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November 7, 2024

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FERC Orders New Reliability Standards in Response to Uri

WASHINGTON — FERC on Thursday approved two new NERC reliability standards in response to the February 2021 winter storm that nearly led to the collapse of the Texas Interconnection (RD23-1).

According to FERC staff, EOP-012-1 (Extreme cold weather preparedness and operations) and EOP-011-3 (Emergency operations) implement about half of the standards-related recommendations from the commission’s joint inquiry with NERC into the Texas grid operator’s poor performance during Winter Storm Uri.

The standards require generator owners to implement several measures to prevent their units from freezing during extreme cold-weather events. These include constructing retrofits at existing units based on the “extreme cold weather temperature” where they are located, defined as the lowest 0.2 percentile of the hourly temperatures measured in December, January and February since Jan. 1, 2000.

Owners will be required to submit corrective action plans if the temperature is at or above the unit’s designated extreme and one of the following occurs:

  • a forced derate of more than 10% of the total capacity of the unit, and exceeding 20 MW, for longer than four hours in duration;
  • a start-up failure where the unit fails to synchronize within a specified start-up time; or
  • a forced outage.

Generator owners and operators will also need to conduct annual staff training on cold weather preparedness and develop procedures to improve the coordination of load-reduction measures during an emergency.

The new standards were approved by the NERC Board of Trustees in October as part of Project 2021-07. (See NERC Board Approves New Cold Weather Standards.)

“These new standards will help to prepare our nation’s grid and our grid operators so they can provide power to consumers in the face of extreme weather,” acting FERC Chairman Willie Phillips said in a statement. “I am pleased that NERC and its regional entities acted swiftly to propose these reliability standards so that my fellow commissioners and I could move decisively and vote today to ensure the reliability and resilience of the bulk power system.”

Despite unanimous approval at FERC’s open meeting Thursday, the commission acknowledged that more work needs to be done. Project 2021-07 is only Phase 1 of a three-phase process at NERC in response to the storm, and staff noted that more proposed standards will be brought before the commission by the end of the year to address the second half of the relevant recommendations.

Standard’s Shortcomings

FERC also found EOP-12-1 to be lacking, and it directed NERC to revise it to “to clarify certain language, enhance certain standard requirements, include criteria on permissible constraints and identify the appropriate entity that would receive the generator owners’ constraint declarations under the standard,” staff said in presenting the order.

“EOP-012-1, in its current form, includes undefined terms, broad limitations, exceptions and exemptions, and prolonged compliance periods,” FERC said in its order.

Among the elements FERC required be included in the next version of the standard are a deadline for the completion of corrective action plans and a shorter grace period for generators to implement those plans and freeze-protection measures. The approved standard gives generators five years to upgrade their facilities, for example.

“Although we are giving NERC the discretion to determine what the effective date should be shortened to, we also emphasize that industry has been aware of and alerted to the need to prepare their generating units for cold weather since at least 2011,” FERC said. After the January 2018 South Central cold snap, a joint FERC-NERC report found “that one-third of the generator owners and operators surveyed ‘still had no winterization provisions after multiple recommendations on winter preparedness for generating units.’”

“NERC should consider the amount of time that industry has already had to implement freeze-protection measures when determining the appropriate implementation period,” the commission ordered.

Commissioner Allison Clements criticized EOP-012-1’s deficiencies at length during the meeting. “This is one of the more important votes we are taking during my time at the commission,” she said before recalling the deaths and economic damage Texans experienced during the 2021 storm as a result of prolonged power outages.

“There are a number of good measures in what we accept today, to be sure,” Clements said. “But the critical generator weatherization requirements as they were proposed, to be frank, are not up to the task.”

EOP-012-01 requires that existing generators be able to operate for at least one hour continuously at their designated extreme low temperature. “Yeah, one hour,” Clements said sardonically. “Needless to say that doesn’t bring total comfort that we will ensure we get through the next multiday event like Winter Storm Uri.”

She also said the amount of time allowed for implementation “does not reflect the urgency we feel.”

The commission gave NERC a year to submit the revised standard.

Although ERCOT’s markets are not subject to FERC regulations, generators in the Texas Interconnection are subject to NERC’s reliability standards. But Commissioner Mark Christie said market design was the bigger issue.

“These [standards] may have a positive impact … for generators, but … one of the problems that prompted [what happened during] Uri was the market design” in ERCOT, he said. “And I think the same issue applies in many other RTOs. It’s a much bigger issue about how these markets are structured and how they deliver the reliability that we need.”

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NERC Board of Trustees/MRC Briefs: Feb. 15-16, 2023

Participants Praise ‘New Cadence’ for In-person Meetings

TUCSON, Ariz. — Following this week’s meetings of NERC’s Board of Trustees and Member Representatives Committee (MRC), board Chair Ken DeFontes congratulated the bodies on “a very productive week,” aided by a “new cadence” for the events intended to give participants more chances to interact outside of formal gatherings.

“I really got a strong vibe last night from everyone … how much they enjoyed getting together and having that kind of approach,” DeFontes said in opening Thursday’s board meeting.

“I also hear positive feedback from people about the time that we’ve allowed for breaks and an opportunity to have more informal conversations. I think we’re becoming more hungry for that just because we haven’t been able to be together as much as we would have liked,” he continued, referring to the moratorium on in-person gatherings caused by the COVID-19 pandemic that the board and MRC ended their August meetings with in Vancouver.

The Tucson meeting was one of only two full gatherings planned for members and trustees this year, as announced when the board met in New Orleans in November. (See “Board Makes Meeting Changes Official,” NERC Board of Trustees/MRC Briefs: Nov. 15-16, 2022.) While the August 16-17 meetings — to be held in Ottawa, Ontario — will feature full attendance by trustees, members and stakeholders as usual, only trustees and members will attend the May 10-11 gathering in D.C. in person, while others will attend virtually.

The final meeting of the year will be held entirely online; currently the plan is for this meeting to be trustees only, though DeFontes has previously said a virtual MRC meeting is possible if action is needed from members.

