November 13, 2024

MISO in Agreement with IMM’s State of the Market Recommendations, Work Begins on 1

CARMEL, Ind. — MISO this year said it generally agrees with the six new market recommendations brought forward in its Independent Market Monitor’s annual State of the Market report and is working on one of them.  

Independent Market Monitor David Patton has debuted six market recommendations. (See MISO Monitor Spotlights Congestion Fixes, Market Mismatches in 2023.) He said MISO should: 

    • Develop a means to decommit resources that were committed in the day-ahead market. 
    • Create procedures outlining when it’s appropriate for its operators to derate transmission constraints to manage congestion. 
    • Require generation owners to fill out the reasons behind outages or outage extensions in the ticketing system the RTO uses to track scheduling.  
    • Use demand curves at the zonal level to better model demand in its local resource zones and produce more accurate local clearing requirements in capacity auctions.  
    • Align its definition of aggregate pricing nodes between its financial transmission rights (FTR) market and real-time and day-ahead markets. 
    • Enforce requirements for MISO’s 30-minute reserve product so it’s used instead of out-of-market actions to solve shortages.  

Of all this year’s new recommendations, MISO said it agrees most strongly with the suggested better guidance on when operators should derate transmission to manage congestion.  

“MISO is actively working on improvements to operators’ tools and procedures related to constraint management, including for out-of-market actions. Procedures will be revised as needed to offer further guidance to operators while maintaining operational flexibility,” MISO Director of Market Design and Development Zhaoxia Xie said at a Nov. 7 Market Subcommittee meeting.  

However, MISO said it would defer any action on creating individual downward-sloping demand curves for the 10 local resource zones in its capacity auction.  

MISO said though there might be value in fashioning separate sloped zonal demand curves, it’s going to do more evaluation on the IMM’s proposed solution.  

On the other hand, Xie said MISO is working in concert to synchronize the definitions of the aggregate pricing nodes and “minimize the gap” between the modeling for its FTR market and real-time and day-ahead markets. 

MISO similarly plans to collaborate with the IMM on possibly developing a means to recommend the decommitment of resources committed in the day-ahead market. However, Xie added that MISO members currently enjoy the financial and operational assurances they get in the day-ahead market while benefiting from being able to adjust offers in the real-time market to meet “their economic and operational needs.” 

As for gathering more detailed descriptions of the reasons behind generation outages, Xie said MISO recently dropped the ‘other’ option from its dropdown menu in its outage reporting software for members. She said MISO will do more to collect explanations for outages.  

“MISO plans to evaluate changes to the outage submission rules that ensure needed information is provided when tickets are submitted or updated,” Xie said.  

Finally, MISO said it plans to investigate how it can enforce short-term reserve requirements in load pockets. Xie said MISO shares the IMM’s concerns about operators increasingly using out-of-market commitments to “satisfy voltage and local reliability requirements in key load pockets.” 

PJM OC Briefs: Nov 8, 2024

Stakeholders Endorse Quick Fix Solution on Day Ahead Scheduling Reserve Calculation

The Operating Committee endorsed a quick fix proposal to revise Manual 13: Emergency Operations to add transparency to the Day Ahead Scheduling Reserve (DASR), a figure that is calculated annually to determine when the 30-minute reserve requirement may be insufficient and emergency procedures necessary. 

The quick fix process allows for an issue charge to be voted on concurrent with a proposed solution. (See “Quick Fix Proposal on Day Ahead Schedule Reserve Calculation,” PJM OC Briefs: Oct. 10, 2024.) 

The 30-minute reserve requirement is set at the greater of the primary reserve requirement, active gas contingency or a flat 3,000 MW, which PJM has argued is not flexible and does not account for operational risks. An earlier proposal to shift to a requirement based on load forecast error and forced outage rates was rejected by stakeholders in July. (See “Stakeholders Endorse Reserve Rework, Reject Procurement Flexibility,” PJM MRC Briefs: July 24, 2024.) 

The DASR is the sum of the three-year average underforecast load forecast error (LFE) and generator forced outage rates (FOR), which currently results in a 74,257-MW peak load threshold after which 30-minute reserves are considered inadequate.  

The manual revisions are intended to clarify how operators use DASR. No change is proposed to the functioning of 30-minute reserves. They are set to go for a first read at the Markets and Reliability Committee (MRC) on Nov. 21, followed by a vote Dec. 18. 

PJM Presents Revisions to Manual 1 Addressing Hybrid Resource Rules, Loss of EMS Real Time Assessment

PJM presented a quick fix proposal to revise Manual 1: Control Center and Data Exchange Requirements to clarify its communication processes and data collection protections. The language is scheduled to be voted on at the Dec. 5 OC meeting and, if endorsed, at the Jan. 23 MRC meeting. 

The changes would add more detail to its backup communication methods to be used in the event of widespread SCADA software outages, as well as alternatives ways of conveying data to PJM during a SCADA outage, such as a cyberattack. The package also includes clarifications around PJM’s view-only mode to protect Inter-Control Center Communications Protocol (ICCP) data from potential errors during planned maintenance. 

