and short-term safety zone implementation,” the study found.

“Impacts on navigation and vessel traffic would also include changes to navigational patterns and to the effectiveness of marine radar and other navigation tools,” the report said. “This could result in delays within or approaching ports, increased navigational complexity, detours to offshore travel or port approaches.”

The study found that scenic and visual resources would suffer a “major” impact in the longer term, whether the New Jersey wind farms were built or not, because of other wind farms nearby being built and as a result of other marine activities, such as dredging and port improvements, marine minerals extraction and marine transportation, the report found.

If the state’s OSW projects don’t go ahead, “the character of the coastal landscape would change in the short term and long term through natural processes and planned activities that would continue to shape onshore features, character, and viewer experience,” BOEM said.

“Ongoing activities in the geographic analysis area that contribute to visual impacts include construction activities and vessel traffic, which lead to increased nighttime lighting, visible congestion, and the introduction of new structures,” the report concluded. The cumulative impact of other OSW projects and general marine activities would create a “major” impact, the study said. As a result, the cumulative effects of the projects and others in the area would be “appreciable,” the study concluded.

“The main drivers for this impact rating are the major visual impacts associated with the presence of structures, lighting and vessel traffic,” the study found.

PJM OC Briefs: May 11, 2023

PJM Doubles Synchronized Reserve Requirement

VALLEY FORGE, Pa. — PJM has doubled its synchronized reserve requirement to account for diminished performance since the implementation of the reserve market overhaul in October.

Donnie Bielak, PJM senior dispatch manager, told the Operating Committee that reserve performance has been approximately 50% since the RTO implemented reserve price formation last year, which consolidated reserves into one product, lowered the offer cap from $7.50/MWh to 2 cents and expanded resources subject to the must-offer requirement. (See Synchronized Reserve Pricing Falls in PJM Markets After Overhaul.)

The higher reserve requirement, announced to members Thursday morning, went into effect for the day-ahead market for Friday and was in place starting at midnight. The increase amounts to an additional 1,588 MW procured, equal to the single largest expected contingency.

“This is meant to be an immediate, albeit temporary measure,” Bielak said. “We are doing this to make sure we have reliable and uninterrupted service to the load.”

Several stakeholders questioned the timing and the immediacy of the decision, asking why there was not more notice. Bielak told RTO Insider that following stakeholders’ decision to initiate a quick-fix process to address reserve rates last month, PJM staff determined a more immediate solution was needed going into the summer months.

Generator performance during the December 2022 winter storm may have led to a violation of NERC’s disturbance control performance (DCS) standard by potentially taking 52 seconds longer than the permitted 15 minutes to alleviate a contingency event recovery period on Dec. 23.

Independent Market Monitor Joseph Bowring said PJM hasn’t provided any evidence of a reliability issue or that there is a risk of violating the DCS standard. After the operating reserve rule change on Oct. 1, 2022, the must-offer requirement for synchronized reserve significantly increased the amount of reserves available, he said, noting also that there have been no issues with violating the NERC DCS standards. Bowring also asked PJM to explain why it thinks it has the authority to unilaterally double the reserve requirement.

Bielak said PJM thinks it has been able to procure adequate synchronized reserves because some generators are continuing to operate under the old ruleset, despite not receiving revenue for doing so. As that reality becomes clear for market participants, the RTO may not receive the same response to its calls to generators. (See PJM MIC Briefs: April. 12, 2023.)

PJM Projects Adequate Supply This Summer

The 2023 Summer Study found that the RTO will have enough installed capacity, 186.5 GW, to meet its 90/10 load forecast of 162.7 GW. The non-diversified peak demand is expected to be 156.1 GW.

“PJM works diligently throughout the year to coordinate and plan for peak load operations, with reliability as our top priority,” PJM CEO Manu Asthana said in an announcement of the study on Thursday. “We’re not saying these extreme conditions will happen, but the last few years have taught us to prepare for events we have never seen.”

No reliability issues were identified; however, re-dispatch and switching could be required in some areas to avoid thermal or voltage violations.

Demand response may need to be implemented in the event of “extraordinary electricity demand and high generator outages,” with around 7.5 GW in pre-emergency load management found to be available in the study.

The study found that PJM should have resources to cover the outage scenarios historically seen in the summer months. It also draws on lessons learned from the February 2021 winter storm to incorporate the possibility of extreme conditions without precedent.