New Standards Sent to FERC

Trustees voted Thursday to adopt two new reliability standards, concluding the work of Project 2021-04 (Modifications to PRC-002 – Phase II) and Project 2021-05 (Modifications to PRC-023).

Project 2021-04 produced the standard PRC-002-4 (Disturbance monitoring and reporting requirements), which clarifies notification requirements for fault recorder data in order to help analyze bulk electric system disturbances. The result of Project 2021-05 is PRC-023-6 (Transmission relay loadability), which aims to “eliminate confusion surrounding out-of-step blocking settings.” Both standards will now be submitted to FERC for final approval.

Following the approval of the new standards, Howard Gugel, NERC vice president of standards development, updated the board on the progress of the organization’s work on addressing extreme cold weather.

Earlier on Thursday FERC had agreed to adopt the new standards EOP-011-3 (Emergency operations) and EOP-012-1 (Extreme cold weather preparedness and operations) following their approval by the board in October. Gugel noted that these two standards represent the first phase of the cold weather standards project that the board ordered in November 2021. The standard development team is currently working on the second phase and plans to have new standards available for public comment by March, after the team revises them one more time to address the commission’s newest order.

Board Agrees to Shortened Data Request Timeline

In addition to the standards actions, the board voted to authorize a shortened timeline for NERC to gather information related to FERC’s order last month directing NERC to develop standards requiring utilities to implement internal network security monitoring on certain bulk electric system cyber systems. (See FERC Proposes New Cybersecurity Standard.)

The commission’s order mandated that NERC’s new standards apply to all high-impact BES cyber systems, and to medium-impact cyber systems with external routable connectivity. In addition, the order directed NERC to study the potential impact of applying the requirements to all other cyber systems. FERC ordered this study to be submitted by Jan. 18, 2024.

Performing such a study would require NERC to issue a Section 1600 data request to responsible entities, but this request must be submitted to FERC for a 21-day review period, and then undergo a public comment period that normally lasts 45 days, which NERC staff feared would leave them unable to meet FERC’s deadline.

Staff requested that the board allow this comment period to be shortened to 21 days, and to request FERC shorten its review period to as little as five days, promising to “conduct outreach and coordination with FERC staff during the data request drafting stage.” The board approved the request without objection.

Thilly Honored in Retirement

Kristine Schmidt joined Thursday’s meeting as NERC’s newest trustee, having been confirmed by the MRC at its meeting the day before along with existing trustees Suzanne Keenan and Jim Piro. Each will serve for three years, with their terms expiring in February 2026.

Schmidt has 40 years’ experience in the electricity industry, including at Pacific Gas and Electric, where she was a board member in 2019-20. She has also served on the Western Energy Imbalance Market Governing Body, where she was the inaugural chair in 2016. Her career has also included stints at Xcel Energy and ITC Holdings, as well as a commissioner adviser at FERC. She will serve on the board’s Enterprise-wide Risk Committee, Finance and Audit Committee, and Nominating Committee.

Schmidt will take the seat recently vacated by former Chair Roy Thilly, who was ineligible for renomination having served on the board for 12 consecutive years. This restriction did not apply to Keenan and Piro, who have served for five and three years respectively.

Introducing a resolution to honor Thilly for his years on the board, DeFontes jokingly called Thilly — who preceded him as chair, serving from 2017 to 2021 — his “consigliere” for helping him get up to speed in his new role.

“When I stepped up to be chair, I was feeling a little uncomfortable [about] following Roy. But to his credit, he helped me a great deal with the transition, … and he did it with grace and dignity and humility,” DeFontes said.

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Heinrich: Pipeline Permitting ‘Reform’ Will Also Benefit Clean Energy

WASHINGTON ― Legislation to streamline the permitting of clean energy projects, including new transmission lines, may require bipartisan collaboration and tradeoffs, according to Sen. Martin Heinrich (D-N.Mex.).

While Republicans and some Democrats, such as Sen. Joe Manchin (D-W.Va.), are focused on permitting new natural gas pipelines, there is an “upside” to the situation, Heinrich said in a brief interview Wednesday at the American Clean Power Association’s Energy Storage Policy Forum.

“If we can do permitting reform and do it well, so much of the capital is actually going to flow to clean electrons. So that sets us up for the potential for a bipartisan solution to all this,” he told RTO Insider.

The senator pointed to cost allocation as one of the “tough issues” to be worked through to prevent states and their residents from “paying for something they’re not benefiting from. But you have to have ways of sharing costs across multiple jurisdictions, multiple businesses and making sure that costs and benefits get shared proportionately.”

Conversations about the issue among Democrats and Republicans in the House and Senate are “more sophisticated than they have been in the past,” he said.

A compromise on pipelines could have “the potential to make this a bipartisan solution,” said Heinrich, who sits on the Senate Energy and Natural Resources Committee, which Manchin chairs. “People have to realize that because of where the markets are heading, anything we do in this space is naturally going to benefit the clean energy transition.”

The need for the storage industry to move ahead with a strong bipartisan strategy was a key theme at the one-day event, with Jason Grumet, ACP’s new CEO, setting the tone in opening remarks that called on attendees to “find a way to balance the audacity of this transition with the humility of the limitations that all technologies have.”

Coming to ACP after 15 years as president of the Bipartisan Policy Center, Grumet said, “The challenge is that … we have to make a century-scale transition in 25 or 30 years. … There’s been a lot of advocacy, which is intended to be supportive, which has not been honest, which essentially said, ‘We can have 100% clean power by 2035 and leave oil and gas in the ground.’  

“That’s not true. It undermines our credibility, makes us seem like hypocrites,” he said. “We just have to be really honest and pragmatic about the challenge. We’re going to have a multi-technology solution,” including natural gas.

“We have to recognize that storage, solar, wind, nuclear, clean gas are all going to be critical to actually decarbonizing the economy, and that’s also helpful because we need a lot of friends,” Grumet said. “We have a divided country, a divided Congress. You can’t get anything done unless you have broad-based appeal.”

Security, Affordability, Climate

ACP’s choice of Grumet to lead the organization, with his strong roots in bipartisan work, comes at a pivotal moment for the industry.