The RTO also first read a set of revisions to Manual 1 identified through its periodic review, which would update several definitions to be more precise and consistent with other manuals. The language also includes requiring that the state of charge be conveyed by SCADA for open-loop hybrid resources, a requirement that already stands for close-loop hybrids.  

PJM Seeks Advance Notice of Expected Maintenance Outage as RTEP Upgrades are Scheduled

PJM is requesting that generation and transmission owners increase coordination around planned outages while a significant number of transmission assets are taken offline to build upgrades under the RTO’s 2023 Regional Transmission Expansion Plan Window 3. The work ramps up in 2026 and continues through 2030, with the number of outages exceeding 30 in some months. 

Transmission owners are asked to review planned outages for conflicts with the scheduled upgrades, provide PJM with a preferred timeline for their outages and fill out the RTO’s Prioritization Scoring Matrix. Quarterly meetings are being held with transmission owners and developers within the six zones affected by the RTEP projects to bolster the coordination efforts. 

On the generation side, any units in the BGE, PEPCO, Dominion and surrounding regions with outages expected over the next two to three years are asked to provide advanced notice as early as those outages can be foreseen. PJM’s Joe Rushing noted that generation outages require only a 30-day notice. The extent of the transmission work that will be conducted will limit the number of generators that can be taken offline at a given time.  

Congestion and increased use of emergency procedures, such as post contingency local load relief warnings (PCLLRWs), are likely throughout the duration of the RTEP work. 

October Operating Metrics

Presenting the October operating metrics, PJM’s Marcus Smith said October saw both hourly and peak load forecast error fall below the 25-month averages, with an hourly rate of 1.32% and peak forecasts off by 1.46% across the month. Underforecasts exceeding PJM’s 3% error rate benchmark were seen Oct. 3 and 6, while overforecasting was seen Oct. 22 and 31. 

The month saw one spin event Oct. 22 that lasted 6 minutes and 11 seconds and a generation response rate of 95% and demand response (DR) deployment at 151% of dispatch. One shared reserve event, two high system voltage actions and 16 PCLLRWs were implemented in October as well.  

Security Briefing

PJM Director of Enterprise Information Security Jim Gluck said the FBI is warning that renewable generation increasingly is being targeted by attacks to steal technology, render systems inoperable for ransom and disrupt generation operations. 

The Infrastructure Information Sharing and Analysis Center (ISAC) has published a research paper detailing several threats to infrastructure in the leadup to the November 2024 elections, including “hacktivist” attacks and state-sponsored actors. As a precaution, PJM implemented a conservative operations procedure the night of Nov. 5 through midnight the following day. 

“While PJM has received no indication of credible threats to the power grid at this time, our government partners have encouraged the industry to remain alert to an elevated risk environment. Out of an abundance of caution, … PJM … will establish a more conservative posture,” the alert stated. 

The RTO also is monitoring the possible impact of a breach at Schneider Electric, where about 40 GB of records were compromised and could be released to the public if a ransom is not paid. 

Gluck recommended that members ensure employees use multifactor authentication and default passwords are not used. 

PJM Presents 2024 Winter Study

PJM’s Mark Dettrey presented the 2024/25 Winter Study prepared by the Operations Assessment Task Force (OATF) to evaluate the risk landscape for the season. While some switching, phase angle regulator (PAR) adjustments and re-dispatch may be required to address transmission violations, no reliability issues were identified under the 50/50 or 90/10 load forecast studies. (See PJM OC Briefs: Oct. 10, 2024.) 

The report expects 177.6 GW of cleared capacity and fixed resource requirement (FRR) resources will be available, as well as 2.2 GW of resources that historically have been available under the study conditions. It assumes 5.5 GW will be exported under the scenario analyses, 18 GW of generator outages and 7.1 GW of load management being deployed. 

The RTO is projected to maintain an 8.7-GW reserve margin under the low wind and no solar scenario, which reduces available generation by 3.1 GW. That margin shrinks to 7.1 GW under the largest gas/electric contingency, which would take 4.7 GW of generation offline. 

The report also included a scenario developed on experiences during December 2022 Winter Storm Elliott, increasing forced outages to 46 GW, which would lead to a reserve margin deficiency of 13.8 GW. The scenario is not included in the reliability analysis but was developed as a numbers game to be informative. 

Other Committee Business:

PJM’s Pete Langbein presented the 2023/24 Load Management Event Summary, which showed that emergency and pre-emergency DR performance was “very good, well north of 100%” across the delivery year. While there were no events requiring load management deployment, testing showed a 122% response rate reflecting 1,614 MW in overcompliance. 

Stakeholders endorsed revisions to Manuals 3 and 10 drafted through the documents’ periodic review. The changes to Manual 3: Transmission Operations include language to reflect existing practices on facility ratings, shifting which section details Automatic Remediation Action Scheme (RAS) operating criteria, and updating several notes and links. 

The Manual 10 language clarifies how the quantity of energy offline during an outage should be reported for inverter-based resources in eDART and more explicitly states that forced outages must be completed before work can begin on a planned outage. 