“We have learned through experience to expand the set of possibilities we prepare for,” Senior Vice President of Operations Mike Bryson said in the announcement. “We will continue to work with our utility partners and stakeholders to refine our planning, analysis and communications of the risks presented by new and challenging weather patterns and other variables.”

About 15.4 GW of discrete generator outages are expected in the study, as well as 4 GW being lost through net interchange. Under the largest gas-electric contingency, which is expected to take 4.8 GW off the grid, PJM would have an additional reserve margin of 4.1 GW. The no-wind and low-solar scenario would reduce available capacity by 5.6 GW, producing a margin of 3.4 GW.

Last year’s study presented the largest contingency and the low-renewables scenario together; however, PJM spokesperson Jeff Shields said it would be unlikely for those conditions to overlap. (See PJM Summer Forecast Reports Sufficient Supply.)

“We didn’t feel that stacking all the contingencies together made for a plausible scenario,” he said. “We wanted to emphasize that with high generator outage failures and high load, combined with either of the unlikely scenarios of almost no sun in peak summer conditions or major pipeline failure, we would have to call on demand response.”

Discussion Continues on Transmission Outage Coordination Proposals

Bowring and PJM presented additional information on dueling proposals to add transparency to the process transmission owners follow to schedule extended outages. (See PJM OC Briefs: April 13 Proposals Seek to Address Transmission Outage Coordination.)

A joint package from PJM, DC Energy and Public Service Enterprise Group (NYSE:PEG) would involve coordination between utilities and RTO staff to identify any extended outages that may be required, evaluate the impact of those outages and expand outage information shared by PJM. Upgrades to facilities may be considered if outages are expected to cause significant operational issues.

The Monitor’s proposal would consider requests to reschedule an outage as a new request and classify it as a late submission if the request comes too close to the scheduled date. The language also would aim to reduce or eliminate approval of outage requests after FTR bidding opens and prevent TOs from bypassing rules for long-duration outages by breaking them into smaller segments.

Bowring said the Monitor’s proposal wouldn’t change existing processes, but it would more clearly define when outages should be considered late and provide market participants with more information about outages.

“We’re not trying to change the way outages are scheduled. We’re just trying to ensure they’re labeled correctly,” Bowring said. “… The goal is to make it easier to understand why the system is behaving the way it is.”

PJM’s Paul Dajewski said the status quo rules allow for outages submitted on time to be rescheduled regardless of their duration, which provides TOs with flexibility when scheduling their outages. He said the ability to reschedule is necessary to account for circumstances such as delays in equipment availability or weather.

Bowring responded that he understood that outages have to be scheduled well in advance and include flexibility but said the Monitor’s proposal wouldn’t change market mechanisms or how outages are scheduled, instead providing more information for other market participants.

Other OC Business:

  • Stakeholders approved revisions to manuals 3 and 36 under each document’s periodic review. In both cases, the changes were updating the manuals with new information, as well as clarifying language in Manual 3.
  • PJM’s Steve McElwee provided a cybersecurity update, saying that a recent attack on Dragos displays the need to stay vigilant against “social engineering” hacks being used to gain access to sensitive systems. (See Cancel: Dragos Breach Did Not Compromise E-ISAC.) He said if a member’s email systems were compromised, it would be difficult for PJM to determine that a breach had occurred unless it had been detected by that organization.
  • The OC voted by acclamation to sunset the Synchronized Reserve Deployment Task Force due to an inability to determine a path forward since FERC rejected PJM’s intelligent reserve deployment in August 2022. Task force facilitator Vijay Shah said its issue charge has limited the ability to discuss the concerns the commission raised in its order and there has been limited discourse and no proposals currently before the group. Shah noted that PJM’s Adam Keech said during the Annual Meeting that RTO staff plan to bring a new problem statement and issue charge this summer.

Overheard at the Energy Bar Association’s Annual Meeting

WASHINGTON — Much of the focus at the Energy Bar Association’s Annual Meeting last week was on the grid’s transition from fossil fuels — specifically matching carbon-free electricity to demand curves.

“For many of you, it may feel like the goalposts are moving, complicating business risks,” NorthBridge Group Partner Neil Fisher said. “And what was considered the gold standard five years ago may not be acceptable in the near future.”

While retiring renewable energy credits from wind farms far from the customer was seen as good enough in the past, now many large, sophisticated customers want to match their load with 24/7 clean energy.

The federal government — the largest buyer of electricity in the country, at about 54 TWh per year —historically only tried to comply with the Energy Policy Act of 2005, which required 7.5% of that come from renewables, said White House Council on Environmental Quality Director of Clean Energy Tanuj Deora.