The U.S. energy storage market is “past the inflection point,” said Jason Burwen, ACP vice president for energy storage. The industry put about 9 GW of new storage online in 2022, and according to the U.S. Energy Information Administration, another 21 GW of new storage could be deployed on the grid by 2025.

Further, the Inflation Reduction Act provides a new tax credit for standalone storage, which opens the way for storage to be used as a grid resource. California has more than 4 GW of storage online, not all of it paired with solar, and could need up to 48 GW by 2045, according to the California Energy Commission.

US Battery Storage Capacity (EIA) Content.jpgDevelopers and power plant owners plan to significantly increase utility-scale battery storage capacity in the United States over the next three years, reaching 30 GW by the end of 2025. | EIA

“The remarkable growth in U.S. battery storage capacity is outpacing even the early growth of the country’s utility-scale solar capacity,” the EIA said in a December update. “U.S. solar capacity began expanding in 2010 and grew from less than 1.0 GW in 2010 to 13.7 GW in 2015. In comparison, we expect battery storage to increase from 1.5 GW in 2020 to 30.0 GW in 2025.”

Grumet sees energy storage as a central answer to the economic and political challenges of the moment. “Security, affordability and climate all have to be engaged at once,” he said. “The effort to focus on one of those three elements turns out to be pretty crappy energy policy that tends to lead you towards one side or the other of the political spectrum.”

While different mixes of generation can move the economy toward net-zero, energy storage is a hinge for all the of them, he said.

But bipartisanship can be a double-edged sword. “There’s a ton of bipartisan support for ‘don’t do anything near me’ … which is absolutely at odds with what we need to do,” Grumet said. “We have a society based on this premise of local control and community rights, and we have to honor that premise [but] you cannot transition that economy with community-based decisions.

“So we’ve got to figure out, again, as an industry, how do we make it clear that we have a shared national interest?” he said.

Starting From Nowhere

In an on-stage conversation with Grumet, Heinrich agreed that energy storage must be “socialized” as a “bread-and-butter” solution to a range of energy challenges.

“When I came to the Senate, and that was after four years in the House, there were a very small number of senators [who] were really focused on what are the nuts and bolts to really make the energy transition work,” he said. But as climate change has become an increasingly important issue, “the entire [Democratic] caucus is focused on solutions and looking for solutions.

“So if you come with credibility and say, ‘This policy or this technology is going to be absolutely critical,’ people start with an open mind,” he said.

Bipartisan solutions will also be needed to address clean energy supply chain issues and dependence on China for the processing of critical minerals, such as lithium, and manufacturing of key storage components.

“What we have to recognize is that industry doesn’t exist in a meaningful way in the continental U.S. today, and we need to change that,” Heinrich said. Tax credits for clean energy manufacturing in the Inflation Reduction Act have catalyzed new interest and activity in developing an industrial policy, he said, “but we’re really starting from practically nowhere.”

At the same time, “we don’t want to shut down for seven years,” while domestic supply chains are built out, he said. “You can’t wait until we make everything here to start creating solutions that we know we need today. … Why this is so complicated a problem is because we are really reorganizing the way we power our entire society.”

Grumet raised ongoing concerns on both sides of the aisle in Congress about China’s acquisition of U.S. technologies and intellectual property, which have resulted in “a reluctance to have any connection at all” with the country.  

Both he and Heinrich see new opportunities for U.S.-Chinese joint ventures growing out of the snowballing investments in clean tech manufacturing in the U.S., triggered by the IRA.

While some European countries have labeled the law as “protectionist” and say it will draw investment away from the European Union, Heinrich said, it shows that “we’re serious about taking a new direction.”

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Mitsubishi: IRA Tax Credits Key to Clean Hydrogen

The multiple tax credits provided by the Inflation Reduction Act are key to the development of major clean hydrogen projects, as well as seasonal hydrogen storage, says one company that is already building the largest green hydrogen storage and generation facility in the U.S.

John Young (Reuters Events) Content.jpgJohn Young, Mitsubishi Power | Reuters Events

“Mitsubishi Heavy Industries has officially recognized that the energy transition is going to happen here in the United States first,” John Young, head of government relations at Mitsubishi Power Americas, said in a webinar Thursday organized by Reuters.

“The center of excellence in the energy transition is going to move from Japan to the U.S,” Young continued. “That’s a big deal for our company here in the U.S. because we now get the full weight of our parent company’s resources.”

The IRA’s multiple and expanded tax credits will provide significant benefits to the company’s energy storage projects as well as its solar development business, and the credits can be stacked, he said.

Among them is a 30% solar investment tax credit for projects through 2025. And projects that can certify that steel and manufactured components were made in the U.S. can qualify for an additional 10% credit. Another tax credit is available for projects located in a community that previously relied on fossil fuel generation, Young noted. The IRA also has expanded the production tax credit, he added, providing additional support for solar projects alone.

Storage, whether battery for short term or hydrogen for longer term, such as seasonal use, are also provided new tax credits under the IRA.

“Under the IRA, this investment tax credit was increased 30% over 10 years. And importantly, standalone storage now qualifies as eligible. Like the other credits, this ITC also includes that 10% bonus credit for energy communities and domestic content.”

The bottom line, he said, is that the credits are “technology neutral,” making it easier for companies like Mitsubishi to innovate and bring new technologies to market quickly.

“That we can choose between the investment tax credit and the production tax credit for both the long-duration energy storage and the production of hydrogen really blows the doors off this whole tax regime and allows hydrogen the flexibility it deserves.

“The IRA represent a clear recognition by Congress that if the U.S. is going to lead the world in the energy transition, it needs carrots and sticks and foundational change in the way our federal tax code works.

“We see this change as leveling the playing field for all technologies to have the same shot, same goal — net-zero greenhouse gas emissions — and it doesn’t matter whether [it’s] from wind, solar, geothermal, hydrogen or space lasers, as long as you are generating energy with net-zero emissions.”

Michael Ducker (Mitsubishi Power) FI.jpgMichael Ducker, Mitsubishi Power | Mitsubishi Power

The company began a massive project in Utah that will power an electrolyzer with renewable power to produce green hydrogen that will be stored in massive salt caverns as a fuel for combined cycle gas turbines when demand outstrips available renewable power. (See The Growing Inevitability of Hydrogen.)