Newsom Convening Legislature to Protect California ‘Values,’ Policies

California Gov. Gavin Newsom is convening a special session of the state legislature to take steps “to safeguard California values” — including the fight against climate change — ahead of President-elect Donald Trump’s second term. 

In a proclamation issued Nov. 7, Newsom (D) said he wants lawmakers to consider additional funding for the state Department of Justice and other agencies so they can quickly challenge actions taken by the Trump administration. The special session will begin Dec. 2. 

“The consequences of his presidency for California may be significant and immediate,” Newsom said in the proclamation. 

Those consequences include potential actions such as dismantling clean vehicle policies “that are critical to combating climate change,” the proclamation states.  

Another concern is that Trump will block federal disaster response funding to California as political retribution. During his campaign, the former president threatened to withhold wildfire aid to the state if Newsom didn’t back his policies. 

Newsom also wants to fend off potential Trump administration attacks on reproductive freedoms and immigrant families in California. 

Past Experience

During Trump’s first term as president, California filed more than 120 lawsuits challenging actions taken by his administration. Newsom said he’s been working with the attorney general’s office for over a year to prepare for the possibility of a second Trump term. 

The additional funding Newsom seeks would help ensure the state can file litigation immediately and seek injunctive relief against federal actions. 

“We’re working closely with the governor and the legislature to shore up our defenses and ensure we have the resources we need to take on each fight as it comes,” California Attorney General Rob Bonta (D) said in a statement. 

The fight against climate change has strong support in the state. Voters on Nov. 5 passed Proposition 4, a $10 billion climate bond measure to fund wildfire programs, clean energy and other projects. (See Calif. Lawmakers Send $10B Climate Bond Measure to Nov. Ballot.) 

“This result demonstrates voters want California to be at the forefront of climate action because our health, lives and livelihoods are at risk,” Katelyn Roedner Sutter, the Environmental Defense Fund’s California state director, said in a Nov. 6 statement.  

Waiver Battle

California’s zero-emission vehicle regulations are a key concern for the state under the new Trump administration. In 2022, the state adopted rules banning the sale of new gas-powered cars in 2035; the sale of new diesel trucks will be prohibited starting in 2036. 

California may set its own zero-emission vehicle and tailpipe emission standards instead of implementing federal standards under a provision of the federal Clean Air Act. The state must submit its emission rules to EPA and receive an EPA “waiver of federal preemption” before a rule may be enforced. 

Other states have an option to adopt California emission regulations rather than follow federal standards. 

California’s right to set its own standards was revoked in 2019 during Trump’s first term, and then reinstated in 2022 under the Biden administration. The reinstatement was challenged by Ohio and 16 other states along with oil and gas interests. A federal appeals court rejected the challenge in April 2024. 

In 2020, while California’s emissions waiver was suspended, six automakers entered into voluntary agreements with the California Air Resources Board (CARB) to reduce greenhouse gas emissions of their vehicles each year through 2026 and speed the transition to zero-emission vehicles. 

Stellantis entered into a similar agreement with CARB in March 2024. 

CARB also made a deal with truck manufacturers in July 2023 called the Clean Truck Partnership. In exchange for CARB giving manufacturers more flexibility to comply with its regulations, the truck makers pledged to meet California’s vehicle standards, including a requirement to produce and sell only ZEVs starting with model year 2036.  

The manufacturers agreed to stick with their commitment even if the regulations face legal challenges and regardless of CARB’s overall authority to implement those regulations. (See CARB, Manufacturers Partner to Support Clean Truck Rules.) 

Airline Partnership

California continues its trend of voluntary agreements with industry. On Oct. 30, CARB announced an agreement with Airlines for America, which represents almost a dozen major airlines, regarding increasing the availability of sustainable aviation fuel. 

CARB and Airlines for America will work to ensure that at least 200 million gallons of cost-competitive, sustainable aviation fuel is available to airlines in the state by 2035. 

The amount would meet about 40% of intrastate travel demand and is a more-than-10-fold increase from current levels, CARB said. 

Proposal to Refine Bid Cost Recovery for Storage Passes Unanimously

The CAISO Board of Governors and Western Energy Markets Governing Body on Nov. 7 unanimously passed a proposal to modify the calculation used to determine bid cost recovery payments for storage resources.  

The product of four months of intense stakeholder engagement, the proposal aims to address what ISO staff and stakeholders identified in 2022: that BCR provisions for storage resources don’t align with the intent of BCR. (See CAISO Proposal Seeks to Refine Storage Bid Cost Recovery.) 

The initiative, which kicked off in July, identified two main concerns: that storage assets are not exposed to real-time prices for deviating from day-ahead schedules, and that they may have an incentive to bid strategically to maximize their combined BCR and market payments. 

Resources receive BCR payments when market revenues don’t cover the resource’s bid costs, such as startup, minimum load and transition costs. BCR also incentivizes resources to follow dispatch and bid efficiently by removing risk if the dispatch doesn’t cover costs.  

But bids for storage resources are largely driven not by the cost to produce energy in a given interval, but rather by their state-of-charge limits. The ISO noted that a combination of ancillary service awards or self-provisions for regulation-down in the real-time market, coupled with relatively high energy bids, resulted in unusually high BCR payments to storage resources.  