But President Biden has upped that with a goal of getting the federal government to 100% carbon-free electricity by 2030.

“We know it’s very ambitious, right?” Deora said. “So, we are looking actively to figure out how we get there because not only is it ambitious, but it is absolutely necessary. I think we all know that we’re living the consequences of climate change, and the impact on the environment here real time, and so there’s no time to waste.”

Today the grid is already at 40% carbon-free power so the federal government procurements will take that into account.

Deora said the government would not seek to supply its facilities exclusively with the output from existing zero-emissions facilities. Instead, the procurements will focus on new resources. And the government is hedging its bets because it is still unclear exactly which technologies will prove economical and scalable among advanced nuclear, virtual power plants, carbon capture and storage, clean hydrogen and others.

The federal government is not alone in trying to procure more green power. Voluntary commitments from corporate buyers helped to build about 40% of new clean energy resources in recent years, Deora said.

Google (NASDAQ:GOOGL) has aggressive clean energy goals and a total load of 18 TWh annually that is growing because of computing power demands from new technologies like artificial intelligence, the firm’s Brian George said. Google says it has met its entire demand with renewable energy since 2017.

“Even as we do that, there are periods during the day where we still rely on fossil energy to serve our data center demand,” George said. “In 2021, around the world … our data centers consumed about 66% of carbon-free energy on an hourly basis.”

Like the federal government, Google wants to increase that to 100% by 2030, which will require it getting new resources built where they can directly serve its data centers. Focusing on 100% carbon-free electricity can help send the signals that are needed to build out the new technologies required to reach an emissions-free grid, he added.

EBA CFE Panel 2023-05-12 (RTO Insider LLC) Content.jpgFrom left: Neil Fisher, NorthBridge Group; Tanuj Deora, White House Council on Environmental Quality; Brian George, Google; W. Mason Emnett, Constellation Energy; and Lon Huber, Duke Energy. | © RTO Insider LLC

“Our systems are not set up to recognize and reward customers for what they are already doing just from paying their electric bills, much less … be tailored to the actions that the Googles of the world want to be taking to be driving change,” said Constellation Energy (NASDAQ:CEG) Senior Vice President of Public Policy Mason Emnett. “And so, we’re spending a lot of time working with our customers in terms of the product development, the commercialization of these types of products.”

While wind and solar are the cheapest options now, over time the more they get built the less the power produced matches up with demand every hour. Emnett said once they hit about 50% of demand that split starts to grow. Once you get to 100% annual match with renewables, the grid is still relying on balancing resources for about 25% of its total needs, he added.

Interregional Transmission

Another EBA panel focused on getting more interregional transmission lines built.

The experiences of Texas and its neighboring grids in SPP and MISO during the 2021 winter storm are one of the main reasons former FERC Chair Richard Glick wants to see interregional transmission built. ERCOT lacked major connections with the outside, and it was short on power for days, leading to hundreds of deaths, while  the nearby sections of the Eastern Interconnection were able to import power from farther afield and avoided the worst.

“There is a lot of consensus out there that much more is needed in terms of connections between these regions,” Glick said.

Many in Texas might still be skeptical about linking up with the rest of the grid. But in other regions, even state regulators have indicated that they support addressing the barriers to interregional transmission.

“We do know, with regard to interregional transmission in particular, that there are multiple benefits,” Glick said. “And part of the problem — some are very easy to quantify, like probably production cost reductions — …  but some of the benefits, whether it be resilience, whether it be achieving public policy goals … are more difficult to quantify.”

Figuring out a way to quantify those benefits is going to be necessary to make progress and deal with the very tricky issue of cost allocation, he added.

“Whenever we talk about transmission, it always does come down to cost allocation,” Glick said. “There’s a lot of other issues. There’s always barriers, but cost allocation is the big one.”

While interregional transmission can produce benefits, the conversation around expanding it has not been very refined, said Edison Electric Institute Managing Director Kevin Huyler.

“When I look at some of the proposals that are out there for driving interregional transmission investment, I don’t see a lot of nuance, which sometimes isn’t surprising, particularly if it’s a legislative proposal,” Huyler said.

Some have suggested that regions should be able to get a 30% minimum transfer requirement, but Huyler said nobody really knows what the right number is, and getting accurate figures is vital to proper transmission planning.

“It can’t be entirely precise,” he added. “But I think there has to be an effort made … to have customers and stakeholders [understand] why that much is being built.”