The ACES Delta Project will produce 100 metric tons of hydrogen per day with 220 MW in Delta, Utah, said Michael Ducker, vice president of hydrogen production for Mitsubishi Americas.

In 2019 when the company began the project, there was no discussion of hydrogen hubs, Ducker said. “We actually had folks tell us when we were investing in the project that it was a science project; that we were throwing money away,” he said.

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FERC Rulings Diverge on Commercial Operation Deadlines

FERC granted an Oklahoma solar project a 90-day extension of its commercial operation deadline while rejecting an Illinois wind project’s request for a waiver, saying the developer failed to make its case for relief.

The commission on Thursday granted Recurrent Energy’s 120-MW North Fork Solar Project in Kiowa, Okla., a 90-day extension of its required commercial operation date (COD) (ER23-737).

North Fork’s generator interconnection agreement with SPP and Western Farmers Electric Cooperative requires commercial operation by May 1, 2024, which was extended from the original COD of December 1, 2019. The company said it needed a 90-day extension, to July 30, 2024, to align the COD with the mechanical completion date provided by North Fork’s engineering, procurement and construction (EPC) contractor and to allow a 90-day period between mechanical completion and the COD, as required under North Fork’s power purchase agreement.

Neither SPP nor Western Farmers opposed the waiver.

North Fork said it has spent $7.7 million developing the project and expects to spend an additional $11 million by the time construction begins, including payments to the EPC contractor, developer fees and financing costs. It has secured land rights for 1,920 acres for the project, which will interconnect at Western Farmers’ 138-kV Snyder Substation.

North Fork has a 15-year PPA with the Oklahoma Municipal Power Authority (OMPA) for the full output of the project. The PPA requires the project to reach commercial operation by May 31, 2024, so that OMPA can claim capacity credits for the summer of 2024. North Fork would be liable for liquidated damages if it misses the deadline.

“Accordingly, North Fork states that it is commercially incentivized to achieve commercial operation as soon as possible,” FERC said.

North Fork said its EPC contractor has provided an estimated mechanical completion date of mid-March 2024, which would precede the initial synchronization and beginning of test sales.

Waiver Rejected

In a second order, the commission rejected a request by ZEP Grand Prairie Wind, a proposed 150-MW project in Illinois, to extend its COD from November 2025 to February 2027 because of delays caused by the COVID-19 pandemic (ER23-137).

ZEP’s generator interconnection agreement with MISO and the city of Springfield, Ill., would be terminated if the project does not reach commercial operation by November 2025.

Developer UKA North America said it had recalled its land agents responsible for negotiating property rights for the project site and interconnection rights-of-way in response to the Illinois governor’s March 2020 executive order requiring all non-essential employees to remain at home because of the COVID pandemic.

The company also cited supply chain problems that arose during the pandemic, saying key components that previously took nine to 12 months to receive are now taking 18 months or longer.

ZEP Wind said that it has spent more than $4 million on the project and obtained 100% site control and more than 85% of the transmission rights-of-way required. Nevertheless, it said will be unable to reach commercial operation by its 2025 deadline.

The commission said ZEP Wind “has not provided any details regarding whether any components for the project are delayed, the estimated time for their delivery, or whether and how any such delay affects its ability to achieve commercial operation by November 15, 2025.”

The commission said it would reconsider the waiver request if ZEP Wind provides more detail.

FERC on Thursday also upheld five prior rulings that had been subject to rehearing requests:

      • The commission addressed arguments raised on rehearing of its Oct. 20, 2022, order accepting Henderson Municipal Power and Light as a transmission owner in MISO and allowing Henderson to recover its revenue requirement for transmission facilities (ER19-776-002, ER19-809-002). (See FERC Rules Kentucky Muni Can Remain a MISO TO.)
      • The commission addressed requests for rehearing of its Sept. 9, 2022, order accepting two unexecuted generator interconnection agreements, which assigned to SPP interconnection customers the costs of a network upgrade (ER22-2371-001, ER22-2372-001).
      • The commission rejected Tenaska Clear Creek Wind’s request for rehearing of its Sept. 9, 2022, order, which found that the assignment of certain network upgrade costs was just and reasonable (EL21-77-003). The order also denied a motion for stay. (See FERC Rules in Three SPP Disputes.)
      • The commission rejected a request for rehearing and clarification of its Dec. 16, 2022, order setting for hearing and settlement judge procedures issues raised in a complaint relating to the operation of Entergy’s Grand Gulf nuclear facility (EL21-56-001). (See Fifth Circuit Demands an Explanation from FERC on Long-Pending Grand Gulf Complaints.)
      • FERC sustained the result of its Oct. 7, 2022, order denying Southwestern Public Service Company’s complaint alleging that SPP violated its tariff by setting the cleared energy award for SPS’s Hobbs generating facility to zero when SPP settled the day-ahead market for Feb. 17, 2021 (EL22-30-001).
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Federal and State Regulators Look into How to Improve Grid Security

WASHINGTON — The sixth meeting of FERC’s Joint Federal-State Task Force on Transmission, held Wednesday, looked into how the grid can be better protected against physical attacks, which have been on the rise recently.

“There are well over 50,000 high-voltage substations across North America, and more than that if you include those that only support the distribution system,” NERC CEO Jim Robb said at the meeting, held concurrently with the National Association of Regulatory Utility Commissioners’ Winter Policy Forum. “That’s a tremendous amount of infrastructure to think through how to protect responsibly, and to really think through the tradeoffs that need to be made between risk and consequence and the investments that you make between protection and prevention, versus response and recovery.”

Protecting all of those assets is not feasible, as it would cost far too much, but not every substation is a critical asset that needs high levels of security, Robb said.

Even most incidents at substations would not qualify as attacks, with “criminal mischief” — in which people steal copper or vandalize substations — being much more common than occurrences like the attacks in North Carolina and Washington state and the foiled plot in Baltimore.

“But over the last six to nine months, we’ve seen more and more attacks, which would exceed the threshold of criminal mischief and really rise to the level of sabotage,” said Robb.