The final proposal recommends revising the calculation of real-time BCR for storage resources by basing the bid cost on an alternative to eliminate the opportunity for strategic bidding that inflates BCR.  

For resources dispatched up, the alternative would be the minimum of the bid and the maximum of three alternatives: the real-time default energy bid, the real-time market-cleared price, or the day-ahead market-cleared price. For resources dispatched down, the alternative would be the maximum of the bid and the minimum of the three alternatives.  

‘An Incomplete Approach’

In an opinion published Nov. 1, CAISO’s Market Surveillance Committee (MSC) agreed with the proposal, but indicated it should represent only a first step. 

“We definitely agree with the ISO and the Department of Market Monitoring that there are important incentive problems that can result in both significant financial transfers that we believe are unearned in the form of excess bid cost recovery and, very importantly, market inefficiencies in terms of insulation from incentives that real-time prices are supposed to provide,” MSC Chair Ben Hobbs said in a Nov. 1 meeting. 

The first goal should be to eliminate BCR “phantom losses” that result from including resource charging bids and discharge offers in the BCR calculation.  

“We believe that this goal is likely to be partially but not completely accomplished by implementation of the ISO proposal,” Hobbs said.  

The ISO’s Department of Market Monitoring (DMM) also showed cautious support of the proposal, viewing it as an interim solution that didn’t fully address both concerns.  

According to Adam Swadley, DMM manager of market policy and analysis, the proposal targets the bid cost component of the BCR calculation by limiting bids used in the real-time BCR calculation but does not affect the revenue portion, allowing storage operators to remain insulated from real-time prices.  

“DMM does not oppose management’s proposal. However, we do view it as an incomplete approach that does not address the underlying efficiency issues of the current BCR rules applied to batteries, and therefore we strongly encourage the ISO to immediately continue working with stakeholders to develop a more complete and effective solution for the fundamental problems,” Swadley said. 

The ISO is kicking off a new storage design and modeling initiative next month to continue addressing the first concern related to real-time prices.  

CAISO, WEM Boards Approve Pathways ‘Step 1’ Tariff Amendments

CAISO’s Board of Governors and Western Energy Markets (WEM) Governing Body on Nov. 8 approved ISO tariff amendments needed to implement the West-Wide Governance Pathways Initiative’s “Step 1” proposal, which would refine four key characteristics in the governance documents and the tariff.  

The proposal seeks to elevate the power of the Governing Body by granting it “primary” authority over rule changes affecting CAISO’s Western Energy Imbalance Market (WEIM) and Extended Day-Ahead Market (EDAM), compared with the “joint” authority it currently shares with the ISO board.  

The tariff amendments will modify the markets’ dispute resolution process to include a dual filing option and augment language considering the public interest. (See CAISO, WEM Boards Approve Pathways ‘Step 1’ Plan.)  

When they approved the Step 1 proposal in August, the ISO and WEM boards directed CAISO to prepare revisions to governing documents for later approval. Implementing the changes would require amendments to three governing documents and a section of the tariff.  

Changes to the charter for EDAM and WEIM governance include:  

    • Adding refinements to the mission of the WEM Governing Body as it relates to considering the public interest and respecting state and local authority.
    • Revising the process for approving tariff amendments within the shared authority from the joint authority to the WEM Governing Body having primary authority, with approved amendments being placed initially on the consent agenda of the ISO board. 
    • Revising the dispute resolution process to add a dual filing with FERC as a possible means of resolving a sustained disagreement between the two bodies. 
    • Adding that the WEM Governing Body may initiate a review of governance if a majority of EDAM entities announce plans to leave EDAM.

Section 6 of the charter, which established the WEM Body of State Regulators, will be amended to clarify that the BOSR can provide opinions to FERC regarding any proposed tariff amendment within the scope of the Governing Body’s authority.  

Additionally, references to “joint authority” will be revised to say “primary authority” in the corporate bylaws and decisional classification guidance for the WEM Governing Body. Tariff language also will be amended to enable dual filing.  

The changes won’t occur until a trigger mechanism is enabled, which is achieved when utilities outside of CAISO’s balancing authority area representing equal to or greater than 70% of the ISO’s load have executed EDAM agreements. To avoid uncertainty about when the changes go into effect, management added a step that requires revised documents to become effective upon certification by the ISO’s CEO or COO.  

While the trigger isn’t expected to be enabled until sometime in 2025, the ISO seeks approval of the changes now to allow time for FERC to issue an order on a tariff amendment.

NAGF Takes on Cold-weather Standard’s Revision

AUSTIN, Texas — Somewhat unnoticed among the plethora of organizations and associations related to the electric utility industry sits the North American Generator Forum, an independent, member-driven organization designed to provide a “united voice” on reliability, resiliency and security to NERC. 

During NAGF’s compliance conference and its annual meeting Nov. 6-7 at the Texas Reliability Entity’s headquarters, attendees shared their lessons learned and best practices with their peers. NERC staffers also called in with the latest developments at the agency. 

The NAGF is modeled after the larger North American Transmission Forum. It relies on its more than 80 member companies, accounting for about 53% of the bulk electric system’s capacity in North America, to share information in providing that “unified voice.” 