Invenergy is pursuing merchant interregional projects around the country, along with the development of new renewable resources and that makes it come at the issue with a sense of urgency, said its Executive Vice President of Public Affairs Kelly Speakes-Backman.

“I don’t want to turn this into a whole climate discussion, but it’s real and it’s here, and we’ve got not a lot of time to fix this,” Speakes-Backman said. “Frankly, the planning and the work that goes into it takes a really long time. And this is part of why we’re in the transmission business itself — to help with the urgency.”

Invenergy can make it easier to get transmission by investing its capital to get new lines constructed. But it does need to get paid for the benefits of such investments to make it work economically, she added.

West Coast States Should Collaborate on OSW, Panelists Say

 

SACRAMENTO, Calif. — West Coast states need to work together on transmission, ports and industrial infrastructure to achieve their goals for floating offshore wind, speakers at this year’s Pacific Offshore Wind Summit said.

The two-day event, hosted by Offshore Wind California, drew 700 attendees to the SAFE Credit Union Convention Center in downtown Sacramento on May 9-10.

Panelists encouraging collaboration cited lessons learned, both positive and negative, from the East Coast’s experience developing offshore wind projects and infrastructure.

Travis Douville 2023-05-13 (RTO Insider LLC) FI.jpgTravis Douville, Pacific Northwest National Laboratory | © RTO Insider LLC

“What we have learned is that there’s great power in bringing the states together,” said Travis Douville, who leads wind energy grid integration research at the Pacific Northwest National Laboratory.

“There already are models of substance in play,” Douville said during a panel on offshore wind transmission. For example, the New England States Transmission Initiative “is showing real promise, and the idea here is that states can come together and develop a shared transmission plan that serves all of their needs at the state level.”

Last year, five New England states — Connecticut, Massachusetts, Maine, New Hampshire and Rhode Island — announced their joint initiative to explore investment in the transmission infrastructure they need to integrate offshore wind and other clean energy resources while improving grid reliability.

In January, the states said in a joint statement that they were seeking funding from the Department of Energy to strengthen New England’s grid and reduce dependence on fossil fuels. (See New England States Group Up To Push For Federal Transmission Funding.)

One of their proposals, the Joint State Innovation Partnership for Offshore Wind, would “proactively plan, identify and select a portfolio of transmission projects needed to unlock the region’s significant offshore wind potential, improve grid reliability and resiliency, and invest in job growth and quality.”

California, Oregon and Washington could benefit from similar arrangements, Douville said.

‘Pacific Coast Scale’

The West Coast states have nearly 300 GW of potential capacity from floating offshore wind turbines, the National Renewable Energy Laboratory estimated in a study last year. California has 88 GW of potential capacity. Oregon has 150 GW, and Washington has 59, NREL said.

The states, federal government and private industry are planning to develop that capacity, starting south and working north.

The Bureau of Ocean Energy Management (BOEM) held the first West Coast wind auction Dec. 7, when five lease areas off the California coast, with 4.5 GW of total capacity, brought more than $757 million in winning bids. (See First West Coast Offshore Wind Auction Fetches $757M.)

Three of the lease areas are in the Morro Bay Wind Energy Area off the coast of Central California, and two are in the Humboldt Wind Energy Area off the coast of Northern California.

The auction was crucial to achieving the Biden administration’s goal of deploying 15 GW of floating offshore wind in deep waters by 2035, the Interior Department said. The California Energy Commission has proposed offshore wind goals of 25 GW by 2045. (See California Boosts Offshore Wind Goals.)

Off the coast of Oregon, BOEM has identified three call areas with 17 GW of capacity, one of which, the Brookings Call Area, is 60 miles north of California’s Humboldt Wind Energy Area. The proximity quickly prompted discussion of collaboration between the West Coast states.

“The growing Pacific Coast scale of this … sets in motion a whole set of speculation about coordination across the region,” Adam Stern, executive director of Offshore Wind California, told an Energy Bar Association meeting shortly after BOEM announced the Oregon call areas Feb. 24, 2022. (See Energy Bar Weighs OSW in Oregon, California.)

In Washington, BOEM has received two unsolicited bids for floating wind farms but has yet to identify any call areas.

‘Economies of Scale’

Ryan Calkins 2023-05-13 (RTO Insider LLC) FI.jpgRyan Calkins, Port of Seattle | © RTO Insider LLC

Washington has moved more slowly on offshore wind, in part because of its vast supply of hydroelectric power, said Ryan Calkins, a Port of Seattle commissioner and part of a panel on West Coast collaboration.