The increased concern over the rise in attacks is appropriate, but Robb said that only 5% of incidents at substations actually impact the grid, either by causing some customers to lose power, or by putting the system into a contingency operation mode.

CIP-014 (Physical security) was issued after the Metcalf Substation attack in Silicon Valley a decade ago. Its purpose is to ensure that physical attacks on substations did not lead to major, cascading outages on the grid, and so it focuses on substations with more power flows, at 345 kV and above, said Robb.

“While many substations may not need to be technically CIP-014-compliant, their owners may very well build in protections because it’s the right thing to do,” he added. “The utility sector generally leans in very, very hard on security matters, whether physical or cyber, to protect their assets and their ability to serve their customers.”

One idea for updating CIP-014 might be to focus on the possibility of coordinated attacks on multiple substations, said Robb. It could also shift from focusing on preventing cascading outages to preventing any outages at all, he added.

Puesh Kumar Jim Robb (Federal State Task Force on Transmission) Content.jpgDOE Office of Cybersecurity Energy Security and Emergency Response Director Puesh Kumar and NERC CEO Jim Robb address the joint task force on Wednesday. | Federal State Task Force on Tran

Puesh Kumar, director of the U.S. Department of Energy’s Office of Cybersecurity, Energy Security and Emergency Response, told the task force that the law enforcement community is very focused on the issue, as he is regularly meeting with the FBI and the Department of Justice.

“When we think of the law enforcement angle, that again doesn’t need to just be at the FBI level,” Kumar said. “We need to make sure that we have local law enforcement; we have state law enforcement also engaged in this conversation and really recognizing and appreciating the criticality of the electricity infrastructure across the country.”

Broad Solutions Save Money

With tens of thousands of physical sites requiring protection around the country, along with the need to protect the grid against cyber-attacks and extreme weather, it is important to focus on solutions that cut the risk across the board, Kumar said.

“How are we investing in tools and technologies that can also help us buy down the risk?” Kumar said. “It’s not just the standard that buys down risk; there’s a lot of other ways and tools and technology as part of the puzzle that we have to be thinking about.”

The biggest threat from a single-asset perspective is electric power transformers, which are just part of a substation’s equipment and thus could benefit from increased protections compared to other assets, PPL Electric Utilities Chief Information and Digital Officer Matthew Green told a panel at the NARUC summit earlier in the day. The risk around transformers can also be mitigated by ensuring the industry has enough backup equipment to replace anything that is damaged.

While physical attacks are a concern and a priority for PPL that is being addressed by prudently investing to protect the riskiest assets, it is not Green’s main worry.

“I’m actually more concerned around cybersecurity attacks,” Green said. “And, actually, in 2022 the single biggest contributor to outages for customers in United States continues to be weather-related outages. So that is also still a top concern.”

Investments to prevent outages from those causes need to be made prudently, after an accurate assessment of the relevant risks, he added.

The U.S. grid is decentralized, which means attacks on individual assets are unlikely to really have a major impact reliability across the board, said Kansas Corporation Commissioner Andrew French. But coordinated attacks are an increasing concern, so French asked Robb what the best strategy to address those would be.

One way of complying with CIP-014 is to remove any kind of critical substations from a utility’s network, which can happen in the process of normal grid planning or in coming back after a storm.

“I would love to see that number continue to decline, as we can build more and more redundancy into the system and less dependence on a subset of the assets around the grid,” Robb said.

Beyond that, coming up with a strategy to deal with the risk of coordinated attacks is tricky because it is not financially feasible to harden every grid asset out there. Having backup equipment available to minimize any downtime would help.

“One of the issues that’s vexing the industry right now, with all the supply chain challenges that we have, is that a lot of this equipment isn’t standardized,” Robb said. “So, I think that’s an opportunity as we as we move forward.”

Changes Needed for CIP-014?

Michigan Public Service Commission Chair Dan Scripps said it makes sense that CIP-014 is site-specific, but he asked whether it would also be prudent to have some kind of minimum level of protection spelled out in the standard.

The standard is fairly new, Robb said, so the industry has less experience from which it can draw best practices, but minimum standards are one of the updates that should be considered.

“There’s nothing that would prevent a state from imposing its own security requirements on any of these assets,” Robb said. “So, if to the extent that any of you feel that the NERC standards don’t go far enough to protect the systems under your jurisdiction from issues that you’re concerned about, you can always go further.”

Physical is usually an afterthought when it comes to planning the grid, but acting FERC Chairman Willie Phillips argued it would make sense to change that.

“If we consider it on the front end, I think we do have an opportunity to do something about what can be a very costly process,” Phillips said.

PJM has a process in which it works to minimize the number of critical infrastructure sites on its grid through planning, Phillips said, and that could work well elsewhere, as long as information on sensitive sites is handled correctly.

Connecticut Public Utilities Regulatory Authority Chair Marissa Gillett said that it might make sense to deal with physical security issues in the transmission planning process, but she worried that it would give the industry another excuse to shut out the states from the process in ISO-NE.

“I just think we need to be cognizant of some of the challenges around them,” Gillett said. “Especially because of that tension … between wanting to have openness while needing to respect the concerns about disclosing too much about physical security threats.”

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Feds Announce Grant Standards for EV Chargers

The Federal Highway Administration on Wednesday announced key details of its effort to create a national electric vehicle charging network, including minimum standards for federally funded projects and an implementation plan for domestic content requirements for chargers.

Also Wednesday, the White House announced that major players in the EV industry would undertake an extensive buildout of chargers, and that Tesla would make part of its U.S. Supercharger network open to all EV brands for the first time.

A nationwide charger network is critical to ease a key barrier to widespread public acceptance of EVs — range anxiety, the fear of running out of power mid-journey.

The U.S. Department of Transportation has begun a $5 billion effort to counter this concern and encourage EV adoption: NEVI, the National Electric Vehicle Infrastructure program. (See US Completes Review of State EV Charging Plans.)