“We look to the Transmission Forum as kind of our guiding light,” Occidental Energy Ventures’ Venona Greaff, NAGF’s secretary, told ERO Insider. “We’re similar, but we’re quite a bit different because they have a full-time staff. We don’t. We do a lot of our efforts through the membership and through the volunteer efforts.” 

The NAGF’s generators provide their comments through the forum’s seven working groups. They include cold-weather preparedness, cybersecurity practices and variable resources. 

“They’re the experts specific to the standards that are applicable to that area,” said Greaff, a 30-year industry veteran who, in her day job, manages the NERC compliance program for Occidental Energy’s cogeneration fleet. 

“It’s sharing information, both among member to member but also getting information from the outside,” she added. “The whole purpose is just to assist our members … to help the generator community in general with compliance responsibilities, reporting responsibilities, understanding of standards and knowing what’s coming down the pipeline toward them.” 

Greaff and ERCOT’s David Kezell, director of weatherization and inspection, updated attendees at the annual meeting on revisions to NERC’s cold-weather standard (EOP-012-2, Extreme Cold Weather Preparedness and Operations). FERC accepted EOP-012-1 in 2023 but ordered revisions to be completed by 2024. That resulted in EOP-012-2, which the commission accepted in June while ordering that seven more changes be completed by March 2025. (See FERC Orders Further Cold Weather Standard Modifications.) 

The drafting team, which includes Greaff and several other NAGF members, has gathered feedback from the industry, asking for specific suggestions to strengthen the standard. Kezell, who chairs the team, said he expects only one more ballot will be posted from the three that are scheduled. The ballot will be live in December, setting up the NERC Board of Trustees’ consideration of the standard in March. 

To speed things along and meet FERC’s deadline, the team is using a shortened comment and ballot period of 20 days, rather than the usual 45 days. 

“We’ve been trying to approach this expeditiously. It’s an accelerated effort,” Kezell said. “We’re hoping to be able to take the responses that we got and the comments that we’ve received from this initial ballot and put together something that would be acceptable and we could get the requisite number of yes votes on the next round.” 

He said the biggest obstacle is coming up with an “appropriate” definition for generator cold weather constraints. The definition has been simplified to “any condition that would preclude a generator owner from implementing freeze protection measures on one or more generator cold weather critical components.” 

The team created a new attachment that establishes “highly common circumstances that would be appropriate for close to a blanket constraint that would be easily approved by the ERO,” Greaff said. 

“We called those pre-approved generator cold-weather constraints,” she said. “Ultimately, we may change that language, but the idea was to create a short list of things that we thought would be appropriately applied nearly everywhere.” 

The team also listed criteria describing a constraint and included them in the review. 

“We want to provide significant clarity to both the generator operators and to the regulatory personnel on what constitutes a valid generator cold-weather constraint,” Greaff said. 

There’s more to come. 

NERC is holding a technical conference on the cold-weather standard Nov. 12 at ERCOT’s headquarters. Speakers will review the FERC order, discuss the defined generator cold-weather constraints and share best practices. 

“As generators, it’s our chance to speak with the regulators, to hear where the constraints lie, but also to share thoughts with the drafting team so that we can move forward with the best approach in revising EOP 12,” Greaff said, encouraging her listeners to attend. 

CEC Floats $38M for Offshore Wind R&D

The West Coast’s floating offshore wind industry is getting a boost from nearly $38 million in research and development funds from the California Energy Commission’s Electric Program Investment Charge (EPIC) program.

During a Nov. 5 CEC meeting, several companies presented projects intended to increase efficiency and reduce costs for the offshore wind sector, including through improved environmental monitoring around wind turbines, new designs for technical components and innovative manufacturing solutions.

The ratepayer-funded EPIC program invests in technology development to advance clean energy solutions. The program’s specific goals related to offshore wind are to lower costs and to reduce technical and financial risk, as well as inform environmental mitigation, deployment planning and permitting.

Two solicitations are currently in progress.

The first awarded nearly $9 million to a handful of companies to advance technologies that detect marine life or ecosystem processes to assess risks and impacts in wind energy areas.

The second solicitation awarded nearly $12 million to projects to advance designs for floating offshore wind mooring lines and anchors. Another $17 million will go to solicitations currently under consideration, including projects seeking to reduce turbine design costs and improve port readiness.

“We are, as many folks know, a much deeper environment than the existing offshore wind systems [in the Atlantic], so reducing the costs of mooring lines and anchors is going to be paramount,” Daphne Molin, supervisor of CEC’s Research and Development Division, said at the meeting. “Additionally, environmental impacts and potential concerns are extremely important. We want to make sure that those designs are put up front into the design work so that these designs can be best placed for California.”

Environmental Monitoring

California’s wind energy areas are rich with seabirds protected under the Migratory Bird Treaty Act and the Endangered Species Act. Integral Consulting presented an EPIC-funded project designed to analyze those risks.