“We have such an abundant source of renewable energy in hydro that I think we didn’t get off the starting blocks very quickly,” Calkins said. “However, I think we’re starting to see some real progress.”

The state has an energy strategy that includes 3 GW of offshore wind by 2045, and “oftentimes you’ll hear our state officials talk about ‘it’s not if, but when’ we will get into offshore wind,” he said.

The state is expecting to learn from California’s experience with offshore wind, including its effects on fisheries, coastal communities and Native American tribes, he said.

“When we join California in a few years with our own plans for offshore wind, I welcome the inputs of California ports and supply chains to help us meet our targets,” Calkins said. “I think it just makes sense for us to have a systemwide approach to this.”

Some types of collaboration between the states are already happening and could serve as models for offshore wind, he said. For instance, West Coast ports employ standardized container shipping equipment that allows ships to offload in multiple ports, from Seattle to Long Beach, after crossing the Pacific from Asia. The setup promotes efficiencies of scale, he said.

“We also have a shared workforce, whether it’s the unions that tie us all together or the brain trust behind what we do, and the various contractors that every port relies on for port design or for engineering services,” Calkins said. “Those same sets of skills are going to be needed for the extension of ports along the West Coast.”

On an international scale, “I think that if we manage to pull off strong collaboration on a coastwide level here, we actually have an opportunity to chase a much bigger prize, which is a larger Pacific Rim system developing offshore wind that includes Korea, Japan, China and elsewhere,” he said.

“But if Washington tries to do it alone, or even if California tries to do it alone, we’re not going to have the kind of efficiencies or economies of scale to be able to participate in bilateral trade with some of those nations, which have even bigger goals than we do in a lot of instances,” he said. “So, I think we’d benefit if we collaborate.”

Competition vs. Collaboration

The East Coast has seen a combination of competition and collaboration that has fostered growth but has also led to inefficient development, panelists said.

Molly Croll, Pacific offshore wind director for the American Clean Power Association, said, “Competition as well as collaboration stimulates progress.”

“Competition has been a big part of progress on the East Coast,” Croll said. “There’s been competition for who can set the highest offshore wind target, who can procure the best projects first … and [who can offer the best] local incentives for supply chain and manufacturing. So, competition is a motivator, but obviously competition without collaboration will lead to inefficiencies, gaps and redundancies, which we don’t want.”

Croll, a California resident, said her home state should take the lead.

“I do not want California to wait for other states to get to where California is,” she said. “But I think there’s still so many areas for potential collaboration, [such as] best-practice sharing and information sharing. That’s a no-brainer. We should be doing that. California is doing a lot of things for the first time that Oregon and Washington will benefit from.”

“Then, moving up towards shared planning, I would love to see that, especially if we can coalesce states around a shared vision of large-scale offshore wind,” Croll said. “Harder to do [are] mutual commitments, shared investments, things like that, but we could get there. And hopefully, working on those first steps provides a platform and habit of collaboration.”

Tony Appleton 2023-05-13 (RTO Insider LLC) FI.jpgTony Appleton, Burns & McDonnell | © RTO Insider LLC

In a panel on building a sustainable West Coast wind industry, Tony Appleton, offshore wind director for engineering firm Burns & McDonnell, said the West Coast could learn from the East Coast’s mistakes.

“The lesson learned from the East Coast is that not everybody actually worked together,” Appleton said. “Everybody was kind of doing their own thing in their own little silos and actually not realizing what the bigger picture was.”

Developers focused on their own projects, and states competed for ports, jobs and supply chain opportunities, he said.

“I think what, what the West Coast could do — what California, Oregon, etc. can do — is actually work together, get all of those key stakeholders working together, rather than … against each other. Because if you get them working together, they will come up with solutions that everybody’s happy with.”

Europe spent 20 years learning to work together on offshore wind, Appleton said.

If California takes a collaborative approach from the start, “It goes straight from iPhone 8 to iPhone 15 and not through all the steps in the middle.”

PJM Members Committee Approves Performance Penalty Reduction

VALLEY FORGE, Pa. — The PJM Members Committee on Thursday approved a proposal that would sharply reduce the penalties generators pay for underperforming during emergency conditions.

The proposed tariff revisions would effectively lower the current penalty rate ($3,177/MWh) and annual stop loss ($142,952/MW-year) by changing the figures from being based on the net cost of new entry (CONE) to Base Residual Auction (BRA) clearing prices for the locational deliverability area (LDA) that the resource is located within. The shift would result in a penalty rate of $394/MWh and a stop loss of $17,744/MW-year. (See PJM MRC Endorses Proposal to Reduce Performance Penalties.)