The rules announced Wednesday include, but are not limited to, NEVI-funded chargers and represent a step toward standardization. They are designed to create a more uniform experience for the EV-driving public, with consistent plug types and charging speeds; common payment systems; and accessible information on location, pricing and availability. Requirements for 97% uptime reliability and future compatibility will be imposed.

This sets the stage for municipalities, states and tribes to apply for the first round of $2.5 billion in competitive funding for charging stations under the Build America, Buy America Act.

The Biden Administration is working to create a national network of 500,000 EV chargers to support a goal of at least 50% of new car sales being EVs by 2030. It says there are now more than 3 million EVs on the road and more than 130,000 public chargers.

The latter number will get a bump from companies including Tesla, General Motors, EVgo, Pilot, Hertz and BP, with the White House announcing Wednesday that they would expand their public charger networks by thousands of plugs over the next two years.

Tesla has built a proprietary network of chargers compatible only with its own vehicles, though Tesla drivers can use many non-Tesla chargers with an adapter.

Under the agreement announced Wednesday, the company will make at least 7,500 Supercharger and Destination Charger stations available to non-Tesla EVs by the end of 2024. At least 3,500 will be along highway corridors. Tesla will also more than double its network of Superchargers.

In addition to Tesla’s efforts:

  • Hertz and BP are building a national network of chargers at Hertz locations, some of which will be large-scale gigahubs. Hertz wants to make a quarter of its rental fleet electric by the end of 2024, and BP plans to invest $1 billion in U.S. EV charging by 2030.
  • Pilot, GM and EVgo are building a network of 2,000 350-kW fast chargers, the first 200 of which will be online later this year.
  • TravelCenters of America and Electrify America plan approximately 1,000 chargers at 200 locations.
  • Mercedes Benz, ChargePoint and MN8 Energy plan more than 400 charging hubs with more than 2,500 public DC fast charging ports across the U.S. and Canada.
  • GM and FLO plan to install up to 40,000 Level 2 chargers in communities by 2026 through GM’s Dealer community Charging Program.

Some of these plans had been announced previously.

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Skelly’s Grid United Quickly Making Waves

Four years ago, transmission developer Michael Skelly was on the outside of the electric industry looking in.

Clean Line Energy Partners, the company he had founded to deliver renewable energy over HVDC transmission lines, had sold off its portfolio of projects and closed its doors. Having taken a senior adviser’s role at Lazard Asset Management, Skelly was invited to speak at the American Wind Energy Association’s WINDPOWER 2019 conference. He said that while Clean Line hadn’t been able to “win the World Cup of transmission,” he was hopeful that “the second mouse gets the cheese in the transmission world.” (See Out of the Game, Skelly Still High on Wind Energy.)

Mike Skelly 2019-05-25 (RTO Insider LLC) FI.jpgMichael Skelly | © RTO Insider LLC

It appears Skelly could be one of those mice.

As CEO of Houston-based Grid United, Skelly now leads a company intent on uniting the nation’s grid by building long-distance, interregional transmission to ensure access to low-cost power “when and where it is needed” — in other words, pretty much what Clean Line was trying to do.

Skelly’s company made a big splash recently by announcing a collaboration with ALLETE to build the North Plains Connector, a $2.5 billion, “first-of-its-kind” project that would span across the Western and Eastern interconnections. The 385-mile HVDC line will run from SPP’s wind-rich North Dakota footprint to the Colstrip power plant in Montana, where two 500-kV lines run into the Pacific Northwest. (See Transmission Project Would Span Across Interconnection Divide.)

Skelly said a number of wind projects are being built around Colstrip. Along with the region’s hydropower assets, it will give North Plains a chance to move power in either direction.

“During times when there’s excess generation in Montana, either from wind or solar or the spring hydro runoff, it will move power to the east into the Midwest,” Skelly told RTO Insider. “At times when there’s high load and low wind during the night and there’s no storage, it will power the West.”

The project, he said, will effectively improve renewable resources’ effective load-carrying capability, a measure of their ability to produce energy when the grid is most likely to experience shortfalls. Skelly said his staff did a backcast on the project to see how it would have performed under extreme weather conditions.

“As it turns out [during the February 2021 winter storm], they were short power in the Upper Midwest, and the Pacific Northwest had a lot of power. And similarly, when there was a heat over Seattle and Portland [last summer], there was plenty of power available in the Midwest,” Skelly said. “Our transmission is a very good way to deal with those extreme events, particularly transmission that can connect things that are a thousand-plus miles apart, because you’ve got very different weather phenomena.”

Grid United is also involved with the Southline Transmission Project, a 280-mile, high-voltage circuit between Tucson, Ariz., and the El Paso Electric system. The project also includes a 120-mile upgrade of existing Western Area Power Administration transmission lines.

“The focus of these grid projects is the things that we all know need to happen to improve resiliency and adapt to the change of generation, but that sort of fall between the cracks of the planning processes,” Skelly said, explaining how Grid United’s strategy is different from Clean Line’s.

“So, the model may be a hybrid model where we own interests and projects, and utilities own interests, or maybe the utilities own the whole thing. It will depend a lot on the specific project,” he said. “From a development perspective, our approach to development is to start to do a lot of the groundwork and a lot of the right-of-way work before we get down to the regulatory processes.”

And then there’s Pecos West, a 280-mile, 525-kV DC line from a substation in the middle of West Texas to El Paso. The project, still on the drawing board, would link ERCOT with the Western Interconnection. Grid United’s application for a “partial” certificate of convenience and necessity is on the Texas Public Utility Commission’s agenda for its open meeting Thursday (53758).

In a filing with the PUC on Monday, Grid United said a preliminary order is not necessary, pointing to its pending motion to abate. It said the abatement will give it time to work with ERCOT in obtaining any required studies or evaluations and that it will likely amend the CCN application with additional data that commission staff have requested. Grid United also wants a ruling from FERC that the project won’t affect ERCOT’s non-jurisdictional status; former FERC Chairs Richard Glick and Pat Wood have both said recently that such links can be made between the Texas grid and the other two interconnections without changing that status.

PUC staff, for their part, filed a motion in December to dismiss, saying it needed more information from Grid United.