“Birds like the albatross and the petrel may be more vulnerable to collisions with floating offshore wind turbines because of their reliance on wind rich areas to propel themselves long distances between their breeding and foraging grounds offshore,” Grace Chang, senior science advisor at Integral, said. “Some of these birds fly at night and some at heights that overlap with rotor swept zones.”

To address these vulnerabilities, Chang said her company identified the need to generate bird and bat collision risk models to estimate species-specific impacts. The models require information about wind farm and turbine characteristics, environmental covariance, and bird and bat qualities. Collision risk models are most sensitive to the “avoidance rate,” which requires detailed information about bird and bat behavior over time.

Integral’s project seeks to fill existing knowledge gaps in understanding collision risk models, bird and bat abundance, and behavioral patterns near wind energy areas. The project integrates real-time testing and validation, 3D sensing technologies to quantify bird and bat avoidance of wind farms, and collision risk across three scales — macro, meso and micro.

The macro scale refers to a species avoidance of the entire wind farm, while meso is avoidance of individual turbines or rotor-swept zones, and micro is a last-second avoidance of a collision.

Field testing is already underway. Integral collected three months of data in California’s Humboldt wind energy area and deployed drones and radars in coastal environments in San Luis Obispo and Santa Barbara counties.

“We have a very rich set of data — multiple terabytes of data actually — that we’re in the midst of analyzing,” Chang said.

The Lawrence Berkeley National Laboratory also received funds for a project to cost effectively monitor the impact of wind farms on underwater species. The project considers the need for mooring lines and other fixed structures that would be tethered to the ocean floor due to the deep waters of Pacific OSW areas.

“How do we deploy floating offshore wind responsibly and harvest clean energy while protecting the marine species?” Yuxin Wu, staff scientist and geophysics department head at the University of California, Berkeley, said. “That is a big challenge.”

The lab is developing a distributed technology that will use optical fibers to sense temperature, vibration and other characteristics more than 100,000 meters deep to monitor species behavior and potential collisions with wind infrastructure.

Anchors and Mooring Lines

Sperra, a renewable energy startup, received CEC funding to develop and deploy concrete anchors for floating offshore wind platforms that it says will be less expensive and more environmentally friendly than traditional anchors.

The company is using its expertise in 3D concrete printing to develop a “next-generation suction anchor and torpedo anchor made from concrete.” The process is expected to reduce manufacturing costs by 37%-82% and carbon emissions by 55%-96% compared with steel anchors, according to company CEO Jason Cotrell.

“Concrete is actually a relatively low-carbon material compared to steel on a per-pound basis,” Cotrell said. “It has half the carbon footprint, and it can be made more green with certain mixes.”

Sperra is manufacturing 3D-printed concrete anchors out of the Port of Los Angeles for a variety of different markets, all of which will be deployed in California. It’s also researching 3D printing for floating foundations and docks.

To determine the design of the concrete anchors, Sperra analyzed seismic activity and seabed composition information in the Humboldt and Morro Bay wind energy areas to conceptually design six concrete anchors and two steel anchors for reference.

Sperra’s hope is to expand and accelerate the growth of California’s concrete and floating wind workforce, research and development capabilities and innovation ecosystem.

Another award recipient was the University of Maine Advanced Structures and Composites Center, which is developing a synthetic mooring line system for a 15-MW-plus floating wind turbine in the Humboldt and Morro Bay wind energy areas that could minimize impact to the ocean ecosystem.

“For an estimated 15 GW of offshore wind capacity, you’re going to need over 1,000 kilometers of mooring lines. The supply chain can’t currently handle that amount of material,” Spencer Hallowell, senior engineer at the University of Maine, said. “And then the installation vessels that may be either flagged for the U.S. or internationally also aren’t available to do that type of installation.”

The use of synthetic ropes can help alleviate supply chain concerns by eliminating heavier components like steel, Hallowell said.

In addition to studying the environmental conditions to determine the exact design of the mooring system, the department will monitor the system for entanglement of marine species and of fishing gear that could also capture marine animals.

The Schatz Energy Center and consulting company H.T. Harvey and Associates won funding for the “MoorSEA” project, an effort to combine mooring and monitoring technology by developing sensors that sit on mooring lines. Project researchers are working to identify which types of species, fishing gear and debris are most likely to become entangled in offshore infrastructure.

A final award recipient, the National Renewable Energy Laboratory, is developing a shared mooring system that would allow individual floating offshore wind turbines to share mooring lines or anchors.

“We want to develop these shared comprehensive mooring solutions to minimize costs, minimize failure risk and also minimize environmental impact for large scale floating wind farms in California,” Matt Hall, senior engineer at NREL, said. “There’s potentially a lot of benefits we can unlock.”

BPA Execs Lay out Markets+ Benefits, Risks, Reasons

PORTLAND, Ore. — The Bonneville Power Administration’s biggest risks in joining SPP’s Markets+ come down to footprint size and the limited transmission connectivity between the Northwest and Southwest entities most inclined to join the market, agency executives said during a Nov. 4 press briefing. 

BPA held the briefing immediately after a sometimes-contentious meeting where agency officials updated stakeholders on the day-ahead market decision process and discussed results from a new production cost model study estimating the agency’s potential economic benefits from participating in either Markets+ or CAISO’s Extended Day-Ahead Market (EDAM). (See related story, Rising Tensions Evident at BPA Day-ahead Markets Workshop.) 