The conditions under which PJM could declare a performance assessment interval (PAI) would also be tightened, limiting when generators can be subject to performance charges.

PJM General Counsel Chris O’Hara said the tariff revisions should be filed by the end of the month to ensure that they can be implemented for the upcoming delivery year. The changes would be in effect through the 2024/25 DY, with proponents describing it as a temporary measure to realign penalty risks while stakeholders consider a capacity market overhaul through the Critical Issue Fast Path (CIFP) process. (See PJM Stakeholders Refine CIFP Capacity Market Proposals.)

The Markets and Reliability Committee endorsed the proposal, brought by American Municipal Power (AMP), a week earlier. Director of PJM Regulatory Affairs Lynn Horning said the RTO’s Capacity Performance (CP) structure has been a proven failure and the proposed tariff changes would align penalties with the revenues received by generators.

“We do need to get to a market design with appropriate penalties,” she said.

An alternative measure only including the PAI trigger provisions was presented by Constellation Energy, but it would only have been considered by the committee if the main motion had failed. Vice President of Market Development Bill Berg said the alternative was a compromise to reduce litigation and would have preserved a strong incentive for generation owners to ensure their facilities would be able to operate during emergencies.

“We think it’s better aligned with assuring reliability,” he said. “It ensures a fundamental CP market-based approach to incentivize strong performance.”

Berg said changing the penalty structure would have impacts on reliability and predicted that the company would protest any eventual FERC filing.

According to the voting report, the strongest support for the main motion came from the Electric Distributor sector, which gave unanimous support in the sector-weighted voting. The Other Supplier and Generation Owner sectors also gave significant support, while End-Use Customers were nearly split at 59% supporting — breaking down to industrial customers supporting and consumer advocates opposing. Transmission Owners were 67% opposed.

PJM’s Adam Keech said the RTO supported changing the PAI triggers, as staff participated in the drafting of the trigger language, but he expressed concerns that reducing penalties without creating mandates to ensure generator performance would undermine the logic of CP: to receive performance through incentives rather than hard requirements.

Heather Svenson, RTO strategy manager for Public Service Enterprise Group, said the proposal would use clearing prices in LDAs to determine penalties for generators in those regions but distribute the bonuses across the RTO. That arrangement could create significant imbalances between the penalty risk and bonuses a generator could receive, she said.

“There’s going to be an inherent mismatch between bonus and penalties,” she said.

PJM’s Stu Bresler said a similar arrangement exists today with the difference between CONE areas, but those regions have closer values than the current spread between LDAs and the Rest-of-RTO region.

Gregory Poulos, executive director of the Consumer Advocates of the PJM States (CAPS), said some advocates were opposing the changes based on a belief that they would prioritize the preservation of existing generators, even if they are not meeting their capacity obligations.

Denise Foster Cronin of the East Kentucky Power Cooperative supported the proposal, saying it would align the penalties with the revenues received by generators.

Alex Stern of Exelon said changing penalties for a delivery year after auctions have already been run could raise retroactive ratemaking concerns at FERC.

The Natural Resources Defense Council released a statement following the MC vote saying the proposal constitutes a bailout of underperforming generators at the expense of those that made investments to back up their capacity offers.

“The public has paid tens of billions of dollars to power plant owners for the promise of reliable service,” said Senior Advocate Tom Rutigliano. “Last winter, we found out that many of them, mostly natural gas owners, failed to prepare to deliver the power they were getting paid for. Today, those same owners have voted to let themselves off the hook if they fail again in the coming winter.”

NJ EV Charger Plan Advances as Enviros Demand ACC II Adoption

The New Jersey Turnpike Authority has signed a deal to put 260 chargers on the state’s two main arteries — the turnpike and the Garden State Parkway — by 2038, even as environmental groups urged the state to move faster to adopt rules that would put more electric vehicles on state roads.

The authority’s agreement with Ireland-based Applegreen NJ Welcome Centres, which operates service area restaurants on the highways, requires the company to design, permit, install, own and operate 80 EV charging ports for passenger vehicles on the highways by the end of 2025.

Applegreen must install an additional 160 charging ports by April 2033, or whenever the number of EVs in New Jersey equals 10% of all vehicles in the state. The deal, which the authority board approved on April 25, also requires Applegreen to construct and operate 20 EV charging ports for medium-duty vehicles by the end of 2038.