“The PUC wants you to file a bunch of alternatives before you do any right-of-way work. We were trying to do the right-of-way work upfront, and then the filings,” Skelly said. “We apply; they asked for more info; we go back. We’re in that process right now. So far, it feels like it’s going fine.”

The North Plains Connector project is further advanced. Grid United has been working with SPP staff since last year; a feasibility study’s scope was approved in September by the Transmission Working Group. Former SPP COO Carl Monroe sits on Grid United’s four-person advisory board.

Skelly said that FERC’s efforts to improve the generator-interconnection process and focus on making transmission easier to site, build and fund, has raised public recognition of the grid’s importance.

“There’s a heightened awareness of the need for transmission,” Skelly said. “Even when you talk to a landowner and you tell them what you’re doing, they go, ‘Yeah, the grid; we got to fix that grid. We’ve got to make that grid better.’ You go to a cocktail party and you talk about the grid, people are like, ‘I heard there’s some issue with the grid. What’s going on with that?’”

Another sign of transmission’s importance is what has happened to the projects Clean Line left behind.

The Western Spirit project, a 155-mile 345-kV line in New Mexico, was energized in 2021. Invenergy is still working on the Grain Belt Express, an 800-mile HVDC line capable of carrying 5 GW of energy that starts in Kansas, runs through Missouri and ends at the Illinois-Indiana border.

“It’s still alive,” Skelly said. “Well, more than alive. They’ve ordered equipment. … That’s huge. Ordering equipment is a big step. You don’t do that unless you’re going to build it.

“Those are our old projects, so we’re excited about that,” he added. “You go through all that and, ‘Wow! Yeah, things have changed since 2019.’”

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NYISO Promises to Lower DER Minimum Capability in Future

The NYISO Business Issues Committee on Wednesday voted to recommend that the Management Committee approve proposed tariff revisions to its participation model for distributed energy resource aggregations after the ISO committed to revisiting its unpopular 10-kW minimum for individual resource participation.

Stakeholders continued to express concern about the proposal, particularly the 10-kW rule, but were assuaged when NYISO promised it would re-evaluate “the ability of small facilities to provide wholesale market services as part of an aggregation” and look to “propose a set of market rules for small facilities that enhance grid reliability and resilience, reduce consumer costs, and lower barriers to entry for small DER.”

The 10-kW rule is perhaps the most controversial among a slate of revisions intended to integrate DER aggregations into NYISO’s markets. Although its model was approved in 2020, staff identified more changes they deemed necessary as they worked on implementing it. The ISO has said the rule is necessary while it gets used to integrating aggregations, as staff could be overwhelmed by so many smaller resources. (See NYISO 10-kW Min for DER Aggregation Participation Riles Stakeholders.)

Aaron Breidenbaugh, director of regulatory affairs at CPower Energy Management, said he understood ISO concerns about being potentially overburdened by thousands of small-scale DERs, but he still would have preferred that “some level of flexibility was built into the tariff” to allow future changes without having to go through a “multi-month process” that is required to make revisions.

Final Import Rights Results (NYISO) Content.jpgFinal import rights results for 2023-24 capability year | NYISO

 

Rana Mukerji, NYISO senior vice president, responded that the ISO’s “intention is to work with [stakeholders] to find rules where we can accommodate all resources.” NYISO is “far ahead of peer ISOs and RTOs on comprehensive DER implementation,” leaving plenty of time to resolve these issues, he said.

Breidenbaugh also mentioned that the two planned stakeholder outreach sessions focused on DER may not be enough to address these issues.

Michael DeSocio, NYISO director of market design, responded that those meetings “are meant to kick us off and figure out how to organize future discussions.” Mukerji followed up with saying that the ISO has “administrative burdens that we need to overcome to integrate an aggregation with very small resources,” so it is critical that “stakeholders actively participate to help [NYISO] figure out” how to best resolve DER implementation questions.

NYISO will seek MC approval of the proposal Feb. 22. If the proposal is approved by FERC, NYISO will accept customer registrations for aggregators in mid-April, and start open enrollment of DER and aggregations in early summer, when the revisions are expected to become effective. It anticipates DERs being dispatched approximately 90 days after they have applied or whenever the ISO completes mandatory workflow reviews.

The ISO also told stakeholders they could attend two training sessions: one dedicated to DER onboarding and market participation, and one on operations that includes an overview of the participation model and operation of the Grid Operations Communication Portal.

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NY Legislators Press Hochul Officials on Energy Transition

Republican and Democratic legislators reacted warily to New York Gov. Kathy Hochul’s climate and energy proposals during a marathon budget hearing Tuesday.

Hochul administration officials defended her agenda against Republicans who think it is too aggressive and Democrats who think it is not aggressive enough.

The 2023/24 budget Hochul proposed includes policy changes and spending decisions that would bolster efforts to slash greenhouse gas emissions and transition to clean energy. The first checkmark — 70% renewable energy by 2030 — is only seven years away.

Among Hochul’s proposals are:

  • a “cap-and-invest” program to cut greenhouse gas emissions;
  • authorization for the New York Power Authority (NYPA) to begin developing its own renewable projects; and
  • a prohibition on new gas-burning appliances and heating equipment.

Both houses of the state Legislature are held by a Democratic supermajority; Hochul, also a Democrat, has many priorities in common with them but diverges on some of the details of achieving those priorities, sometimes significantly.

Like her predecessors’ executive budgets, her record $227 billion proposal is a starting point for closed-door negotiations, an aspirational wish list that will not emerge intact.

Cap-and-invest

The cap-and-invest proposal was a frequent topic. Some legislators expressed reservations that Hochul’s proposal is short on details on how the program would be designed, how the resulting money would be spent, and how certain large emitters of greenhouse gases would be chosen for exemption from the requirements.

Sen. Liz Krueger, the Manhattan Democrat wielding the gavel during the hearing, pressed Basil Seggos, commissioner of the Department of Environmental Conservation, on how much control the Legislature would have.

Not much, suggested Seggos, who said DEC already has sweeping authority to create such a program.

Krueger wondered if Hochul’s plan is weaker than what was recommended in the scoping plan recently completed for the state’s landmark Climate Leadership and Community Protection Act (CLCPA).