The study, prepared by Energy and Environmental Economics (E3), found that BPA stands to realize the greatest savings in a single West-wide day-ahead market and would earn significantly more financial benefits from EDAM than from Markets+ under the most likely scenario reflecting the commitments a handful of key utilities have already made to joining the CAISO-run market. 

Despite those findings, BPA has said it plans to hold fast to its staff recommendation that the agency choose Markets+ for more qualitative reasons, such as its independent governance from the get-go and the market design established under that governance. (See BPA Sticks to Markets+ Leaning Despite Study Showing EDAM Benefits.) 

“I think footprint is a fair issue [for risk in Markets+], especially when you look at production cost model studies,” Rachel Dibble, BPA vice president of bulk power marketing, said during the briefing. “That’s really where those [economic benefits] numbers come from … the size of the footprint.” 

Dibble and acting BPA CIO Nita Zimmerman agreed that transmission connectivity between the two prospective Markets+ areas was another key point of risk for potential participants. 

“It really impacts the ability for power to flow across the region,” Dibble said. 

Dibble noted there is some connectivity between the Northwest and Southwest, but it’s “not particularly robust,” especially if NV Energy joins EDAM, a near certainty after the utility in May announced its intention to do so. (See NV Energy to Join CAISO’s Extended Day-Ahead Market.) 

“More connectivity would be better, because it does give the chance to do more optimization across the two [regions], but there is some transmission” between them, she said. 

“Flow will also go through California on California transmission as well,” Dibble added. “That’s still part of the market, because that transmission … also links the Northwest to the Southwest.”

Libby Kirby, BPA | © RTO Insider LLC 

Libby Kirby, BPA’s market initiatives policy lead, said the agency has few concerns about passing FERC market power screens under a scenario in which the two major parts of Markets+ are held together by limited transmission. 

“One piece of the market design in Markets+ includes a ‘conduct and impact’ test,” Kirby said. “So it’s not just, ‘Is there the potential for market power?’ It’s like, ‘Are you actually impacting the price?’ So there’s kind of some additional steps that they check before they actually assess you for market power.” 

During the workshop, some stakeholders pointed to the financial risk of BPA paying its $25 million share to fund the Phase 2 implementation phase of Markets+ if it later decides not to join the market, given that the funding is expected to be paid through future transactions in the market. Agency officials said the expense is worth ensuring the West has two viable day-ahead market options. 

During the briefing, Dibble said she didn’t yet know when the $25 million would come due if BPA declined to join Markets+ and that such details would be worked out in the Phase 2 contract. 

‘A Real Option’

Some workshop participants also expressed concern about BPA’s timeline for issuing a decision on its market choice, urging the agency to push back its May 2025 target to allow more time for legislative developments to play out around the West-Wide Governance Pathways Initiative.  

Asked about the impact on the BPA decision timeline of FERC potentially issuing a second deficient letter on the Markets+ tariff, Dibble said: “It’s something we would have to play by ear. It depends on what’s in it, [and] how quickly it could be answered. But I think ultimately, until we have a FERC-approved market, we don’t have a market to join.” 

Dibble pointed out that other Western entities aren’t waiting on BPA to make their market decisions. “And what concerns us is that Bonneville just gets pulled into whatever everyone else chooses, instead of it being a proactive choice that we are making based on what’s best for our customers,” she said. 

“I don’t believe that creating a West-wide market is something that is Bonneville’s responsibility,” she added, reiterating a point BPA representatives have made throughout the agency’s decision process. 

Nita Zimmerman, BPA | © RTO Insider LLC 

BPA recognizes the impact of its decision and wishes “no harm” to others in the Western Interconnection, Dibble said, “but our obligation and our fiduciary responsibility is to the people of the Pacific Northwest, and our decision will be what is best for the people of the Pacific Northwest and the subset of our preference customers that we have special obligations to.” 

The most telling comments about BPA’s firmness on its Markets+ leaning came in response to a question about whether the agency will be looking for signals from the California legislature next year around Pathways’ “Step 2” proposal to implement a more independent governance framework for CAISO’s Western markets. 

Dibble said that after a decade of waiting for California to grant CAISO more independence, BPA “decided to go out and work with the region and another market operator to create what we wanted.” 

“So to now say, ‘OK, we know what option you have out there that satisfies your needs, but now tell us what your bare minimum is that California could do’ — we’re not going negotiate against ourselves that way,” she said. “We have an option that’s no longer hypothetical. It is a real option that has a real independent market governance structure that satisfies us, and that’s what we’re measuring everything else against.” 

Duke Reports on Hurricanes’ Impact, SMR Plans in Q3 Earnings

Duke Energy on Nov. 7 reported third-quarter earnings of $1.226 billion ($1.60/share), a dip of about 15% from the same period in 2023, as results were impacted by one of the biggest hurricane seasons to hit its territory in memory.