The authority’s vote preceded a May 3 report by the Sierra Club and Natural Resources Defense Council (NRDC) highlighting what the groups say are the climate, health and job benefits of New Jersey adopting California’s Advanced Clean Cars II (ACC II) regulations. The rules would require 43% of new vehicles sold in the state to be zero-emission by 2027 and 100% by 2035.

“We urge New Jersey to move forward quickly with the Advanced Clean Cars II Program in order to promote public health and address the climate crisis, while also positioning ourselves as a market leader in clean transportation across the nation,” Anjuli Ramos-Busot, director of the New Jersey Sierra Club, said in a release outlining the report.

‘Omnipresent’ Charging Stations

The highway charger installation plan is the latest part of New Jersey’s aggressive effort to put more EVs on the road. The state had 93,000 EVs at the end of 2022, according to the Board of Public Utilities, well below the state’s target of 330,000 registered light-duty EVs by 2025.

New Jersey officials, like those in other states, believe that getting more chargers on the roads is key to motivating more EV purchases by reducing range anxiety — the worry that the distance limitations of an EV will cause a battery-powered vehicle to run out of charge in a location where there are no chargers.

“Electric vehicle charging stations need to become as omnipresent as gas stations in order to build the consumer confidence that’s necessary to make the transition that is undoubtedly required,” Commissioner Shawn LaTourette, head of the New Jersey Department of Environmental Protection (DEP), told a state Senate Budget Committee hearing on May 2.

He said the state now has 2,600 charging stations, up from 800 in 2020. The DEP, through a charger installation incentive program called It Pays To Plug In, has already awarded $16 million in subsidies for 1,700 chargers, with applications for another $8 million waiting because the funding has been exhausted.

The turnpike authority’s deal with Applegreen, which does not involve the DEP, sets out a $166 million program for charger installation, of which the authority will pay $25.7 million, contributing $1.28 million per service area. (See Rest Stop Operator Seeks Piece of $166M NJ EV Charger Push).

Service areas on the New Jersey Turnpike and Garden State Parkway currently host 76 chargers — 70 on the turnpike and six on the parkway. Most of the chargers are for Tesla vehicles.

Applegreen will be responsible for all buildout and operating costs, and the authority will receive 5% of the revenue from each charging space, or $1,250 — whichever is greater. The authority also will get 0.5% of any subsidy of $2 million, or $10,000.

The authority, in its approval order, said Applegreen’s existing on-site presence as a rest-stop restaurant operator means it is well placed to “quickly roll out and efficiently manage EV Charging Services at the Service Areas to the benefit of Authority patrons and overall Service Area operations.”

Market Trends

The state’s effort to ramp up charging stations is just one element of a passel of initiatives to promote EV adoption. They include several EV purchase incentives, as well as the adoption of ACC II, the plan that Gov. Phil Murphy announced in February. Environmental groups have since urged the state to move as quickly as possible in order to get them enacted by the end of the year. (See Enviros Demand NJ Move Faster on 100% EV Rule.)

If that happens, the rules would first apply to the 2027 vehicle manufacturing year, rather than postponing the impact until the following year if the state misses the year-end deadline. (See Enviros Demand NJ Move Faster on 100% EV Rule.)

Speaking at an Assembly Budget hearing on April 24, LaTourette said his agency is still evaluating the California rules and has not yet proposed New Jersey’s rules for adoption. Under federal law, the state can adopt California’s version of the rules and does not have much leeway to change them.  (See NJ Governor Sets Out Accelerated Emissions Targets.)

“I’m not sure that we can also get it adopted this year, given the time that it takes to get a rule from proposal to adoption,” LaTourette told the hearing, adding that “we would do all we could in order to make to make that happen [so] that we don’t lose out on a model year of benefit of improving air quality.”

There is no doubt the rules are needed, he said.

“This is the way the market is going; this is where the market is,” he said. “So having supportive regulatory reform coupled with incentives and market action, that’s the type of trifecta you want to see in order to make real progress on what is our greatest source of climate pollution in this country.”

He also told the hearing the state would have to “double down on our investment in electric vehicle charging capacity.”

Cost-Benefit Analysis

The Sierra Club-NRDC report, which was prepared by global consultant ERM, seeks to highlight the impact of ACC II by conducting a numerical analysis of the benefits of adopting the rules for light-duty vehicles.