“Look,” she said, “I support this effort, but I’m a little confused about what we’re signing off, particularly in perpetuity; that generally makes me nervous as a legislator.”

Seggos said the state is consulting with stakeholders on what the regulations and structure should be, and it would be premature for him to discuss it. “We will be coming back to the public at a very aggressive rate over the coming five months before we even get into the regulatory phase,” he said.

The deadline for passage of the budget is only six weeks away.

Sen. Michelle Hinchey, an upstate Democrat, alluded to a recurring issue in New York government: Who controls the purse strings? Hochul’s cap-and-invest proposal is short on details, she said.

“It’s hard from our place of responsibility to greenlight an entire program without really understanding — even if we all kind of believe kind of deeply in the foundational points of it — where that’s going to go because historically we have lost lots of money that way. So we want to make sure we’re tracking it and it’s actually going to the places it needs to.”

NYPA Boost

Democratizing the energy sector and expanding public ownership is a goal of numerous advocacy groups, many of which have thrown their support behind the proposed Build Public Renewables Act, which is similar to Hochul’s proposal for NYPA.

But they do not like the way Hochul is proposing to do it, and have dubbed it “BPRA Lite.”

Her budget would not require NYPA to undertake development — only authorize it to do so — and she would give NYPA considerable discretion on how to go about development. Union-friendly provisions of the BPRA also are missing from Hochul’s proposal.

Assemblyperson Zohran Kwame Mamdani, a New York City Democrat, pressed acting NYPA CEO Justin Driscoll on the missing labor provisions. “Why has that language been removed and how do these omissions better position the state to unionize and expand the workforce needed to meet the goals of the CLCPA?” Mamdani asked.

Driscoll replied that NYPA already requires prevailing wages on its projects and is open to project labor agreements. He said a $25 million training fund would be created for new workers.

“I don’t see what’s missing,” Driscoll said.

“Did NYPA or the governor speak to labor before drafting this version of the Build Public Renewables Act?” Mamdani asked.

Driscoll said he could not speak for the governor.

“But for NYPA?”

“I did not personally. I can’t speak for my staff.”

NYPA acknowledged the “great challenge” of building renewables but is committed to doing it as economically as possible, Driscoll said.

NYPA needs to have case-by-case discretion on developing renewable energy projects, Driscoll said, which is why Hochul proposes to authorize NYPA to take such steps, not require it to.

NYPA could undertake small renewable projects on its own but is more likely to partner with other entities on larger projects because of its finite resources, Driscoll said.

Fear Factor

Hochul’s bill calls for a ban on installation of fossil fuel building systems in newly constructed residential buildings up to three stories tall starting Dec. 31, 2025, and in taller buildings starting Dec. 31, 2028. Retrofits in existing buildings up to three stories would be banned starting Jan. 1, 2030, and in taller buildings starting Jan. 1, 2035.There’s no specific ban on gas stoves proposed, but a ban on installing gas systems would at some point begin to limit use of gas cooking equipment.

Sen. Mario Mattera, a Republican representing some of Long Island’s suburbs, said constituents are anxious over being told they will need to replace their familiar fossil-burning fixtures with technologies whose costs, reliability and even availability are still unknown.

“People are frightened right now,” he told Doreen Harris, CEO of the New York State Energy Research and Development Authority (NYSERDA).

A similar question had been asked of her earlier, and Harris again acknowledged the challenges facing the state, not least of which is building out electric vehicle charging infrastructure in New York City.

“You’re still not answering the question,” Mattera said. “Is this [reaching the state’s 2030 goals] feasible?”

“Certainly when we look … at the goals in the climate law for 2030, we do see them as feasible,” Harris replied. However, she acknowledged his point about communicating not just the goals for CLCPA but the steps that will be taken to reach them.

“We are not taking away gas stoves, as one example of perhaps misinformation we need to correct,” she said. “Also, we are going about this in a measured and deliberate way that does not create cliffs or specific reasons for alarm. This is a very rational, thought-out plan.”

Long Day of Q&A

The legislators had as little as three minutes each to question the witnesses, and some prefaced their questions with their own thoughts and opinions. So even though the hearing lasted more than 13 hours, witnesses often had time only to dash off half-answers or promise to follow up.

But the Q&A did yield some nuggets of information, including:

  • New York’s existing nuclear power plants are central to achieving the state’s goals, and the advanced nuclear technology now in development could also provide cost-effective benefits, Harris said.
  • Seggos said DEC will soon request proposals for a consultant to assess the cryptocurrency mining industry, which is under a two-year moratorium on building more of its power-intensive server farms in New York.
  • Only about 20% of the 11,000 communal EV charging station plugs in New York are accessible to the general public, Harris said.

Rory Christian, chair of the Public Service Commission, acknowledged complaints about the inability to connect new generation to the power grid but said the PSC is aggressively working on the issue and is on track to have generation and transmission infrastructure in place to accommodate all the electrification planned by 2030.

Rory Christian Houtan Moaveni (New York State Legislature) Content.jpgRory Christian, chairman of the New York State Public Service Commission (left), and Houtan Moaveni, executive director of the New York state Office of Renewable Energy Siting, speak Tuesday at a joint legislative hearing on environmental conservation spending in the 2023-2024 budget proposed by New York Gov. Kathy Hochul. | New York State Legislature

The PSC’s mission and goal is preserving reliability of the power system through the clean-energy transition, Christian said, and if the transition plans are delayed or derailed, the plans will be reworked because reliability will remain paramount.

Hinchey, who chairs the Senate Agriculture Committee and represents a wide swath of farming communities, said there are too few braking mechanisms on development of productive farmland for solar arrays.

“We can’t replace a climate crisis with a food crisis,” she said.

Houtan Moaveni, executive director of the Office of Renewable Energy Siting (ORES), said the state will not meet its CLCPA goals without such integration of uses. He said ORES is looking at the marriage of the two through agrivoltaics but does not want to be prescriptive.

Hinchey thought it would make sense to hold off solar siting on farmland until agrivoltaic technology is mature and available because once farmland is gone, it is hard to get back.

The clock ran out before Moaveni could respond.