“I am proud of the remarkable response from our employees and utility partners to a historic storm season, including three consecutive hurricanes,” Duke CEO Lynn Good said in a statement. “Our team’s commitment to our customers was unwavering as they worked around the clock to restore 5.5 million outages as quickly and safely as possible and rebuilt large portions of our system in a matter of days.”

Duke’s multiple utility territories were hit by hurricanes Debby, Helene and Milton this season, and it is expected to spend $2.4 billion to $2.9 billion on restoration in the Carolinas and Florida.

The costs impacted third-quarter earnings, but the work continues in the fourth quarter. Most of those costs will be deferred for future recovery in regulatory assets on the condensed, consolidated balance sheets or related to capital projects, the company said.

“My heart goes out to all of those who are directly impacted by these catastrophic storms, especially those who lost loved ones, homes or businesses,” Good said on a quarterly call with analysts.

The firm’s workforce had to repair its system while, in many cases, dealing with the impacts from the storms in their personal lives, she added.

“Our field teams rose to the challenge, working around the clock to restore outages as safely and quickly as possible,” Good said. “And our customer care representatives, corporate responders, community relations managers and state president offices worked tirelessly to keep customers and policymakers informed.”

Helene’s impact on Asheville, N.C., was unlike anything Duke has dealt with before, company President Harry Sideris said on the call.

“Over the three hurricanes, we assembled more than 20,000 resources from across the U.S. and Canada and restored approximately 5.5 million outages in some of the harshest conditions,” Sideris said.

Debby hit in August, knocking out power to 700,000 customers in Florida and North Carolina, though most were restored within a day, he added.

Helene hit both states a month later and impacted every one of the company’s territories, with the hardest hit areas in western North Carolina, upstate South Carolina and Florida’s barrier islands, Sideris said.

“The storm brought record-breaking rainfall and flooding, created landslides, and washed out roads and towns,” he added. In total, Helene led to approximately 3.5 million outages.

Then, as work to repair from Helene was continuing, a week later, Milton hit Florida and knocked out power to an additional 1 million customers there.

“Our success in responding to storms of this magnitude is due to our strategic preparation ahead of the storms, near constant communication with customers and stakeholders, and most importantly, the tireless work of our employees and utility partners,” Sideris said.

Meanwhile, Duke has been in the early planning stages of considering small modular reactors (SMRs), with Sideris saying some of its large customers are interested in using the technology to provide clean power for their operations.

“But any decision as we move forward, we’ll have to address three key items,” Sideris said. “The first one is the first-of-its-kind risk that exists, really, around the maturity of the technology [and] the supply chain. The second item is cost overrun protection, to protect our investors and our customers. And then our third is to make sure that we can protect our balance sheet [when] making these investments.”

Good also commented on the biggest story of the week when she congratulated President-elect Donald Trump for his victory.

“I think the U.S. economy will be a focus and a priority of his, and our industry plays an incredibly important role,” Good said. “So, as we look at what we’re doing here in the Carolinas and also Indiana and Florida, we are putting infrastructure in place in order to serve economic development and believe there are lots of opportunities to work together.”

Rhode Island Voters Approve Funding for OSW Port Infrastructure

Rhode Island voters overwhelmingly approved a ballot proposal Nov. 5 to dedicate $53 million in bonds to several environmental infrastructure projects, including $15 million for the Port of Davisville, which is transforming into an offshore wind staging point. 

The R.I. Ports Coalition, a maritime industry advocacy group that campaigned for the proposal, said the funding “will finance new berthing space, … prepare the port to serve as a key offshore wind hub for the North Atlantic and play a critical role in delivering clean energy to homes across the Northeast.” 

The Port of Davisville, Rhode Island’s only public port, is close to the large offshore wind lease area southeast of the state, which hosts the operating South Fork Wind facility, the under-construction Vineyard Wind and Revolution Wind projects, and several other proposed projects. 

“These infrastructure development projects will create additional jobs, position [the Quonset Business Park] to serve as a critical offshore wind hub in the North Atlantic, support Rhode Island’s clean energy goals and maintain the port’s position as one of the nation’s top auto importers,” the coalition said in a press release. 

In 2023, the port hosted 57 offshore wind vessels after opening “a specialized harbor” intended to accommodate smaller vessels. Quonset Development Corp. (QDC), which oversees the port, is hoping to scale up this operation in the coming years. 

“Given its proximity to the offshore wind leasing areas, the Port of Davisville is the ideal location for berthing offshore wind vessels, and with additional wind farms finalizing permitting, the port will continue to grow as a central location for marine logistics and operations,” QDC wrote in its 2023 annual report. 

QDC has outlined plans for a new pier to “offer specialized berthing spaces to accommodate a variety of offshore wind vessels and cargoes,” along with new support docks and a boat ramp to “accommodate smaller boats and the short-term docking needs of small businesses, emerging companies and research and development organizations.” 

However, the annual report identified a $40 million funding gap in the port’s master plan; the approved state bond will help address this need. 

The green bond approval will also give $2 million to restore coastal habitats to help improve climate resilience, $10 million to the Rhode Island Infrastructure Bank for municipal resilience, $5 million to preserve working agricultural lands, $5 million to clean former brownfield sites and $3 million to preserve open space.