The report looks at three scenarios of ACC II adoption and assesses the costs and benefits of their impact on the market and pollution in the state.

One scenario looks at the impact if car manufacturers used “compliance flexibilities” in the rules to meet their requirements, and so selling fewer EVs than predicted.

The second scenario assesses the impact given the same manufacturer response but if the state reached 100% clean electricity generation by 2035, earlier than expected.

The final scenario assesses the situation if manufacturers didn’t use the “compliance flexibilities” and reached the projected EV sales figures and the state achieved 100% clean energy generation by 2035.

The report also compared the outcomes of the three scenarios to the scenario of “business as usual,” with no implementation of ACC II.

The report found that all three ACC II scenarios would bring “significant cumulative net societal benefits,” ranging from $84 billion in benefits from 2027 to 2050 in the first scenario to $97 billion under the third scenario.

The benefits included between 175 and 358 fewer premature deaths from breathing polluted air and 170 to 362 fewer hospital visits from the same reason.

The report estimated that under the first two scenarios, 16% of light-duty vehicles in the state would be EVs by 2030, rising to 68% by 2040 and 94% by 2050.

In the third scenario, 19% of vehicles would be EVs by 2030, 70% by 2040 and 94% by 2050.

“The report findings make clear that adopting Advanced Clean Car II rules would bring immense benefits — including improved public health and vehicle owner savings — and put the state on a pathway that centers climate action around clean air, health and affordability for all New Jerseyans,” Kathy Harris, clean vehicles and fuels advocate at NRDC, said in the release outlining the report.

NYISO Recommends NYPA-Transco Proposal for Long Island Tx Need

NYISO staff last week selected a proposal by Propel NY Energy to meet the ISO’s Long Island Public Policy Transmission Needs (PPTN) solicitation for transmission lines to export offshore wind energy and unbottle constraints across the island.

Propel, a partnership between the New York Power Authority and NY Transco, proposed three new 345-kV lines on the island. In a draft report released May 8, staff said the proposal would add “a strong 345-kV backbone to the Long Island transmission system that not only allows the delivery of offshore wind power but also will effectuate the efficient transfer of power in the future, providing optionality for resource planning and expansion needed to achieve” the state’s climate goals.

NYISO rankings for Tx projects from PPTN (NYISO) Content.jpgNYISO rankings for top-tier transmission projects from PPTN | NYISO

The goal of the PPTN was to add at least one bulk transmission intertie cable to increase Long Island’s offshore export capability by at least 3,000 MW and upgrade associated local transmission facilities to accompany the growing scale of wind power development off the Long Island coast, according to the report (20-E-0497).

Propel, along with the Long Island Power Authority and Consolidated Edison, would build two lines between Shore Road and Sprain Brook and one between East Garden City and Tremont for $3.26 billion. Propel, however, proposed a soft cost cap of $2.9 billion with a commitment to not recover 20% of included capital costs above the cap from ratepayers, which was one of the major evaluation criteria the ISO considered.

Staff also found that the proposal has a potential economic benefit of up to $3.6 billion over 20 years and, although not required by the PPTN, would relieve the 138-kV Barrett-Valley Stream congestion constraint.

NYISO presented the report to the Transmission Planning Advisory Subcommittee on Thursday.

Mark Younger, president of Hudson Economics, contended that the ISO’s “presented results are not detailed enough” and what stakeholders have seen “has been very high level.” He argued that because NYISO did not conduct a transmission security analysis examining the potential impact on the capacity of neighboring zone interfaces, the ISO’s stated benefits may be overstated.

“It’s like [NYISO] is the old economist, where [you’re] on a desert island and have a can of food but are assuming there is also a can opener,” he said. “It would be kind of embarrassing if after the line goes in that the ISO discovers that you have too much capacity in Zones H through K.”

Cost cap for PPTN Tx projects (NYISO) Content.jpgIndependent estimate and voluntary cost cap for PPTN transmission projects | NYISO

 

NYISO staff acknowledged that although they did not perform that specific analysis, “overall New York state will benefit from this public policy transmission need, and this is our recommendation to our board.”

Doreen Saia, an attorney with Greenberg Traurig, sought clarification on a potential appeals process, which NYISO confirmed was possible but added that the board is not looking to receive any more presentations.

The ISO will present its recommendation to both the Business Issues and Management committees on May 24 and 31, respectively, seeking stakeholder advisory votes before advancing to the Board of Directors for final approval. The board will consider any submitted written comments or requests sent to PublicPolicyPlanningMailbox@nyiso.com.